The new mandatory online filing of P11Ds may cause problems with HMRC’s systems where the agent filing the forms is not also the agent for PAYE and Real-time Information (RTI). HMRC have provided a workaround.

Many employers do not use the same agents for PAYE and P11D reporting. They may use a payroll agency to deal with wages and salaries but then ask their accountant, as their main tax agent, to prepare and file P11Ds. HMRC systems are not currently set up to deal with two separate employer PAYE agents.

  • HMRC have advised the ICAEW that P11D agents in this position should go into their agent portal and add the relevant clients to their unauthorised client list. This will allow them to electronically file P11d and P11D(b)s for those clients without disturbing the agent authority for the PAYE agent.
  • Some agents may need to register for online filing first if they have previously only filed paper returns for clients
    • This requires a PIN being sent out by post so these agents will need to act soon to ensure they are registered in time to meet the P11D filing deadline of 6 July 2023.

Useful guides on this topic

P11Ds: Employers' checklist & top tips
Top Tips for employers on preparing form P11D together with a checklist.

P11D: Reporting benefits and expenses
How do you report benefits and expenses? What is the P11D deadline?

Payrolling of benefits
The value of certain taxable Benefits In Kind can be included in taxable pay when calculating the PAYE deducted from payments of wages and salaries to employees.

External links

Source: ICAEW P11Ds: filing online when a different agent is authorised for PAYE

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