P11D Filing Deadline 2025 | Key Dates and What Employers Must Know

Meeting tax compliance deadlines is a critical responsibility for employers across the UK. One of the key reporting obligations is the filing of P11D forms, which notify HMRC of any benefits and expenses provided to employees during a tax year.

With the P11D filing deadline for 2025 approaching, it’s essential to understand the key dates, penalties for late submission, and the upcoming changes that will affect how benefits are reported from 2026 onwards.

This article outlines everything UK employers must know about the P11D filing process, the P11D(b) return, Employment Related Securities (ERS) requirements, and what happens when errors or delays occur.

What Is The P11D Filing Deadline For 2025 And Who Must File It?

The P11D filing deadline for the 2024/25 tax year is 6 July 2025. This date is fixed annually and applies to all UK employers who provide non-payrolled benefits to their employees.

The P11D form is used to report benefits in kind (BIKs), which are perks or benefits provided to employees that are not included in their wages but still have taxable value.

Employers must submit a separate P11D form for each employee who has received taxable benefits during the tax year. These benefits might include:

• Company cars or fuel
• Private medical insurance
• Low-interest or interest-free loans
• Gifts or vouchers
• Accommodation or relocation expenses

The obligation to file a P11D applies regardless of business size, and even small companies with a single director who receives benefits must comply.

In addition, employers must assess whether benefits are to be payrolled or reported separately.

For the tax years 2023/24, 2024/25, and 2025/26, P11D reporting remains a requirement for any non-payrolled benefits.

From the 2026/27 tax year, HMRC will move to a system where all benefits must be payrolled, which will eliminate the need for separate P11D submissions in future years.

What Forms Need To Be Submitted Alongside The P11D?

Along with the P11D form for each employee, employers are also responsible for submitting two other documents if applicable: the P11D(b) and the Employment Related Securities (ERS) return.

P11D(b)

The P11D(b) is used to declare the total amount of Class 1A National Insurance Contributions (NICs) owed by the employer on the benefits reported in the P11Ds.

This summary form must be submitted even if all benefits have been payrolled, simply to declare that no further NICs are due.

ERS Return

The ERS return is required when employees have received employment-related securities, such as shares or options, during the tax year.

The return must be submitted through HMRC’s online service and cannot be filed on paper.

Submission Options

Employers have several ways to submit the P11D and P11D(b) forms:

• Using HMRC’s PAYE Online service
• Through commercial payroll software that supports these forms
• By paper (only for P11D and P11D(b), not ERS)

Employers must register with HMRC to use the ERS online service. Failure to do so can result in delays and penalties, especially if the deadline is missed.

What Are The Penalties For Missing The P11D And P11D(B) Filing Deadline?

Missing the 6 July deadline triggers automatic penalties from HMRC. These penalties apply to both the P11D and P11D(b) forms. HMRC calculates the penalty based on the number of employees for whom forms are due.

The penalty is £100 for every 50 employees (or part thereof) for each month or part of a month that the return is late. For example, if a company employs 105 staff, they would face a penalty of £300 per month for a late submission.

In addition to this automatic monthly penalty, employers may also face further charges if they fail to pay the Class 1A NICs by the deadline of 22 July (for postal payments) or 22 August (for electronic payments).

Escalating Penalty Schedule

• 1 Month Late: £100 per 50 employees (or part) per month
• After 30 Days: 5% penalty on unpaid NICs
• After 6 Months: Additional 5% penalty
• After 12 Months: Final 5% penalty (totaling 15%)

Interest is also charged on any unpaid tax or NICs from the date it was due until it is fully paid. These charges accumulate and can significantly increase the employer’s total liability.

In some instances, HMRC may issue a penalty of £300 for each late P11D form. However, this requires authorisation by the First-tier Tax Tribunal (FTT).

Once approved, daily penalties of £60 may also be charged until the employer becomes compliant.

How Are ERS Late Filing Penalties Structured By HMRC?

ERS returns are also subject to a strict filing deadline of 6 July following the end of the tax year. Penalties for late submission of these returns are different from those applied to P11Ds and P11D(b).

