Employer Bulletin: October 2026

HMRC have published their Employer Bulletin for October 2026. Key content includes an update on mandatory payrolling of Benefits In Kind (BIKs), as well as reminders on P11D and P11D(b) filing, common mistakes on Construction Industry Scheme (CIS) monthly returns and the opening of mandatory tax adviser registration for payroll agents.

employer bulletin

Payrolling Benefits In Kind: update on globally mobile employee exceptions and Class 1A National Insurance contributions

In the August 2026 Employer Bulletin, HMRC informed employers how to prepare for the mandatory payrolling of Benefits in Kind (BIKs) and expenses to be introduced in phases from 6 April 2027.

  • Phase 1 will apply to company cars, car fuel, vans, van fuel and employer-provided medical benefits.
  • Employers should start preparing for real-time reporting of Income Tax and Class 1A National Insurance Contributions (NICs) for these BIKs and taxable expenses using payroll from April 2027.
  • HMRC are advising employers of Two updates announced by the government that might affect them and employees.

Exception cases: Globally Mobile Employees (GMEs)

  • Employers will have the option to voluntarily exclude GMEs from mandatory payrolling from 6 April 2027.
  • The GMEs exception is intended for employees whose globally mobile working arrangements create genuine practical difficulties in calculating or reporting BIKs through payroll in real time.
  • Employers will need to tell HMRC which eligible GMEs should be excluded from mandatory payrolling by submitting an online G-Form to HMRC, which will be available from November 2026.
  • Once the G-Form has been submitted, the following arrangements will apply for reporting BIKs for excepted GMEs. Employers should:
    • Leave GMEs BIKs out of mandatory payrolling from 6 April 2027.
    • Continue using the existing year-end reporting process through Forms P11D and P11D(b) for these employees.

Class 1A NICs if employers voluntarily payroll other BIKs

  • From 6 April 2027, when BIKs are voluntarily payrolled, any associated Class 1A NICs must also be reported and paid through payroll in real time. Employers cannot choose to payroll the Income Tax and report the associated Class 1A NICs separately at the end of the tax year.
  • Employers can register to voluntarily payroll non-mandated benefits for the 2027-28 tax year from November 2026. 
  • If a company has already registered to voluntarily payroll non-mandated benefits, the registration will automatically continue for 2027-28.
  • If employers do not want to continue voluntarily payrolling non-mandated benefits, they should withdraw registration by 5 April 2027 and continue to use P11D and P11D(b) forms to report Income Tax and Class 1A NICs.

What employers should do now:

  • Review the BIKs provided to employees.
  • Consider any changes to payrolls, HR and finance processes.
  • Speak to payroll software providers, payroll providers, or an agent to help manage payroll.
  • Identify any employees within the workforce who may be eligible for an exception process.
  • Consider how to communicate these changes to employees.

See Mandatory payrolling of benefits from 2027: Briefing

Mandatory tax adviser registration for payroll agents opens 18 November 2026

If an agent provides payroll or PAYE services and communicates with HMRC on behalf of clients as part of the business, they may need to register under HMRC’s mandatory tax adviser registration requirements.

  • The registration window for payroll agents opens on 18 November 2026.
  • There is no need to register yet, but now is a good time to check whether the requirement applies and understand what action needs to be taken when the window opens.
  • HMRC have published a Checker tool to find out if and when you need to register.

See Mandatory tax adviser registration with HMRC

P11D and P11D(b) for tax year 2025-26

P11D and P11D(b) filing and payment deadlines

  • The deadline for informing HMRC online about any Class 1A NICs that are owed for the tax year ending 5 April 2026 was 6 July 2026. If this has not been done, employers must submit one without delay to avoid any further penalties that may be issued.
  • Any Class 1A National Insurance owed must have been paid by 22 July 2026.

