What is mandatory payrolling of benefits - and what happens to the P11D?
HMRC has confirmed that P11D and P11D(b) forms remain mandatory for tax years up to and including 2026/27, with a final filing deadline of 6 July 2027. Once mandatory payrolling of benefits kicks in from April 2027, P11D submissions will only be required for employment-related loans and accommodation. For everything else, the P11D is gone.
How mandatory payrolling of benefits - and the end of P11D - affects your practice
This isn’t just an admin tweak. The shift from P11D reporting to mandatory payrolling of benefits is a fundamental change in how employer compliance works, and it touches payroll software, internal workflows, client communication, and cash flow planning all at once.
For practices managing payroll on behalf of clients, monthly submissions will now need to include the taxable value of each employee’s benefits divided across pay periods. Mid-year P11D-triggering changes – a new company car, an update to a healthcare plan – must now be reflected in real time rather than corrected at year end. That demands tighter, more consistent data-sharing between your clients’ HR functions and your payroll team.
HMRC has also confirmed that Class 1A NIC payments will shift from the familiar single annual lump sum in July – currently tied to the P11D cycle – to monthly payments via payroll. For clients who budget around that July payment, this is a material cash flow change worth raising in your next client conversation.
The P11D to mandatory payrolling of benefits transition - potential double tax risk for your clients
How to prepare your practice for mandatory payrolling of benefits before P11D is phased out
HMRC is encouraging employers to voluntarily adopt payrolling of benefits during 2026/27 as a live testing window, while P11D submissions are still available as a fallback safety net. Practices that proactively guide clients through this voluntary migration will be significantly better positioned when mandatory payrolling of benefits becomes law in April 2027. Think of it as a dress rehearsal with a P11D backup – the ideal conditions to iron out data gaps, software issues, and client communication before the stakes are higher.
There are three practical steps worth prioritising now. First, audit which of your clients currently have P11D obligations and map out their benefits landscape. Second, confirm your payroll software will be ready for HMRC’s updated technical specifications, due in the second half of 2026. Third, open the conversation with clients early – mandatory payrolling of benefits will affect their payroll team, their HR function, and their employees. The practices that brief their clients now will be the ones those clients trust most when 2027 arrives.
Key P11D and mandatory payrolling of benefits deadlines every UK practice must act on
These are the dates your practice and your clients need locked in now.
6 April 2027: Mandatory payrolling of benefits becomes law. P11D reporting ends for most benefits from this point forward.
6 July 2027: Final P11D and P11D(b) submission deadline for the 2026/27 tax year. This is the last time the majority of employers will file a P11D.
2028/29 onwards: Full HMRC penalty and interest regime applies. Mandatory payrolling of benefits is treated as a standard payroll function with no further leniency.
The direction of travel is clear. P11D is on its way out and mandatory payrolling of benefits is coming in. The only question is how prepared your practice will be when it does.
Take P11D and payroll compliance off your plate
The move from P11D to mandatory payrolling of benefits is one of the most significant compliance shifts UK practices have faced in years – and the firms that act early will have a clear competitive edge. Befree’s outsourced payroll services are built specifically for UK accounting firms and business owners navigating exactly this kind of HMRC transition. We stay on top of P11D obligations, mandatory payrolling of benefits requirements, and every deadline in between, so your team doesn’t have to. Free up your capacity, protect your clients, and focus on growing your practice.