Unless the employer has a reasonable excuse, the following penalties apply:

• Immediately After Deadline: £100 penalty
• Three Months Late: Additional £300
• Six Months Late: Further £300
• Nine Months or More Late: £10 per day until submitted

In addition to financial penalties, late submission of ERS returns for tax-advantaged schemes such as Share Incentive Plans (SIPs), Save As You Earn (SAYE), or Enterprise Management Incentives (EMIs) can lead to the loss of tax reliefs.

This not only impacts the employer but also affects the tax positions of the participating employees.

Therefore, maintaining a tight schedule and regularly checking HMRC’s ERS portal is recommended to ensure all share plan activity is correctly reported on time.

What Happens If There Is A Mistake In Your P11D Or P11D(B)?

Even if a P11D or P11D(b) is filed on time, submitting incorrect information can still result in penalties. HMRC assesses these errors based on the amount of tax lost and the behaviour of the employer during the process.

The penalty calculation is influenced by two key factors:

1. Whether the employer disclosed the error voluntarily or was prompted by HMRC
2. The nature of the behaviour—whether it was careless, deliberate, or concealed

Penalty Bands Based on Behaviour and Disclosure

If the employer notifies HMRC of the mistake before any investigation begins, they are more likely to receive a lower penalty.

Conversely, if HMRC discovers the issue and prompts the employer to correct it, the penalties are generally more severe.

Mistakes in ERS returns that are deemed careless or deliberate may result in penalties up to £5,000.

Given the complexity of benefits and share schemes, employers are advised to regularly audit their records and seek professional advice when needed.

How Can Employers Avoid Common P11D Submission Mistakes?

Preventing errors and late submissions requires an organised approach to recordkeeping, planning, and communication. Employers should establish internal systems that support timely compliance throughout the year.

Recommended Practices

• Maintain Accurate Records: Keep detailed logs of all benefits provided to employees.
• Understand Reporting Methods: Know which benefits must be payrolled and which require a P11D.
• Train Payroll and HR Teams: Ensure staff understand current HMRC guidelines.
• Use Approved Software: HMRC-compatible tools help reduce data entry mistakes.
• Set Internal Deadlines: Create checkpoints before the 6 July filing deadline to catch any discrepancies.

Employers may also register to payroll benefits before the start of a tax year. Doing so reduces the need for P11D forms and spreads the tax burden for employees across the year.

However, this registration must be completed before 6 April of the relevant tax year.

What Are The Key Dates Employers Should Remember For The 2024/25 Tax Year?

Staying compliant with HMRC deadlines depends on being aware of the key dates that apply to the relevant tax year. For 2024/25, these are as follows:

Employers are advised to build these dates into their finance and HR calendars and communicate them clearly within their teams.

This ensures there is adequate time to gather information, process calculations, and address any anomalies before submission deadlines.

Conclusion

With the P11D filing deadline for 2025 set for 6 July, UK employers must act promptly to meet their compliance obligations.

From reporting benefits to calculating Class 1A NIC and submitting ERS returns, timely and accurate filing avoids penalties, interest charges, and reputational damage.

By understanding the rules and preparing well in advance, employers can remain compliant while adapting to upcoming changes in benefit reporting.

Staying ahead of deadlines today ensures fewer surprises tomorrow, especially as HMRC transitions to a fully payrolled system in the near future.

FAQs

What types of employee benefits require a P11D?

Employers must report benefits such as company cars, private medical insurance, interest-free loans, and gym memberships provided to employees or directors during the tax year.

Can a P11D be corrected after submission?

Yes. If an error is discovered, employers should resubmit the corrected form as soon as possible. Voluntary disclosure often results in lower penalties.

Is it mandatory to submit P11D forms online?

While paper submissions are still allowed for P11D and P11D(b), HMRC encourages digital filing. ERS returns must be submitted online.

What happens if an employer has no benefits to report?

If no benefits were provided, there’s no need to submit individual P11D forms. However, a P11D(b) ‘nil return’ may still be required to confirm this.

Are there exceptions to ERS filing requirements?

If no reportable share transactions occurred in the year, an employer can opt out of submitting an ERS return. However, a declaration must still be made via HMRC’s portal.

How long should employers keep records for P11D?

Employers should retain P11D-related records for at least 3 years, including calculations, receipts, and any correspondence with HMRC.

What if you’re late but have a reasonable excuse?

HMRC may waive penalties for late submissions if there is a valid reason, such as serious illness, natural disaster, or system outages. Employers must contact HMRC promptly and provide supporting evidence.