How to submit P11D and P11D(b) online

What to file

  • If benefits or non-exempt expenses (or both) have been paid, or if any benefits were payrolled, a P11D(b) must be filed. Include the total benefits liable to Class 1A NICs, even if some or all of them were taxed through the employees’ pay.
  • The P11D(b) is used to report any employer’s Class 1A NIC liability.
  • Employers must submit a P11D for each employee in receipt of benefits and/or non-exempt expenses unless registered with HMRC online before 6 April 2025 to tax them through payroll. If employers did not register online but then taxed some or all benefits through payroll, employers must still submit a P11D online for all benefits that were not payrolled. 

Nothing to declare

  • HMC only need to be notified that no return is required where they have issued an electronic notice to file a P11D(b) or a reminder to file a P11D(b) letter. A declaration of no return of Class 1A NICs can be made.

Common mistakes when completing a P11D or P11D(b)

  • Entering 6 April 2025 as the start date or 5 April 2026 as the end date for company cars, unless these are the actual dates the employee received or returned the car.
  • Submitting P11D and P11D(b) forms over several days. They must be submitted together, so should only be submitted once all P11Ds and the P11D(b) have been completed.
  • Not including the approved CO₂ emissions figure when reporting a fully electric car.
  • Not including the approved zero-emissions mileage when reporting a hybrid car with approved CO₂ emissions between 1 and 50g/km.
  • Submitting more than one P11D(b) for a scheme. Employers should only submit one P11D(b) showing the total amount due for all employees and directors; any additional P11D(b) will be treated as an amendment.

Employers should also check the P11D(b) to see if the ‘adjustments’ section should be used.

See P11D and P11D(b): Index and P11D: Reporting benefits and expenses

Company car tax calculator:

See Company cars

Construction Industry Scheme (CIS): how to get monthly returns right

The most common mistakes HMRC see with CIS monthly returns are using the wrong deduction rate, missing out material costs and entering figures incorrectly.

Using the wrong CIS deduction rate

  • Contractors must Verify a subcontractor with HMRC before paying them for the first time and again if they have not been included on a CIS return in the current tax year or the previous two tax years.
  • HMRC will tell contractors which deduction rate to use: 20% for registered subcontractors, 30% for unregistered ones, or 0% where the subcontractor has gross payment status.
  • A subcontractor’s deduction rate can change. HMRC will write to the contractor if this happens. Contractors should not rely on an old rate or a rate used on a previous return and must check that the rate used matches the latest rate HMRC has provided.

Not recording the cost of materials:

  • Another common mistake is leaving material costs out of the CIS monthly return. This can make the deduction look wrong, even if the correct deduction rate was used.
  • CIS deductions usually apply to the labour part of a subcontractor’s invoice, not the cost of materials. The material cost should be recorded separately on the return so the payment, materials and deduction figures match records.

Entering incorrect figures

  • Small data entry mistakes can cause problems. For example, entering the wrong payment amount, material cost or deduction amount can make the return inaccurate. Contractos should check each figure against the payroll, invoice or accounting records before submitting the return.

What should be done

  • Before submitting each monthly return, contractors should:
    • Verify subcontractors when required.
    • Use the latest deduction rate provided by HMRC.
    • Record the cost of materials separately when materials are included on the invoice.
    • Check payment, material and deduction figures against their records.
    • Correct any errors as soon as possible if a mistake is discovered.
  • HMRC checks CIS returns and may ask contractors to review their records so they can understand how the return was completed. 

See Construction Industry Contractors and Subcontractors: Tax

Electronic payment deadline falls on a weekend

In November, the Electronic payment deadline falls on Sunday 22 November 2026. To ensure payment for this month reaches HMRC on time, funds need to clear HMRC’s account by 20 November 2026, unless employers can arrange a faster payment.

  • It is the employers' responsibility to make sure payments are on time and if a payment is late, penalties may be charged.
  • Employers will need to check bank or building society’s single transaction daily value limits and cut-off times well in advance of making payment. They will need to make sure that they know when to initiate the payment, so it reaches HMRC on time.

