Missing a P11D deadline can feel like a disaster, but don’t worry.
If you’ve missed your P11D submission date, or you’re worried you might, you need to know what steps to take and how to handle the situation properly.
One question we get at Double Point around P11D season is “What happens if I’m late?” And it’s a fair question.
P11D forms – those detailed reports of employee benefits and expenses – can be complex and time-consuming to prepare. Even experienced business owners sometimes struggle with deadlines.
Let’s walk through exactly what P11D forms are, what happens if you miss the deadline, and most importantly, what you need to do about it.
We’ll break down the penalties, explain how to minimise their impact, and show you how to get back on track quickly.
What is a P11D?
A P11D is an annual tax form that employers must submit to HMRC. It reports any benefits, perks, expenses and non-cash advantages provided to employees during the tax year that aren’t included in their regular salary.
Along with the P11D forms for individual employees, employers also need to submit a P11D(b) form. This companion form summarises the total value of all benefits provided and calculates the Class 1A National Insurance contributions the employer needs to pay on these benefits.
It acts as HMRC’s way of tracking everything you give employees beyond their wages.
While regular payroll handles salary, the P11D captures all those extra perks that make up the total employment package.
What Needs to Be Reported?
Most benefits and expenses need to be reported on a P11D. Common examples include:
- Company cars and fuel benefits
- Private medical insurance
- Living accommodation
- Interest-free loans over £10,000
- Assets provided for personal use
- Entertainment expenses
- Non-business travel expenses
Even smaller benefits and perks might need reporting. Many employers get caught out thinking certain benefits are too minor to mention, but HMRC wants to know about all taxable benefits, regardless of their value.
Understanding P11D vs Payrolling Benefits
Some employers choose to put benefits through their payroll instead of reporting them on a P11D. This is called ‘payrolling benefits‘ and needs to be registered with HMRC before the start of the tax year.
If you payroll all your benefits, you might not need to submit any P11Ds, but you’ll still need to submit a P11D(b) to pay your Class 1A National Insurance.
Who Needs to Submit P11Ds?
You need to submit P11Ds if:
- You’re an employer providing taxable benefits to employees or directors
- The benefits haven’t been put through your payroll
- You have employees earning at or above £8,500 per year (including the value of benefits)
Even if you don’t provide any benefits, you might need to submit a ‘nil return‘ to confirm this to HMRC. Many employers miss this requirement, thinking no action is needed if no benefits were provided.
P11D Deadlines: What You Need to Know
There are two critical deadlines that every employer needs to know about. Missing either of these can result in penalties and complications with HMRC.
The main deadline is 6 July each year. By this date, you must:
- Submit all your P11D forms to HMRC
- Submit your P11D(b) form summarising the total benefits
- Give copies of their P11D forms to all relevant employees
The second deadline is 22 July each year. This is when you need to pay any Class 1A National Insurance contributions due on the benefits you’ve reported. If you’re paying by cheque, this deadline is actually earlier – 19 July.
Nil Returns
As noted, if HMRC has requested P11D returns from you but you haven’t provided any benefits or expenses to report, you must tell HMRC that no P11D forms are due.
This is called a ‘nil return’. However, if HMRC hasn’t specifically requested P11D returns and you have no benefits to report, you don’t need to submit anything.
PAYE Settlement Agreements
If you have a PAYE Settlement Agreement (PSA) in place, you’ll have different deadlines to consider.
A PSA is a voluntary arrangement with HMRC that allows employers to make a single annual payment to cover the tax and National Insurance on certain expenses and benefits provided to employees.
You might use a PSA if you provide employees with:
- Minor benefits – e.g., small gifts or staff entertainment (that don’t qualify as trivial benefits).
- Irregular benefits – e.g., one-off incentives or rewards that aren’t part of the employee’s regular pay.
- Impractical-to-allocate benefits – e.g., shared staff benefits where it’s difficult to divide costs among individuals.
