What to look out for to help clients avoid submissions being rejected
Agents and/or employers who are dealing with the 2024/25 P11D season, or correcting P11Ds for earlier tax years, should be aware that paper amendments are no longer allowed. It is now vital to get these forms correct the first time.
The deadline for submitting forms P11D and P11D(b) for 2024/25 to HMRC is 6 July 2025. All employers must submit the following forms online to HMRC:
- 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.
Class 1A NIC must be paid by 22 July if paying electronically, or by 19 July if paying by cheque.
Historically HMRC’s PAYE Manual at PAYE 57002, ‘P11D Quality Standard’ provided HMRC’s requirements that every P11D must meet and the Quality Standard 1 (QS1) checks that were carried out based on these standards; however, this guidance is no longer available. It required that the P11D should include:
- the employer’s reference
- the employee’s name and NI number
- if the employee’s NI number is not known, it must provide their date of birth and gender
- where a car that has been provided to an employee, it must include its list price
- where box 10 in section F (total cash equivalent of car fuel provided) is completed, box 9 (total cash equivalent of cars provided) must also be completed
- where a beneficial loan to an employee has been provided and it is reported in section H, box 15 (cash equivalent of loans) must also be completed (in cases where an employee has more than two loans, the employer is allowed to attach a copy of the P11D WS4 working sheet and write ‘see attached’ in box 15 in section H and so the form should not be rejected for this reason).
HMRC may impose penalties for both late and incorrect filing. If a P11D(b) is filed late, a charge of £100 per month (or part of a month) applies for every 50 employees, or part thereof, until the return is submitted. For incorrect P11D forms, a penalty of up to £3,000 may be levied per form. If the business has incurred a penalty for late or incorrect filing, they may appeal on the reasonable excuse grounds, if applicable.
