Guide
Is the P11D being abolished? What survives after April 2027
Updated
The headline everywhere is that the P11D is dead. It is not. It shrinks, twice, and keeps a job that gets more awkward as fewer employers use it.
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.
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Where the P11D still applies
- Employment-related loans and living accommodation, which are excluded from both mandation phases and can only be payrolled voluntarily.
- Benefits outside the phase 1 list, until April 2028. If you provide, say, gym membership but no cars and no medical cover, nothing about your reporting changes on 6 April 2027.
- Employees who cannot be payrolled. HMRC's guidance carries a chapter on reporting benefits for employees whose benefits cannot be payrolled, and the penalties chapter refers to incorrect submission of a P11D or P11D(b) as a live risk after 2027.
- Excluded employees under the current voluntary regime, where a P11D is used to declare the non-payrolled benefit.
What definitely changes
For a phase 1 benefit, the annual P11D entry is replaced by a value in every pay period on the Full Payment Submission.
HMRC says FPS fields will increase to cover company cars, car fuel, vans, van fuel and private medical benefits. It needs that visibility to check the right tax is reported and paid (gov.uk).
The deadlines you still need in the diary
| What you need to do | Deadline after the end of the tax year |
|---|---|
| Report expenses and benefits | 6 July |
| Give employees a copy of the information | 6 July |
| Report the total Class 1A National Insurance you owe | 6 July |
| Pay Class 1A National Insurance | 22 July, or 19 July if paying by cheque |
| Pay tax and Class 1B on a PAYE Settlement Agreement | 22 October, or 19 October if paying by cheque |
The late P11D(b) penalty is £100 per 50 employees for each month or part month the return is late, plus penalties and interest for late payment (gov.uk). Those deadlines and penalties are unchanged by mandatory payrolling for anything you still report at year end.
The awkward year
2027 to 2028 is the year employers run both systems: real-time reporting for cars and medical cover, and a P11D exercise in July 2027 for the 2026 to 2027 year.
Budget for the July 2027 P11D cycle even though the old system feels like it should be gone. See what happens to Class 1A, where the cash flow surprise sits.
If you provide only loans or accommodation, nothing about your reporting changes at all. That is a genuinely correct answer, and most summaries do not give it.