Employers must submit the following forms to HMRC for 2024/25:
- form P11D for each employee in receipt of benefits in kind which have not been processed via the payroll; and
- form P11D(b), reporting the total amount of class 1A national insurance contributions (NIC) payable by the employer on benefits in kind. It is still necessary to submit form P11D(b) even if all benefits have been processed via the payroll.
Forms P11D and P11D(b) can only be submitted online, using HMRC’s online PAYE service (for employers with up to 500 employees) or other payroll software.
Deadlines
The deadline for submitting forms P11D and P11D(b) for 2024/25 to HMRC is 6 July 2025. It should be noted that 6 July falls on a Sunday this year.
6 July 2025 is also the deadline for the employer to give employees details of the benefits in kind and for submitting employment related securities returns.
Class 1A NIC must be paid by 22 July if paying electronically, or by 19 July if paying by cheque. See HMRC’s guidance on how to make a payment.
How to correct mistakes
HMRC only accept one electronic P11D submission for each PAYE reference using payroll software. Therefore, if an error is discovered after forms have been filed, the amendment must be submitted electronically using HMRC’s correction service. Amended paper forms will not be accepted by HMRC.
There is no specific time frame for amendments to these forms, but corrections should be submitted as soon as the employer becomes aware of any errors. Class 1A NIC may need to be recalculated if the original reports contained incorrect values. The employer will also need to provide the employee with an amended P11D if the values have been changed as the employee may need to file a self assessment tax return using this information.
Penalties
Penalties for late and incorrect filing may be applied by HMRC. Late filing of the P11D(b) may attract a penalty of £100 per every 50 employees (or part of 50) per month, or part-month until payment is received. The maximum penalty for submitting an incorrect form P11D is £3,000 per form.
The future of forms P11D and P11D(b)
It has been said that mandatory payrolling of benefits in kind, which has been delayed to 6 April 2027, will mark the end of forms P11D and P11D(b). However, it is likely that the forms will remain in place for some time longer due to accommodation and loan benefits which will be excluded from mandatory payrolling, at least to begin with. We await further guidance as to how class 1A will be reported and paid on a real time basis.
Further information
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