Payrolling benefits in kind (BIKs)

What can you do to prepare?

A reminder of what’s changing

Starting in April 2027, employers will be required to process all benefit in kind values through the payroll in real time, except for accommodation and loan benefits which can still be reported via Form P11D or included in payroll on a voluntary basis.

This means that the P11D process will no longer apply to most benefits in kind for the tax year 2027/28 onwards. For any employer that currently provides benefits in kind, this is a significant change, fundamentally altering how you report, pay for, track and manage employee benefits. Without adequate preparation, this leaves lots of room for error.

What can you do to prepare

These changes represent a significant shift for employers and employees. Do not underestimate how complex they are, how many parts of your organisation they might affect, and just how long they will take to embed.

You will need to report even more data than is currently required (even if you are already payrolling benefits), to provide a full breakdown of the benefits being reported through the payroll, and to reflect the Class 1A NIC being payrolled.

In order to get prepared, you should:

1. Make sure you have all the correct benefit information from within your business and from benefit providers.

2. Have systems in place for calculating benefit in kind values which are to be processed in the payroll for each of your pay periods, including adjustments for starters, leavers and benefit cost changes.

3. Communicate the impact of the changes to your employees. The tax adjustment for benefits has always been delayed to the following tax year, after the submission of form P11d. From April 2027 employees will see changes to their tax codes and payslips, and they will be paying tax on benefits in real time.

  • In addition, if errors are made, the correction must be processed over the remaining months of the tax year, which could further impact on their net pay.
  • Furthermore, if your employees have underpayments of benefits from an earlier year, they will be taxed twice; in real time for the 2027/28 benefit and for the unpaid tax on earlier year benefit adjustments.

4. Ensure that your 2027/28 forecasts include the financial impact of paying Class 1A NIC for both 2026/27 and 2027/28 in the same year.

5. Establish an end of year process if you do not know the value of taxable benefits in kind during the year. We are expecting HMRC to introduce a ‘month 13’ to allow employers to correct some benefits which they previously had to estimate.

6. We would advise your employees to set up their Personal Tax Account (PTA) with HMRC, if not done already. They will be able to access all their tax information, including the benefits in their PTA, and liaise with HMRC before and after April 2027.

In terms of penalties. HMRC have said that there will be a light touch approach in 2027/28, unless the errors are deliberate. From 2028/29 onwards, the penalty regime will be in force.

The HMRC guidance is still in draft format. They have said that they will provide the final specifications to software developers sometime between June and December 2026. This does not leave much time for software to be updated, tested and rolled out.

Their current timetable is as follows.

Action Date
Responses to the consultation of draft legislation and guidance to be considered February 2026 to April 2026
Updated legislation and guidance to be published July 2026
Primary and secondary legislation to be laid before parliament In line with 2026 Finance Bill timings
RTI technical specifications to be published Second half of 2026
Voluntary registering for the payrolling of loans and accommodation in April 2027 to 2028 to go live November 2026
Voluntary registering for the payrolling of loans and accommodation in April 2027 to 2028 to close April 2027
Mandating Payrolling of BiKs to go live April 2027

 

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We always recommend that you seek advice from a suitably qualified adviser before taking any action. The information in this article only serves as a guide and no responsibility for loss occasioned by any person acting or refraining from action as a result of this material can be accepted by the authors or the firm.

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