The profession has spent most of 2026 talking about quarterly updates. While that conversation continues, a second real time reporting change is quietly moving towards your payroll bureau, and it will land on almost every employer client you look after. From April 6th 2027, reporting benefits in kind through payroll stops being a choice and becomes the default. For most benefits, the P11D as we know it is finished.
HMRC published interim guidance and draft legislation in June 2026, and the practical detail is now clear enough to act on. The firms that use the autumn of 2026 to plan will move through this comfortably. The firms that wait until the 2026/27 P11D season is over will be doing process design in the middle of a live payroll year.
Today, most employers report taxable benefits after the tax year ends on forms P11D and P11D(b), employees pay the tax through an adjusted code in a later year, and Class 1A National Insurance is settled the following July. From April 2027, Income Tax and Class 1A National Insurance on affected benefits must be reported and paid in real time, through the Full Payment Submission, in the period the benefit is provided.
The change is being phased:
There is no registration step for the mandatory benefits. Payrolling simply becomes the default, and HMRC has confirmed it will strip those benefits out of employees' tax codes before April 6th 2027 so nothing is taxed twice. Underpayments carried forward from earlier years will stay in codes, which is a point worth flagging to clients before the first payslip queries arrive.
If a client provides loans or accommodation, they face a choice: run two parallel reporting processes, one through payroll and one on a P11D, or voluntarily payroll everything and keep a single process. Most employers with any volume of benefits will be better off with one process.
The service to register for voluntary payrolling of non-mandatory benefits from April 2027 goes live in November 2026, and the registration deadline is April 5th 2027. That is a decision your firm should be taking to affected clients in the next few weeks, not next spring. Note too that the existing voluntary payrolling process closed to new registrations after 5 April 2026, so clients who missed that window cannot dry run through 2026/27 in the old way.
This is the point that will earn you the most credit with clients. In 2027/28 many employers will pay Class 1A National Insurance twice in the same financial year. In July 2027 they must still settle Class 1A on benefits provided in 2026/27 under the old P11D(b) regime, while simultaneously paying Class 1A in real time on benefits provided from April 2027 onwards.
It is a one off overlap rather than a permanent extra cost, but for a client with a large company car fleet it is a serious cash flow event. Modelling that number now, and getting it into your clients' 2027/28 budgets and cash forecasts, is a straightforward piece of advisory work with an obvious value attached to it.
Payroll software will be ready. Your clients' internal processes may not be. Under the P11D regime, benefits data could arrive months late and still be reported accurately. Under real time reporting, information that arrives late is a correction, and corrections at scale are where cost and risk sit.
The questions to work through with each employer client are practical ones:
HMRC has offered some breathing room here. Employers who make an inaccuracy related to mandatory payrolling in their 2027/28 Real Time Information returns will not face inaccuracy penalties unless there is evidence of deliberate non compliance. Treat that as time to get processes right, not as permission to arrive unprepared.
There is an easy narrative in which this is just more admin arriving at the worst possible time. There is a better one. The P11D has always been an unloved form that told employees about tax on benefits long after they had enjoyed them. Real time reporting is more transparent, it removes a year end scramble, and it gives you a legitimate reason to sit down with every employer client and review what benefits they offer, what those benefits cost after tax and National Insurance, and whether the package still does what they want it to do.
Those reviews are chargeable, valued and impossible for a client to do alone. April 2027 is close enough to be urgent and far enough away to be planned for. The work you do in the next three months decides which of those it feels like.
Payrolling benefits in kind is easy to file under "more admin arriving at the worst possible time." For firms that approach it that way, it will feel exactly like that. But the firms that use the next three months to build the client list, fix the data flows and put a price on the work will find that a mandatory change has handed them a reason to review every employer client's benefits package, and to charge for it.
The groundwork is mostly practice management. Knowing which clients are affected, tracking who owes payroll what and by when, and making sure the November registration decision reaches the right clients before the deadline passes. TaxCalc Practice Manager and Engager are built for exactly that kind of client segmentation and task tracking, so the planning work happens on schedule instead of in a live payroll year.
If you would like to see how TaxCalc can help your firm get ahead of April 2027, take a free trial today.