What are P11Ds and when are they needed?

Benefits can include company cars, private medical cover and certain loans, but each has its own valuation, exemption and reporting rules. Do not assume every reimbursed expense needs a P11D: qualifying business expenses may be exempt. For taxable benefits not payrolled, a P11D is normally required for each relevant employee or director. Payrolling an eligible benefit generally removes the separate P11D requirement for that item, but a P11D(b) can still be needed for Class 1A National Insurance. Returns are normally due by 6 July after the tax year ends. Keep invoices, benefit agreements and any employee contributions so the figures can be checked against the payroll records.

HMRC’s August 2026 guidance says mandatory payrolling starts on 6 April 2027 for cars and car fuel, vans and van fuel, and employer-provided medical benefits. Most other benefits are planned to follow from April 2028, so this is not a single switch for every item. Check the current implementation guidance before the relevant tax year, including how employer National Insurance will be handled. For 2026/27, continue to follow the reporting rules applicable to your arrangements. CASS can help build a benefits register, identify the forms still needed and prepare the payroll data. That gives you time to resolve missing valuations before the annual deadline or a change in reporting.