For companies that have ceased trading, employers now have the option of submitting paper P11Ds and HMRC has updated its guidance.
ICB has written about the legislation that makes administrative changes where:
1. Employers report taxable expenses / benefits-in-kind; and / or
2. Register to voluntary payroll these
P11D and P11D)b) Filing
Employers are required to submit these electronically. However, from 06 April 2026, only in the circumstances an employer ceases to trade during the tax year, HMRC will accept paper copies.
HMRC’s updated guidance clarifies that:
- Online P11D or P11D(b) forms can only be filed after the end of the tax year; but
- If the employer has ceased trading and wants to do this mid-year, either they or the insolvency practitioner acting on their behalf ‘can submit paper forms to HMRC instead’
Voluntary Payrolling
Note that the voluntary payroll registration tool is now closed.
The service was only valid to register to payroll benefits and expenses for tax years 2026/27 and before (and the registration deadline for the current tax year was 10pm on 05 April 2026).
For Bookkeepers
The facility for in-year paper filing is useful and ICB supports this. See our previous article that points to the legislation and HMRC’s Policy Paper.
