A P11D is a form that employers must submit to HMRC each year to report the value of any non-cash benefits and expenses provided to employees or directors that have not already been taxed through payroll. If you employ anyone — or are a director drawing benefits from your company — you almost certainly need to understand your P11D obligations. The deadline is 6 July following the end of each tax year.
What benefits need to be reported on a P11D?
Not every benefit triggers a P11D. HMRC distinguishes between taxable benefits in kind (which must be reported) and exempt benefits (which do not need to be declared). The table below covers the most common items on both sides.
| Benefits requiring a P11D | Benefits exempt from P11D |
|---|
| Company car (personal use element) | Mobile phone — one per employee (per HMRC) |
| Private medical or dental insurance | Employer pension contributions |
| Interest-free or low-interest loans exceeding £10,000 | Cycle to work scheme |
| Non-business entertainment (e.g. client lunches with personal element) | Electric car charging at the workplace |
| Company-provided accommodation (where taxable) | Trivial benefits — per item value under £50, not cash (per HMRC) |
| Non-business travel and subsistence | Annual staff party or event up to £150 per head (per HMRC) |
| Childcare vouchers (post-October 2018 schemes) | Childcare vouchers (legacy pre-October 2018 registered schemes) |
The trivial benefit exemption is a practical tool for small employers. Per HMRC, a benefit is trivial and exempt if it costs £50 or less per employee (or per occasion), is not cash or a cash voucher, is not provided as a reward for services, and is not contractual. Directors of close companies (typically owner-managed limited companies) face an annual cap of £300 for trivial benefits — not a per-occasion limit.
The mobile phone exemption applies to one mobile phone per employee — the entire benefit is exempt regardless of cost or personal use. A second phone provided to the same employee is fully taxable. A data plan or SIM provided separately is treated as a separate benefit and may be taxable depending on the arrangement.
When is the P11D deadline?
There are three key P11D dates each year, all per HMRC. Missing any of them triggers penalties.
P11D filing deadlines
- · 6 July — P11D (individual employee forms) submitted to HMRC
- · 6 July — P11D(b) (employer declaration of total Class 1A NI due) submitted to HMRC
- · 6 July — Copies of P11D provided to each affected employee
- · Both forms relate to benefits provided in the tax year ending 5 April
Class 1A NI payment deadlines
- · 19 July — Class 1A National Insurance payment (cheque or bank transfer)
- · 22 July — Class 1A NI payment by electronic transfer (BACS/Faster Payments)
- · Class 1A NI rate: 13.8% of the taxable value of benefits provided (per HMRC)
- · The employer bears this cost — it is not deducted from the employee
Late filing of P11D or P11D(b) carries a penalty of £100 per 50 employees (or part thereof) for each month or part month the forms are late, per HMRC. A single-director company with one P11D filed one month late would incur a £100 penalty. Errors in P11D figures can also trigger penalties if HMRC considers them careless or deliberate.
How do you submit a P11D?
Paper P11D forms are no longer accepted — HMRC requires all P11D submissions to be made online, per HMRC guidance in force from April 2023. There are two main online routes: HMRC's PAYE Online service (free, suitable for small employers with few P11Ds) and commercial payroll or expense management software that submits directly to HMRC via the PAYE API.
You must file a separate P11D for each employee or director who received taxable benefits during the tax year. The P11D(b) is a separate form — the employer's summary declaration — which states the total value of all benefits and the total Class 1A NI due. You must file a P11D(b) even if you file no individual P11Ds, if HMRC has asked you to or if you payroll benefits (in which case it still declares the Class 1A amount).
An important point for directors: if you are the sole director and shareholder of your own company, you are both the employer (completing P11D(b)) and the employee (receiving the P11D). The obligations are the same as for any employer/employee relationship — the fact that they are the same person does not remove the filing requirement.
What is payrolling benefits and is it better than P11D?
Payrolling benefits is the alternative to filing P11D forms. Instead of reporting benefits after the tax year end, you include the cash equivalent of benefits in the employee's monthly payroll — meaning the employee pays income tax on benefits in real time through PAYE, rather than through a tax code adjustment the following year. You must register with HMRC before 5 April to payroll benefits in the following tax year. You cannot register mid-year and apply it to that year's benefits.
