Benefits in kind: what employers need to know before the rules change
Benefits in kind have always carried a compliance burden — P11Ds, Class 1A NIC, code adjustments. But from April 2027, the way you report and pay tax on employee benefits is changing significantly. Here is what it all means and what to do about it now.
Benefits in kind — non-cash perks that an employer provides to employees or directors — are one of those areas where the compliance rules feel disproportionately complicated relative to the actual value involved. A company car, a private medical policy, a gym membership: all taxable, all reported differently, and all subject to rules that have been patched and updated over decades.
We work with a lot of owner-managed businesses where the director is both employer and employee, which makes benefits in kind especially relevant. Get it wrong and you face HMRC penalties and unexpected National Insurance bills. Get it right and you can use benefits as part of a tax-efficient remuneration strategy.
There is also a significant change on the horizon. From April 2027, reporting benefits through the payroll becomes mandatory rather than optional. That is a meaningful shift in how this all works, and employers who are not prepared will find themselves scrambling. Here is how we think about benefits in kind — what matters, what is changing, and what you should be doing now.
What actually counts as a benefit in kind
A benefit in kind is anything of value that an employer provides to an employee — or a director — that is not included in their cash salary. The list is longer than most people expect.
- Company cars and vans, including fuel provided for private use
- Private medical or dental insurance
- Living accommodation provided by the employer
- Interest-free or low-interest employer loans
- Gym memberships and other lifestyle benefits
- Non-trivial gifts and entertainment
- Assets made available to employees for personal use
Not everything an employer provides to an employee is taxable, however. There are statutory exemptions and trivial benefit rules that take certain low-value items out of the picture entirely — provided the conditions are met. A box of chocolates at Christmas is not a benefit in kind. A £250 cash bonus dressed up as a gift almost certainly is.
The principle that runs through all of it is straightforward: if an employee receives something of economic value as a result of their employment, and it is not covered by an exemption, it is taxable. The employer pays Class 1A National Insurance on the value, and the employee pays income tax. The mechanics of how that happens are where it gets complicated.
How benefits are valued and who pays what
The taxable value of a benefit in kind is generally the cash equivalent — what it actually cost the employer, minus anything the employee has paid back. If a benefit is shared between employees, the value is apportioned accordingly.
Assets made available for an employee’s use (rather than transferred outright) are valued at 20% of the market value at the point the asset was first provided, plus any ongoing running costs the employer picks up. So a piece of equipment worth £10,000 when first provided would give rise to an annual benefit value of £2,000 — regardless of what it is worth today.
Where an asset is transferred to an employee, the value is the higher of its current market value or what the employer originally paid — a rule designed to prevent employers from deflating the taxable amount by running assets into the ground before handing them over.
The employer’s liability is Class 1A National Insurance, charged at the prevailing rate on the total taxable value of all benefits provided. The employee’s liability is income tax at their marginal rate, collected historically through a P11D return and a corresponding adjustment to their tax code. That last part is about to change — which is where the April 2027 reforms become important.
A lot of owner-managed businesses discover, when they actually sit down and go through it, that they have been providing benefits informally without properly accounting for them.
Exemptions worth knowing about
Not all employer-provided perks generate a tax bill, and it is worth being clear on where the exemptions apply — particularly for owner-managed businesses where directors are closely scrutinising their remuneration structure.
Mobile phones
A mobile phone provided by the employer to an employee is exempt from reporting where it is provided primarily for business use and any private use is incidental. This applies to directors as well as employees. If the employer owns the contract and pays the bill, and the phone is genuinely used for business purposes, there is no P11D entry and no benefit-in-kind charge. Where private use is more than incidental, or where the employer simply reimburses a personal phone bill, the position becomes more complicated and HMRC is likely to take a different view.
Trivial benefits
Benefits that cost less than £50, are not cash or a cash voucher, are not provided as a reward for performance or service, and are not provided under a contractual entitlement, can qualify as trivial benefits — exempt from both income tax and National Insurance. For directors of close companies, the annual cap on trivial benefits is £300.