 See Penalties: PAYE and late payment

Guidance for employers on Real-Time Information (RTI) reporting obligations for payments made early at Christmas

Some employers need to pay their employees earlier than usual in December. This can be for several reasons, such as businesses closing during the festive period.

  • HMRC is reminding employers of the permanent easement on reporting RTI that applies during this time.
  • If businesses do pay early over the Christmas period, this must be reported on the normal or contractual payment date on the Full Payment Submission (FPS).
    • For example, if an employer pays on 19 December but the normal payment date is 31 December, the employer will need to report the payment date as 31 December. The FPS would need to be sent on or before 31 December.
  • Doing this will help to protect employees’ eligibility for income-based benefits such as Universal Credit, as an early payment could affect current and future entitlements. 

See RTI: Real-Time Information for PAYE

Make the PAYE Settlement Agreement (PSA) payment by 22 October 2026

A PSA allows employers to make one annual payment to cover all the tax and National Insurance due on small or irregular taxable expenses or benefits for employees.

  • Any electronic payments for a PSA for the tax year ended 5 April 2026 must have cleared into HMRC’s account by 22 October 2026. If the payment is received late, there may be interest payments and a late payment penalty.
  • To pay, employers will need to use the PSA reference number, for example XA123456789012, from the payslip HMRC sent. If they do not have this, they will need to contact the employer helpline for advice.
  • They must not use their PAYE Accounts Office reference to make their PSA payment. Payments received with a PAYE Accounts Office reference are allocated to the normal PAYE account, and employers will continue to receive reminders for the PSA even though they have paid.

See PAYE Settlement Agreements

There is still time to help parent or carer employees receive Child Benefit payments

Anyone who wants to continue receiving Child Benefit should act before 30 November 2026 to get their full entitlement.

  • For customers who missed the 31 August 2026 deadline, Child Benefit payments will have stopped automatically. However, claims can be restarted, with backdating available for up to three months.
  • Parents and carers whose children remain in full-time education can continue to receive Child Benefit. This includes those who:
    • Will study at home due to illness or disability.
    • Start approved training.
  • If the child is starting the second year of a full-time non-advanced education course, they do not need to contact HMRC.
  • Any parent or carer who extends their Child Benefit and who (and/or their partner) has an income of more than £60,000 will be liable to pay the High-Income Child Benefit Charge, which can now be paid through their PAYE tax code.

See High-Income Child Benefit Tax Charge

Welfare counselling guidance update

HMRC have updated its guidance on the tax treatment of employer-provided welfare counselling, which aims to help employers understand how the existing exemption applies.

  • The welfare counselling exemption allows employers to provide certain counselling services to employees without a tax charge arising. The updated guidance does not change the legislation or extend the scope of the exemption. 
  • As part of the update, new examples have been added to illustrate support that may fall within the welfare counselling exemption, including:
    • Mental health support.
    • Menopause support.
  • The revised guidance also provides links to other employment income exemptions that may be relevant when employers provide health and wellbeing support, including:
    • Recommended medical treatment provided to support an employee’s return to work.
    • Health screening and medical check-ups.
    • Employee assistance programmes.
  • Employers who provide welfare counselling, health and wellbeing support, or employee assistance programmes may wish to review the updated guidance at EIM21845 - Particular benefits: exemption for welfare counselling to ensure they are applying the correct tax treatment.

See Medical benefits and health checks

New YouTube video: what is the Foreign Income and Gains (FIG) regime

See Non-Domicile: Rules from 6 April 2025

Statutory Neonatal Care Pay (SNCP) and Neonatal Care Leave

SNCP and Neonatal Care Leave apply to eligible employees whose baby is born on or after 6 April 2025 and requires specialist neonatal care. Both entitlements are available to employees in England, Scotland and Wales. 

