Guidance on how to complete P11D forms (480: Chapter 25)
How to complete form P11D if you’re an employer and need to report end-of-year expenses and benefits for employees and directors.
Overview
25.1
A separate form P11D should be used for each employee. Apart from the information given in this tax guide, you should also reference:
- How to complete P11D and P11D(b)
- Class 1A National Insurance contributions on benefits in kind (CWG5)
- CWG2: further guide to PAYE and National Insurance contributions
25.2
A form P11D should be completed either by the:
- employer
- person making the expenses payments to, or giving benefits for, the employee
This is where the payment or provision is by reason of the individual’s employment (read paragraphs 1.23 to 1.25 of chapter 1). Employees should send their Section 336 claims for deduction against expenses to HMRC.
25.3
Each form P11D should contain details of all non-exempt expenses payments and benefits given for the employee concerned, whether the payment is made:
- to the director or employee personally
- to a third party including a credit card company
You do not have to include items for which an exemption applies or are covered by a PAYE Settlement Agreement (read CWG2: further guide to PAYE and National Insurance contributions).
You should include expenses payments from which tax has been deducted under PAYE.
A P11D is not needed where an employer:
- has registered to either payroll benefits or expenses, or both
- has deducted tax under PAYE and sent these details by Real Time Information (RTI)
25.4
Any benefits given to the employee’s spouse, family or household member must be treated as though they were given to the employee personally. Read paragraph 1.22 of chapter 1.
25.5
Employers pay Class 1A National Insurance contributions on numerous benefits. Check which benefits you need to pay Class 1A National Insurance contributions for in Expenses and benefits: A to Z.
Employers who are registered to payroll benefits must also pay Class 1A National Insurance contributions. Read more information in Class 1A National Insurance contributions on benefits in kind (CWG5) and how to complete P11D and P11D(b).
However, the employer must pay the Class 1A National Insurance contributions due by:
- 19 July after the end of the tax year if paying by post or cash
- 22 July after the end of the tax year if paying electronically
If the employer pays late, or does not pay enough, interest will be charged on the amount outstanding after 19 July.
Information in list form
25.6
HMRC stopped accepting lists of P11D information on 6 April 2023. A list of Mileage Allowance Relief Optional Reporting Scheme (MARORS) is the only list we will accept as they cannot be filed online.
Your MARORS list of employees must be:
- easy to read
- in Arial font size 11 or more
- in alphabetical order by employee’s surname
- include each employee’s:
- name
- gender
- National Insurance number or date of birth
Send the list of the MARORS employee details, with a covering letter to HMRC:
HM Revenue and Customs
BX9 1WE
You do not need to include a street name, city name or PO box when writing to this address. Couriers should use a different address.
Electronic filing of expenses and benefits returns
25.7
From 6 April 2023, employers must file expenses and benefit returns (forms P11D, P11D(b)) online unless you are digitally exempt. If you think you may be digitally exempt, contact the employers’ helpline on 0300 200 3200 to see if you qualify for an exemption.
Filing expenses and benefit returns electronically offers benefits to employers, including:
- speedier information flow with less clerical handling
- accuracy of data reporting with reduced errors
The electronic filing options are:
- HMRC’s PAYE online service
- commercial payroll software
PAYE online filing for employers
25.8
The PAYE online filing service is available to any PAYE employer. The service allows secure submission of the following expenses and benefits return forms through HMRC’s Government Gateway using the internet:
- P11D
- Class 1A National Insurance contributions form P11D(b)
You can submit your returns either by:
- using the free HMRC software provided
- using commercial software provided by a third party
In either case, you must first enrol with HMRC to use the PAYE online filing service before you can send your returns using this option.
You must submit your P11D and P11D(b) forms at the same time.
Read more information on the PAYE Online Filing for Employers service.
HMRC’s online end-of-year expenses and benefits service
25.9
The online service for small to medium sized employers (up to 150 employees) to create and send P11D and P11D(b) forms electronically was withdrawn in April 2021.
How to find out more
For more information, contact the Online Services Helpdesk.
Effects of VAT
25.10
The amount to be included on forms P11D should include the full amount of VAT paid, whether or not the VAT may be recovered in whole or in part by the employer from HMRC.
Entertaining expenses
25.11
Chapter 20 explains that entertaining expenses will often be disallowed when calculating the tax liability of the business. However, the full amount of all sums paid out in relation to entertainment should still be shown on forms P11D.
Use of assets
25.12
When you enter an amount in the section ‘use of assets’, you must show the gross figure. There’s no deduction for expenses.
Subscriptions
25.13
In addition to subscriptions to professional and learned societies related to the employment (read paragraph 7.5 of chapter 7) entries at the section for ‘other items’ on form P11D should include initial and annual subscriptions to:
- clubs catering for leisure or sporting activities
- other societies, where the expense of the subscription is borne by, or on behalf of, the employee
Initial and annual subscriptions relating to credit cards provided for an employee by reason of their employment are exempt from a tax charge and should not be included on form P11D.
Penalties
25.14
An employer who fails to make a return on form P11D within the appropriate time limit may incur a penalty not exceeding £300, with a further penalty not exceeding £60 a day if the failure continues.
An employer registered to payroll benefits who does not send them through RTI will be subject to penalties for failure to report on or before the payment was made.
25.15
There’s also a penalty for making an incorrect return on form P11D. The penalty is a maximum of £3,000 per form.
An employer will be subject to a penalty based on details contained in Schedule 24 Finance Act 2007 if they:
- are registered to payroll benefits
- send an incorrect RTI return
25.16
There are also penalties for:
- late filing of form P11D(b), ‘Return of Class 1A National Insurance contributions due’
- making incorrect returns on form P11D(b), ‘Return of Class 1A National Insurance contributions due’
For more information on P11D(b) penalties read Class 1A National Insurance contributions on benefits in kind (CWG5).
More information
25.17
For help completing forms P11D or the P11D(b), contact Employers: general enquiries.
Last updated 8 March 2024 + show all updates
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Section 25.6 has been updated to clarify that Mileage Allowance Relief Optional Reporting Scheme (MARORS) details must be submitted by post. Section 25.7 has been updated to clarify that employers must file expenses and benefit returns online unless they are digitally exempt.
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Section 25.6 of the guidance has been updated to show HMRC stopped accepting lists of P11D information on 6 April 2023 for everything other than Mileage Allowance Relief Optional Reporting Scheme details. Section 25.7 has been updated to show the electronic filing options for filing P11D information are using HMRC’s PAYE online service or commercial payroll software. Section 25.9 has been updated to show the online service for small to medium sized employers to create and send P11D and P11D(b) forms electronically was withdrawn in April 2021.
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First published.