Mandatory payrolling was due to come into effect from 6 April 2027. However, it has now been announced that the introduction will be phased in, with mandatory payrolling only applying to benefits in kind in phase one from 6 April 2027, with all remaining benefits in kind (with the exception of taxable cheap loans and living accommodation benefits) being brought within mandatory payrolling from 6 April 2028. From the same date, employers will be able to opt to payroll taxable cheap loans and living accommodation benefits if they register to do so before the start of the 2027/28 tax year. These benefits are to be brought within mandatory payrolling from a later date.
Nature of payrolling
Under payrolling, the taxable amount of a benefit in kind is treated like extra pay which is paid to the employee with the same frequency as their cash pay. For example, if a monthly paid employee receives medical insurance with a cash equivalent value of £600, the employee’s gross pay for PAYE purposes each month would include £50 in respect of the medical insurance benefit. Tax is worked out on the total gross pay in the pay period and deducted from the employee’s cash pay.
As most benefits in kind are within Class 1A National Insurance, rather than Class 1, the payrolled benefit is not included in gross pay for National Insurance purposes.
Phase one
Mandatory payrolling is phased in from 6 April 2027. From that date it will apply to:
- company cars;
- car fuel;
- company vans;
- van fuel; and
- medical benefits.
Employers must payroll these benefits from that date. For 2027/28, payrolling is optional for other benefits in kind including taxable cheap loans and living accommodation benefits. There is no need to register benefits for which payrolling is mandatory. However, where a benefit is to be payrolled voluntarily in 2027/28, it must be registered for payrolling before the start of that tax year.
Phase two
From 6 April 2028, mandatory payrolling is extended to all other benefits in kind with the exception of taxable cheap loans and living accommodation benefits from 6 April 2028 (however, employers will be able to opt to payroll these voluntarily as long as they are registered for payrolling before the start of the new tax year).
Class 1A National Insurance
For 2026/27 and earlier tax years, Class 1A National Insurance is included in the Class 1A National Insurance calculation on the P11D(b). The liability is paid in a single lump sum after the end of the tax year. Payment must be made by 22 July following the end of the tax year where payment is made electronically or by 19 July if payment is made by cheque.
However, under mandatory payrolling, the associated Class 1A National Insurance will be reported through Real Time Information on the Full Payment Submission each month and paid over to HMRC with the PAYE and Class 1 National Insurance for the month. This will bring forward the payment date and may have cashflow implications for employers.
During the move to in-year collection, employers may pay some Class 1A National Insurance monthly and some after the end of the tax year.
Impact on P11D and P11D(b)
Where a benefit is payrolled, it is not reported on the P11D. The introduction of mandatory payrolling will render the P11D obsolescent. For 2028/29 and later tax years, it will only be used to report taxable cheap loans and living accommodation where the employer has not opted to payroll these.
As noted above, under mandatory payrolling, Class 1A National Insurance contributions are reported and paid in-year. This will mean that benefits in kind within mandatory payrolling will not be included in the Class 1A calculation on the P11D(b). For 2028/29 and later tax years, the P11D(b) will only be used to calculate the Class 1A National Insurance liability on taxable cheap loans and living accommodation benefits where these are not payrolled.
Call to Action
To find out more about how mandatory payrolling will affect your business, or to discuss how to prepare for the April 2027 changes, please get in touch with our team today.
