ICB draws your attention to legislation that make administration changes where:
1. Employers report taxable expenses / benefits-in-kind; and / or
2. Register to voluntary payroll these
On 03 March 2026, HMRC issued a Policy Paper explaining these changes.
P11D and P11D(b) Filing
Employers are required to submit these electronically.
However, from 06 April 2026, in the circumstances an employer ceases to trade during the tax year, HMRC will allow the employer (or insolvency practitioners acting on their behalf) to file these electronically or on paper.
Voluntary Payrolling
Currently, if an employer wants to voluntarily payroll taxable expenses and / or benefits-in-kind, they are required to register.
However, for tax years 2027/28 and after, the facility will be removed (ahead of mandation in April 2027). As the Policy Paper explains, this is a necessary step otherwise legislation will say the employer cannot operate payrolling if they have not registered.
The Legislation
For Bookkeepers
With regards the move back to allowing paper P11Ds and P11D(b)s for companies that have ceased trading, this is sensible and ICB supports this. This is not a return to paper submission and only applies in the circumstances a company has ceased trading.
With regards the abolition of the payrolling registration service, HMRC’s previous advice has been that employers will still be able to voluntarily payroll employer-provided accommodation and beneficial loans. It seems, therefore, that if the facility is being removed, there will be no requirement to advise HMRC via their registration service. Which does bring into question how HMRC will know an employer has chosen to put this taxable value through the payroll and make the necessary tax code adjustments.