The advantages of payrolling are significant for businesses with multiple employees receiving benefits. There is no P11D to file for payrolled benefits (though P11D(b) for Class 1A NI is still required). Employees see the benefit value on their payslip each month, which is clearer and eliminates the year-end tax code adjustments that frequently confuse employees. HMRC has signalled that payrolling will eventually become mandatory, making early adoption sensible.
The main constraint is the advance registration requirement. If you miss the 5 April deadline, you must continue filing P11D forms for that tax year and can only switch to payrolling from the following April. A few benefits cannot currently be payrolled — most notably employer-provided living accommodation and beneficial loans — and must still be reported via P11D regardless.
How is the P11D value of a company car calculated?
The taxable value of a company car is calculated using the cash equivalent method: the car's list price (including factory-fitted options, delivery, and VAT) multiplied by a benefit in kind (BIK) percentage that is set by HMRC based on the car's CO2 emissions. The BIK percentage increases each year per HMRC's published rates.
| Vehicle type / CO2 emissions | BIK % for 2025/26 (per HMRC) | Example: £40,000 list price |
|---|
| Fully electric (0g/km CO2) | 2% | £800 taxable value |
| 1–50g/km CO2 (electric range > 130 miles) | 2% | £800 taxable value |
| 51–75g/km CO2 | 17% | £6,800 taxable value |
| 76–94g/km CO2 | 23% | £9,200 taxable value |
| 150g/km+ CO2 (high-emission vehicle) | Up to 37% | Up to £14,800 taxable value |
For a fully electric company car with a list price of £40,000, the taxable benefit in 2025/26 is £800 (£40,000 × 2%). A basic-rate taxpayer would pay 20% income tax on that — £160 per year. The employer would pay 13.8% Class 1A NI — £110.40 per year. This is why fully electric company cars remain extremely tax-efficient. The BIK percentage for electric cars rises by 1 percentage point each year, reaching 9% by 2030/31, per HMRC's published rates.
For further reading on employer obligations, see our guide to bookkeeping for small businesses. The accounting and tax resources hub has additional guidance on payroll, corporation tax, and PAYE compliance.
Frequently asked questions
What is the P11D deadline for 2025/26?
The P11D deadline for the 2025/26 tax year (benefits provided between 6 April 2025 and 5 April 2026) is 6 July 2026, per HMRC. This covers both the individual P11D forms for each employee and the P11D(b) employer declaration. Class 1A National Insurance must be paid by 19 July 2026 (or 22 July for electronic payment).
Do I need to file a P11D if I only provided trivial benefits?
No. Per HMRC, trivial benefits under £50 per item that are not cash, not contractual, and not provided as a reward for services are exempt from P11D reporting entirely. There is no need to include them on a P11D or declare them to HMRC. Directors of close companies have an annual trivial benefit cap of £300, not per-item.
Can employees avoid tax on company car benefits?
No — company car benefits in kind are taxable income for the employee. The employee pays income tax at their marginal rate on the P11D value. The most effective way to reduce the tax charge is to choose a low-emission or fully electric vehicle, as the BIK percentage is much lower. Alternatively, the employer can offer a salary sacrifice car scheme, which has different tax treatment.
What is the penalty for filing P11D late?
Per HMRC, late filing of P11D or P11D(b) incurs a penalty of £100 per 50 employees (or part thereof) per month or part month that the forms are outstanding. This means a small employer with one employee filing one month late would face a £100 penalty. Persistent late filing can also trigger HMRC compliance reviews.
If I payroll benefits, do I still need to file anything with HMRC?
Yes — you still need to file a P11D(b) to declare the total Class 1A National Insurance due on all payrolled benefits, and pay that Class 1A NI by 22 July (electronic) or 19 July (other methods). You do not need to file individual P11D forms for benefits you have successfully payrolled, but registration with HMRC must have been completed before 5 April of the relevant tax year.