  • Employees may be entitled to one week’s SNCP and Neonatal Care Leave for every seven consecutive full days their baby spends in specialist neonatal care, up to a maximum of 12 weeks, provided the baby has entered specialist neonatal care within 28 days of birth.
  • Both SNCP and Neonatal Care Leave are in addition to other statutory family leave and pay entitlements, such as maternity, paternity, adoption and shared parental leave. 
  • SNCP is paid at the statutory rate, or 90% of average weekly earnings, whichever is lower. 

 See Statutory pay entitlement: directors and other employees

Basic PAYE Tools (BPT): Apple support changes

HMRC are aware that Apple plans to end support for Intel-based applications on Apple Silicon Macs from autumn 2027. Basic PAYE Tools (BPT) will continue to operate as normal throughout the 2026-27 tax year. HMRC are assessing the impact of this change for future releases.

The Tell ABAB Report 2026

The Tell ABAB Report 2026 is now available to read. The report presents findings from the annual Tell ABAB Survey, commissioned by the independent Administrative Burdens Advisory Board (ABAB). This year’s survey received the highest number of responses since it began. 

  • ABAB works to understand the needs of small businesses and provide independent advice to HMRC. Its members come from a range of business and professional backgrounds and work with HMRC to identify opportunities to make the tax system simpler and easier to use for small businesses.
  • As an independent advisory body, ABAB provides challenge and scrutiny of HMRC’s services and transformation programmes, including Making Tax Digital and wider improvements to the taxpayer experience. Each year, ABAB publishes a report to Treasury ministers setting out its assessment of HMRC’s progress against the Board’s priorities and recommendations.
  • The feedback received will help ABAB understand the issues that matter most to taxpayers and support ongoing work to reduce administrative burdens across the tax system. Insights from this year’s record level of participation will also help inform future discussions and recommendations.

See ABAB reports record response to survey

Help employees plan and prepare for retirement with the HMRC app

The HMRC app can be downloaded free from the App Store and Google Play Store, giving users the ability to find all their State Pension and retirement needs in one place.

  • In the app, employees can:
    • View their State Pension forecast.
    • Check for gaps in their National Insurance record, and make Voluntary contributions if needed.
    • See their scheduled retirement date.
  • They can also find Guidance on paying tax on a State Pension.
  • HMRC recommend that employers share this message and guidance with employees to help them feel fully prepared for the future.

See State Pension Age

Changes to trade union law: what employers need to know

As part of the ongoing implementation of the Employment Rights Act 2025, a number of reforms related to trade union law are being introduced over the coming months. 

Trade Union Right of Access

  • The Employment Rights Act 2025 introduced a new legal right for independent trade unions to access workplaces and engage with workers, either in person or digitally.
  • From 30 October 2026, employers and unions will be able to negotiate access agreements under a statutory framework set out in the Employment Rights Act 2025. Where agreement cannot be reached, the Central Arbitration Committee (CAC) can reach a determination.
  • The key changes that take effect on 30 October 2026 include:
    • Independent trade unions will be able to formally submit a request to employers to access their workplace(s).
    • Access will be physical, digital, or a combination of both.
    • If agreement cannot be reached, either party will be able to apply to the CAC
    • Employers who employ fewer than 21 workers across all of their workplaces will be exempt from these provisions.
    • The CAC will be responsible for overseeing and enforcing statutory access agreements and can issue fines for breaches of an agreement.

