P11D Deadline Has Passed: What UK Employers Should Check Now

The P11D deadline for the 2025/26 tax year was 6 July 2026.

If you are a UK employer, company director or small business owner, this is a good moment to check whether your P11D obligations were dealt with properly.

P11D reporting is one of those areas that can easily be missed, especially in smaller companies where benefits are informal, expenses are paid through director accounts, or payroll and bookkeeping are managed separately.

What is a P11D?

A P11D is a form used to report certain taxable expenses and benefits provided to employees and directors.

These are often called benefits in kind. They are benefits provided by the business that have a personal value to the employee or director, even if no cash has been paid directly to them.

Common examples can include:

• Company cars or fuel benefits

• Private medical insurance

• Interest free or low interest loans

• Living accommodation

• Assets made available for personal use

• Certain travel, subsistence or entertainment expenses

• Other non-exempt expenses or benefits provided outside payroll

Not every expense or benefit needs to go on a P11D. Some expenses are exempt, some may already be taxed through payroll, and some may not create a taxable benefit at all. The important point is that the position should be reviewed rather than assumed.

What is a P11D(b)?

P11D(b) is the employer’s declaration to HMRC.

It tells HMRC how much Class 1A National Insurance the employer owes on taxable benefits provided to employees and directors.

You may need to submit a P11D(b) if:

• You have submitted any P11D forms

• You have provided taxable benefits or non-exempt expenses

• You have payrolled benefits

• HMRC has issued a notice asking you to file one

This is a common area of confusion. Even where benefits are payrolled, a P11D(b) may still be required because the employer still needs to report and pay the Class 1A National Insurance due.

What were the 2025/26 deadlines?

For the tax year ended 5 April 2026, the key dates were:

• 6 July 2026: submit P11D forms to HMRC

• 6 July 2026: give employees a copy of their P11D information

• 6 July 2026: submit P11D(b)

• 22 July 2026: pay Class 1A National Insurance electronically

• 19 July 2026: payment deadline if paying by cheque

HMRC’s guidance confirms the standard deadlines for reporting expenses and benefits, giving employees the information, reporting Class 1A National Insurance and paying Class 1A National Insurance. You can read the HMRC deadline guidance here.

HMRC’s June 2026 Employer Bulletin also states that all P11Ds and P11D(b) for the 2025/26 tax year must be filed online and at the same time. You can read the HMRC bulletin here.

What happens if the P11D deadline was missed?

If the deadline has been missed, it is better to act quickly rather than ignore it.

Late filing penalties can apply, and HMRC may also charge interest or penalties if Class 1A National Insurance is paid late.

The next step is usually to review whether a P11D or P11D(b) was actually required, check what benefits or expenses were provided during the year, and submit any outstanding forms as soon as possible.

If HMRC issued a notice to file but no taxable benefits were provided, the business may still need to tell HMRC that no return is due.

Why small companies often miss P11D reporting

P11D issues are not limited to large employers.

Small companies can easily have reportable items without realising it. For example:

• A director has private medical insurance paid by the company

• A company car is available for private use

• The company pays for personal expenses through the business account

• A director has an overdrawn loan account

• Staff receive benefits that are not processed through payroll

• Expenses are reimbursed but not reviewed for tax treatment

The issue is rarely intentional. More often, the business simply does not realise that a benefit has been created.

What should you check now?

If you are unsure whether your company had a P11D requirement for 2025/26, start with these questions:

• Did the company provide any benefits to directors or employees?

• Were any personal costs paid through the business?

• Were any expenses reimbursed that may not be exempt?

• Were any benefits already payrolled?

• Did HMRC send a P11D(b) reminder or notice to file?

• Has Class 1A National Insurance been calculated and paid?

If the answer to any of these is yes or unclear, it is worth reviewing the position.

P11D reporting is changing

HMRC is moving towards mandatory payrolling of most benefits in kind from April 2027.

This means employers will increasingly need to report benefits through payroll in real time, rather than dealing with everything after the tax year end through P11D forms.

For small businesses, this makes it even more important to have clear processes for expenses, benefits, payroll and director transactions.

Need help reviewing your P11D position?

If your accountant has already dealt with your P11D and P11D(b), there may be nothing further to do.

But if you are unsure whether anything was filed, or you think something may have been missed, Juniper can help you review your position and deal with any outstanding reporting.

We support UK small businesses with bookkeeping, payroll, VAT, management accounts and year-end compliance support.