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P11Ds: filing online when a different agent is authorised for PAYE


Published: 19 May 2023 Update History

Many employers will outsource their payroll to one agent but use another for P11D reporting. As HMRC systems do not have the functionality to recognise multiple agents for the same head of duty (eg, employers’ PAYE), concerns have been raised about how agents in this situation can submit P11Ds online for clients. ICAEW’s Tax Faculty shares the solution.

It is not uncommon for employers to split responsibility for their employment tax reporting between: 

  • A payroll agency that handles payroll. They are the authorised agent on HMRC systems for employers’ PAYE and make all RTI submissions on behalf of the employer.
  • The ‘main’ tax agent who submits the annual report of taxable expenses or benefits provided to employees (P11Ds), as well as providing other (non-employer PAYE related) tax services. 

HMRC’s systems do not currently have the functionality to recognise multiple agents for the same head of duty – employers’ PAYE in this case. 

As P11Ds and P11D(b)s must be submitted only online from 6 April 2023, concern has been raised about how the ‘main’ tax agent in this situation can submit the P11Ds electronically as they are not the client’s authorised agent for employers’ PAYE. 

ICAEW raised this issue with HMRC. HMRC has advised ICAEW that an agent can file P11Ds and P11D(b)s, including amendments, for an “unauthorised” client. They would need to add the client to their unauthorised client list in their Agent portal. Once they have done that, they are then able to file returns on behalf of the client. 

If the agent does not have log in credentials, which may be the case if they have been filing by paper previously, they would need to register themselves first, before being able to log in and then add a client to their unauthorised list. 

If the agent needs to register to obtain an agent reference for PAYE, they should do so in enough time to receive a PIN code through the post to meet the 6 July P11D filing deadline. 

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