Trade union recognition changes:

  • If an employer does not voluntarily recognise a trade union for collective bargaining purposes, the process by which trade unions negotiate with employers on behalf of their members, the union can apply to the CAC for statutory union recognition.
  • In April 2026, the Employment Rights Act 2025 amended the statutory recognition process by:
    • Deleting the requirement for unions to have the support of at least 40% of the workforce in the proposed bargaining unit in a trade union recognition ballot. Unions only need a simple majority of those voting to win.
    • Deleting the requirement for a union to demonstrate on application to the CAC that they are likely to win a recognition ballot. Unions only need to show the CAC that they have 10% membership of the proposed bargaining unit for their application for recognition to be accepted by the CAC.
  • From 30 October 2026, the Act will further amend the statutory recognition process by:
    • Extending the legislation and Code of Practice on access and unfair practices during the recognition and derecognition process to apply from the point where the CAC accepts an application from a union.
    • Setting a clear timetable for negotiations on access between the employer and union, 20 working days from the point the CAC accepts a trade union recognition application. If no agreement is reached, the CAC will have ten working days to determine a reasonable access agreement
    • Allowing five working days after the close of the recognition ballot for complaints to be submitted to the CAC where an unfair practice is alleged.
    • Making it easier to determine such complaints by only requiring the CAC to consider whether an unfair practice has occurred without considering the effect it may have had.
    • Preventing employers from diluting union membership through mass recruitment by freezing the bargaining unit once a CAC recognition application is submitted, ensuring new recruits are excluded from the recognition process and any recognition ballot.

Code of practice and guidance:

  • A Revised code of practice has been produced to reflect the above legislative changes in the Employment Rights Act in relation to access and unfair practices during the recognition and derecognition process. Subject to parliamentary approval, it will come into force on 30 October 2026. The code:
    • Increases the suggested union access meeting frequency to once every five working days during the recognition and derecognition process.
    • Increases the suggested minimum length of union access meetings to 45 minutes during the recognition and derecognition process.
    • Provides more detailed guidance on trade union digital access and digital communications.

New rights and protections for trade union representatives:

  • From 30 October 2026, employees who are trade union workplace representatives will have stronger rights to paid time off and facilities to fulfil their duties. Subject to parliamentary approval, an updated Code of Practice on time off for trade union duties and activities will come into effect.
  • The Revised draft Acas Code of practice available on the Acas website on time off for trade union duties and activities is expected to be published and come into effect from 30 October 2026.

Industrial action detriments:

  • From 30 October 2026, subject to parliamentary approval, employers will be prohibited from treating workers unfairly, also known as imposing detriments, if the main purpose is to penalise, prevent or deter the worker from taking protected industrial action.
  • This change helps protect workers while still allowing employers to take measures to respond to industrial action where those measures are not solely to penalise, prevent or deter workers.
  • Employers can still proportionately withhold pay for time a worker spends taking industrial action.

New employer duty to inform workers of their right to join a trade union:

  • Employers will be required to give workers a written statement provided by the government informing them of their right to join a trade union. Employers must only amend the statement to add specific workplace information where required or permitted.
  • From 1 January 2027, the statement must be provided to new workers directly at the start of their employment at the same time as the written statement of employment particulars.
  • By 5 April 2027, employers will be required to provide the statement to existing workers using direct or indirect methods.

Guidance and statement:

  • An overview of the duty requirements is available at Trade union reform on the business.gov website.
  • Detailed guidance is expected to be published in November 2026.

Harassment protections: new Acas and Equality and Human Rights Commission (EHRC) guidance

In October 2024, the Worker Protection Act 2023 came into force, requiring employers to anticipate the risk of sexual harassment occurring and take reasonable steps to prevent it.

  • The Employment Rights Act 2025 contains measures to strengthen this and other harassment protections.
  • The following changes will come into force from 30 October 2026:
    • Employers will be expected to take ‘all reasonable steps’ to prevent sexual harassment of their employees.
    • There will be an obligation on employers not to permit the harassment of their employees by third parties.

Employers should:

  • Review the updated guidance published by the EHRC and the Advisory, Conciliation and Arbitration Service (Acas). These are available on the Workplace sexual harassment and third-party harassment page on the Business gov website.
  • Make sure their current harassment policies align with the new measures coming into force. This should include their risk management procedures, reporting routes and harassment training provided to their employees.

External link

HMRC: October 2026 issue of the Employer Bulletin