What is a P11D and who needs to complete one?
Answered 11 March 2026
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What is a P11D and Who Needs to Complete One?
What the law says
The P11D is a statutory return — formally titled the "Return of Expenses and Benefits" — that employers are required to submit to HMRC. Under the PAYE Regulations (regulations 85–96), an employer must complete and submit a P11D form to HMRC including all benefits and expenses paid to or on behalf of employees that are not accounted for through PAYE returns, including items such as beneficial employment-related loans and medical insurance.
Benefits in kind are chargeable to income tax under ITEPA 2003 on an amount of general earnings and must be reported on form P11D. The P11D is also the mechanism by which Class 1A National Insurance Contributions (NICs) are assessed, as Class 1A NICs are calculated by reference to the cash equivalent of a benefit reported by employers on the P11D.
HMRC guidance / practice
Who must complete a P11D: Employers are required to complete a form P11D for any director, or employee that they provided benefits in kind to within the tax year.
What is reported:
- Benefits in kind (e.g. company cars, private health insurance, living accommodation) are reported on form P11D unless made good in full by the employee before the P11D is due to be submitted.
- Expenses payments (e.g. reimbursements of non-business expenses) that are not put through payroll must also be returned on form P11D.
- From 6 April 2016, expenses and benefits that would be fully deductible for the employee are exempt and do not need to be reported on form P11D.
Filing deadline: From 6 April 2023, employers were mandated to file their P11D returns online by 6 July each year.
The companion form — P11D(b): Alongside the P11D, employers must also submit a P11D(b) (Return of Class 1A NICs), which summarises the total Class 1A NIC due on all benefits reported across the individual P11D forms. Class 1A NICs are payable by 19 July (or 22 July if paying electronically) following the end of the tax year.
HMRC guidance resources: HMRC provides a range of supporting materials to help employers complete the forms, including the P11D Guide, P11D Working Sheets, and Leaflet CWG5 on Class 1A NICs on benefits in kind.
In summary: A P11D is an annual employer return used to report taxable expenses and benefits in kind provided to directors and employees that have not been taxed through PAYE. Any employer who has provided such benefits to a director or employee during the tax year must complete one, filing online by 6 July following the end of the tax year.
Citation sources
Liability for Class 1A NICs arises where: the benefit provided is chargeable to income tax under ITEPA 2003 on an amount of general earnings, section 10(1)(a) of the SSCBA 1992 refers. For more information see NIM13021 And a liability for UK NICs arises, see NIM13040. Providing these two primary conditions are satisfied, Class 1A NICs are: a secondary contributor’s liability only, normally an employer’s, except in limited circumstances where a benefit is provided by a third party, see NIM16350
Specific reimbursements of private expenditure, such as home to work travel expenses, should be included in taxable pay and PAYE should be applied. Reimbursements of other expenses, (including payments at scale rates approved by HMRC), related to the employment should not be included in taxable pay for any employees, and PAYE should not be applied. Instead they should be returned on form P11D for directors and employees earning at the rate of £8,500 a year or more. The amounts returned can be co
The P11D(b) Summary Information screen / pop-up displays The total Class 1A NIC due on the benefits shown on forms P11D The employers Class 1A NIC amount payable as captured from forms P11D(b) To access the screen / pop-up Select the [Summary] button on the P11D(b) screen In some cases all the summary information will not be available, for example where all the forms P11D have not yet been examined or the form P11D(b) has not yet been captured. Where the information from the P11Ds is not complet
Guidance on Class 1A NICs for employers is available on GOV.UK. These include: Leaflet CWG5: Class 1A NICs on Benefits in Kind Leaflet CA33: Cars and Fuel Class 1A National Insurance contributions on car and fuel benefits P11D Guide: A brief guide to help employers complete forms P11D and P11D(b) P11D Working Sheets: Optional working sheets for calculating the cash equivalent of certain benefits. For example, P11D working sheet 1 helps an employer calculate the cash equivalent in respect of cert
Employers are required to complete a form P11D for any director, or employee that they provided benefits in kind to within the tax year. From 6 April 2023 employers were mandated to file their P11D returns online by 6 July each year. Where forms P11D are not received by the due date,the employer will receive a Penalty warning letter. Penalty warning letters will not be issued in the following circumstances Permanent or temporary inhibition signal is set A P11D(b) has been received A P11D is not
S289A ITEPA 2003 For periods prior to 6 April 2016 see EIM30050. From 6 April 2016 employers will no longer be able to apply to HMRC for a dispensation in relation to expenses or benefits that they pay, reimburse or provide to employees and which would previously have been fully matched by a deduction from the employee’s earnings. All existing dispensations will cease to be effective after 5 April 2016. See EIM30215. Almost all expenses or benefits that might previously have been covered by a di
Benefits in kind are reported on form P11D unless made good in full by the employee before the P11D is due to be submitted. Subject to the full amount of the benefit being chargeable, benefits in kind are explained at EIM20000 onwards.
e Income Tax (Pay As You Earn) Regulations 2003 (“the PAYE Regulations”). Section 336 of ITEPA sets out the general rule that an employer is allowed to deduct expenses from an employee’s earnings provided that the employee is obliged to incur and pay those expenses as holder of the employment and that the amount is incurred “wholly, exclusively and necessarily” in the performance of the duties of the employment. Other sections within Part 5 of ITEPA then go on to provide specific rules for parti