HMRC, phased from 6 April 2027
What is changing for P11Ds?
Mandatory payrolling was due in April 2026 and was pushed back a year: it now starts on 6 April 2027, and it is phased. Phase 1 covers company cars, car fuel, vans, van fuel and employer-provided medical benefits, which move to real-time reporting on the Full Payment Submission with Income Tax and Class 1A National Insurance calculated in year. Most remaining benefits follow in April 2028. Loans and living accommodation stay voluntary. Answer three questions to see what applies to you.
Question 1
Which taxable benefits do you provide to employees or directors?
Pick the one that matters most to you. You can run the checker again for the others.
What this checker covers
- Which benefits are mandated from 6 April 2027 and which wait until April 2028
- Employment-related loans and living accommodation, which stay voluntary
- Whether you need to register (for the mandated benefits, no)
- What happens to the P11D and the P11D(b), and to Class 1A National Insurance
- The registration window that closed on 5 April 2026 and reopens in November 2026
- Based on HMRC's interim guidance and the July 2026 policy paper; detailed scope comes in secondary legislation at Budget 2026
P11D Changes is an independent information site operated by Ellul Solutions Ltd. It is not affiliated with HM Revenue and Customs or any government department, and nothing here is tax advice. HMRC's detailed scope, exclusions and operational rules are due in secondary legislation at Budget 2026: confirm the current position on gov.uk before acting.
Benefit by benefit: how reporting changes in 2027 and 2028
Last updated
What moves into real-time payroll reporting, when, and what stays on the P11D. Phase 1 is a short list, which is the point most summaries get wrong.
Compiled from HMRC's interim guidance 'Mandatory payrolling of benefits in kind and expenses' (published 26 November 2025, updated 31 July 2026) and the policy paper 'Mandatory reporting of benefits in kind in Real Time Information (RTI) from April 2027', both on gov.uk, as at the updated date above. HMRC has confirmed that secondary legislation setting out the detailed scope, exclusions and operational rules will be introduced at Budget 2026, so the phase 2 list in particular may be refined. No penalty or cost figures are invented here: the penalty position quoted comes from HMRC's own penalties and interest chapter.
| Benefit | How it is reported now | From 6 April 2027 | From 6 April 2028 |
|---|---|---|---|
| Company car | P11D after year end, or payrolled if registered before 6 April 2026 | Payrolled through the FPS, mandatory | Payrolled, mandatory |
| Car fuel | P11D after year end, or payrolled if already registered | Payrolled through the FPS, mandatory | Payrolled, mandatory |
| Van, and van fuel | P11D after year end, or payrolled if already registered | Payrolled through the FPS, mandatory | Payrolled, mandatory |
| Employer-provided medical benefit | P11D after year end, or payrolled if already registered | Payrolled through the FPS, mandatory | Payrolled, mandatory |
| Most other taxable benefits and expenses | P11D after year end, or payrolled if already registered | Unchanged: P11D, or voluntary payrolling | Payrolled, mandatory |
| Employment-related loans | P11D after year end (cannot be payrolled today) | Voluntary payrolling only, registration required | Still voluntary |
| Living accommodation | P11D after year end (cannot be payrolled today) | Voluntary payrolling only, registration required | Still voluntary |
| Class 1A National Insurance on the above | P11D(b) by 6 July, paid by 22 July | Reported and paid in real time for mandated benefits | Real time for mandated benefits; P11D(b) for the rest |
- Mandatory payrolling of benefits in kind starts on 6 April 2027 and is phased: phase 1 covers company cars, car fuel, vans, van fuel and employer-provided medical benefits, and phase 2 from 6 April 2028 covers most remaining benefits.
- Employment-related loans and living accommodation are excluded from both phases and remain voluntary, so employers providing them will still file a P11D and P11D(b) unless they register to payroll them.
- Employers do not need to register to payroll the benefits that become mandatory in April 2027; registration is needed only for non-mandatory benefits, through a service opening in November 2026 with a deadline of 5 April 2027.
Cite this page
“Benefit by benefit: how reporting changes in 2027 and 2028”, P11D Changes, https://p11dchanges.co.uk/ (updated 2026-08-14). Compiled from HMRC's interim guidance 'Mandatory payrolling of benefits in kind and expenses' (published 26 November 2025, updated 31 July 2026) and the policy paper 'Mandatory reporting of benefits in kind in Real Time Information (RTI) from April 2027', both on gov.uk, as at the updated date above. HMRC has confirmed that secondary legislation setting out the detailed scope, exclusions and operational rules will be introduced at Budget 2026, so the phase 2 list in particular may be refined. No penalty or cost figures are invented here: the penalty position quoted comes from HMRC's own penalties and interest chapter.
Need help getting payroll ready for 2027?
We'll introduce you to a payroll bureau or accountant who handles benefit in kind reporting and can review your readiness.
Related guides
Each one cites where its numbers come from.
Mandatory payrolling of benefits in kind: what happens in April 2027
From 6 April 2027 employers must payroll cars, car fuel, vans, van fuel and medical benefits, reporting Income Tax and Class 1A through the Full Payment Submission.
Is the P11D being abolished? What survives after April 2027
The P11D is not abolished. It survives for loans, living accommodation, excepted employees and, until April 2028, most benefits outside the phase 1 list.
Class 1A National Insurance from April 2027: the double payment year
Class 1A moves into real-time reporting for mandated benefits from April 2027, while the July 2027 P11D(b) payment for 2026 to 2027 still falls due.
Payrolling benefits registration: closed, and reopening November 2026
You can only payroll benefits registered before 6 April 2026. Registration for voluntary payrolling of non-mandatory benefits reopens in November 2026.
Straight answers
When does the P11D change take effect?
6 April 2027 for phase 1, which covers company cars, car fuel, vans, van fuel and employer-provided medical benefits. Phase 2 follows on 6 April 2028 for most remaining benefits in kind. Employment-related loans and living accommodation are excluded from both and stay voluntary.
Which benefits must be payrolled from April 2027?
Company cars, car fuel, vans, van fuel and employer-provided medical benefits, together with taxable expenses. They are reported through the Full Payment Submission with Income Tax and Class 1A National Insurance calculated in real time.
Do employers have to register for mandatory payrolling?
No. HMRC has confirmed employers will not need to register in order to payroll the mandatory benefits from April 2027. Registration is required only for voluntary payrolling of non-mandatory benefits, through a service opening in November 2026 with a 5 April 2027 deadline.
What happens to the P11D(b) and Class 1A National Insurance?
For mandated benefits, Class 1A is reported and paid in real time through payroll from April 2027. Where you still report benefits at year end, such as loans and accommodation, the P11D(b) and the 6 July and 22 July deadlines continue to apply, along with the £100 per 50 employees monthly late filing penalty.
Will employees pay more tax because of payrolling?
No more tax overall, but the timing changes: tax on a benefit is paid in the year it is received rather than in arrears through a tax code adjustment. HMRC will remove payrolled benefits from tax codes ready for April 2027, though underpayments from earlier years stay in the code, which can make it look like double taxation.
Are penalties being charged during the first year?
HMRC has said that for 2027 to 2028, inaccuracy penalties will not be charged for errors related to mandatory payrolling in RTI returns unless there is evidence of deliberate non-compliance. Existing late filing and late payment penalties still apply, and full penalties and interest resume from 2028 to 2029.
Find out what actually changes for you
Three questions and you will know which phase you are in, whether you need to register, and what to ask your software provider.
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