04 March 2026
HMRC has introduced two minor policy and administrative changes affecting how employers report benefits in kind (BiKs). These were published on 3 March 2026.
1. Allowing paper P11D / P11D(b) returns for employers who cease trading
Effective from 6 April 2026, employers who cease trading mid tax year (or insolvency practitioners acting for them) will be exempt from the usual requirement to file P11D and P11D(b) forms electronically.
- They will be permitted to submit paper returns mid-year, rather than waiting until the end of the tax year when online filing reopens
- This formalises an existing HMRC concession into law.
The purpose is to make it easier for ceased businesses to finalise their tax affairs promptly by allowing earlier filing.
2. Ending voluntary registration for real-time payrolling of benefits
From 6 April 2026, employers will no longer be legally able to voluntarily register to payroll benefits in kind in real time for the 2027–28 tax year onward.
- This closes the voluntary registration route ahead of the government’s plan to make real-time BiK reporting mandatory from April 2027
- Without this change, employers could still legally opt into voluntary payrolling, which would undermine the move to a fully mandatory system.
Overall purpose of the changes
These measures are designed to support smoother administration for employers ceasing to trade and to prepare the system for the 2027 mandatory payrolling reform, ensuring consistency and removing legacy voluntary processes.
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