09 April 2026
HM Revenue and Customs (HMRC) has updated its guidance on completing P11d and P11d(b) forms for employers. It has now been confirmed that any business that stops trading during the current tax year can submit paper forms directly to HMRC. This reflects a more practical approach for employers who are unable to access payroll systems or submit forms electronically once trading has ceased.
Under normal rules, all employers must submit the P11d and P11d(b) forms electronically after the tax year ends to report employees’ taxable benefits and the employers Class 1A National Insurance contributions. Where benefits are payrolled, a P11d(b) form is still required to declare Class 1A NICs.
HMRC’s updated guidance now states:
“If you have stopped trading and you (or an insolvency practitioner acting on your behalf) want to submit a P11D or P11D(b) form, you can submit paper forms to HMRC instead.”
This amendment reduces the risk of late-filing penalties where an employer or their agent can no longer access payroll systems or submit returns electronically. It also provides welcome clarity for a business facing a complex and time-pressured cessation process.
Crucially, this change means employers can finalise their PAYE obligations earlier, without having to wait for the electronic window to open after 5 April. This allows the business’s tax position to be brought to a close more efficiently.
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