Any tax and Class 1B National Insurance covered by your PSA needs to be paid by 22 October 2025 (or 19 October if paying by cheque).
Need help with payroll? Contact Double Point today.
What Should I Do If I Miss the P11D Deadline?
If you’ve missed the P11D deadline, don’t panic – but you do need to act quickly. The longer you wait, the more penalties and interest will build up.
Immediate Steps to Take
First, complete and submit your P11D forms as soon as possible, even if they’re not perfect.
You can always amend them later, but getting them submitted stops additional penalties from accruing.
Next, contact HMRC’s employer helpline immediately. Be prepared with:
- Your employer reference
- A clear explanation of why you missed the deadline
- Details of what you’re doing to rectify the situation
- When you discovered the missed deadline
Understanding the Penalties
HMRC applies penalties for late P11D submissions and unpaid Class 1A National Insurance.
For late P11D submissions, there is a £100 fine per 50 employees (or part thereof) for each month the forms are overdue. If the delay exceeds 3 months, additional penalties based on the tax owed may apply.
For late Class 1A National Insurance payments, interest charges will apply to overdue amounts. If the payment is more than 30 days late, a 5% penalty is added.
Example
If you have 75 employees and file your P11Ds one month late, the penalty is £200. Since 75 employees count as two groups of 50 (50 + 25, rounding up), the fine is £100 per group, totalling £200 for that month.
Missing these deadlines can result in further penalties, so ensuring timely submission and payment is essential.
Can Penalties Be Appealed?
HMRC may consider appeals against penalties if you have a ‘reasonable excuse’. This might include:
- Serious illness that prevented submission
- Computer or software failure just before the deadline
- Fire, flood or theft that prevented completion
- Unexpected postal delays
However, HMRC won’t accept excuses like:
- Relying on someone else who failed to submit
- Not understanding the rules
- Making a mistake
- Not having enough money to pay
Remember, missing a deadline once doesn’t have to lead to the same problem next year. Use this as an opportunity to improve your processes and ensure future compliance.
How to Appeal Against Penalties
If you receive a penalty notice from HMRC for late P11D submission, you can appeal if you have a genuine reason for missing the deadline. The key is to act quickly – you normally have 30 days from the date of the penalty notice to appeal.
To make an appeal:
- Write to HMRC explaining your reasonable excuse
- Provide evidence supporting your case
- Demonstrate that you corrected the failure as soon as possible
- Submit your appeal within the 30-day window
Remember that HMRC considers each case individually. They’ll look at what stopped you from meeting the deadline and what steps you took to try to comply.
A reasonable excuse needs to be something unexpected or outside your control that made it impossible to meet the deadline.
Preventing Future Late Submissions
Prevention is always better than dealing with missed deadlines. Here’s a robust system to keep you on track:
Year-Round Record Keeping
Set up a system to track benefits and expenses as they happen. Don’t wait until June to start gathering information. Keep accurate records of:
- Company car details and changes
- Health insurance payments
- Employee loans
- Entertainment expenses
- Travel and subsistence costs
Create a P11D Timeline
Work backwards from the July deadline:
- March: Start gathering all information
- April: Begin initial calculations
- May: Review draft P11Ds
- June: Final checks and sign-off
- Early July: Submit with time to spare
Use Available Tools
Consider using:
- HMRC-approved software for benefits tracking
- Calendar reminders for key dates
- Spreadsheet templates for ongoing record keeping
- Professional services for complex calculations
Getting Help with Your P11Ds
At Double Point, we understand how challenging P11D compliance can be. Whether you’ve missed a deadline or want to ensure you never do, our team of chartered accountants can help you:
- Set up efficient benefit tracking systems
- Handle P11D calculations and submissions
- Deal with HMRC correspondence
- Appeal against penalties
- Plan for future compliance
Don’t let P11D worries keep you up at night. Book a consultation with Double Point today, and we’ll help you get your benefits and expenses reporting sorted for good.