Workplace facilities
Canteen meals available to all employees on the same terms, on-site parking, and employer pension contributions are among the benefits that attract specific exemptions. Each has its own conditions, and assuming something is exempt without checking can be an expensive mistake.
Mandatory payrolling is coming in April 2027
This is the change that every employer — and every payroll provider — needs to be across right now.
Currently, most benefits in kind are reported annually via a P11D return submitted after the end of the tax year. HMRC then adjusts the employee’s tax code for the following year to collect the income tax owed. It is a clunky system that results in tax being collected a year late, employees having unclear tax codes, and employers facing an annual compliance deadline that too often gets left to the last minute.
From April 2027, this changes. Reporting of benefits in kind and taxable employment expenses will become mandatory through the Full Payment Submission (FPS) — the same real-time submission employers already make every time payroll is run. Employers will report benefits alongside wages, and the tax will be collected through payroll in the same way as salary. To prepare, HMRC will automatically remove benefits from employees’ tax codes ahead of the April 2027 implementation.
Employment-related loans and employer-provided accommodation are being handled slightly differently — employers will be able to payroll those voluntarily from April 2027, with mandatory requirements following later.
If you want to get ahead of this, voluntary payrolling is available now. For the 2026 to 2027 tax year, the registration deadline was 5 April 2026 — so if you missed it, the next opportunity is to register ahead of the 2027 to 2028 year, when the change becomes mandatory regardless. Either way, this is not something to ignore until the last minute.
What owner-managed businesses should do now
If you run a limited company and pay yourself through a combination of salary and benefits — whether that is a company car, private health cover, or other perks — the April 2027 changes directly affect your payroll process. In our experience, a lot of owner-managed businesses are on top of the compliance side but have not thought through the practical implications of switching from P11D reporting to real-time payrolling of benefits.
There are a few things worth doing now:
- Review what benefits you currently provide. A lot of clients discover, when they actually sit down and go through it, that they have been providing benefits informally without properly accounting for them. Better to find that yourself than have HMRC find it for you.
- Talk to your payroll provider. The mandatory payrolling change will require your payroll software to handle benefit values in the FPS. Not all providers are equally prepared. Ask the question.
- Consider whether voluntary early adoption makes sense. If your payroll is already straightforward and your benefits are clearly defined, moving to payrolling benefits early can simplify the annual process and remove the P11D deadline from your calendar.
- Check your exemptions are genuinely applying. Particularly around mobile phones and trivial benefits — the conditions need to be properly met, not just assumed.
None of this is cause for panic. But it is the kind of thing that benefits from a bit of forward planning rather than a rush in March 2027.
Our take
Benefits in kind are not a niche concern — they affect most businesses that employ people, and they affect directors of limited companies particularly directly. The rules around valuation, exemptions, and reporting have always required some care to navigate, but the shift to mandatory payrolling from April 2027 adds a layer of change that makes now a sensible time to review how you are handling this.
If you are unsure whether you are reporting benefits correctly, or if you want to think through how the payrolling changes will affect your business, this is exactly the kind of thing we help clients with. It does not need to be complicated once you have the right information and a payroll process that handles it properly.
Initial conversations are free and without pressure — if it would be useful to talk through your situation, we are here.
Frequently asked questions
Do directors of limited companies have to report benefits in kind?
Yes. Directors are treated as employees for benefits in kind purposes, so the same rules apply. If your company provides you with a car, private health insurance, or other non-cash benefits, those need to be valued, reported, and taxed — currently via P11D, and from April 2027 through payroll.
Is a mobile phone provided by my company a taxable benefit?
Not necessarily. There is a specific exemption for employer-provided mobile phones where the phone is used primarily for business and any private use is incidental. The exemption applies to directors as well as employees. If the conditions are met, there is no P11D entry and no benefit-in-kind charge.
What is changing about how benefits in kind are reported from 2027?
From April 2027, employers will be required to report benefits in kind through the Full Payment Submission — the real-time payroll submission — rather than via an annual P11D return. HMRC will remove benefits from employees’ tax codes in readiness. The income tax on benefits will be collected through payroll in the same way as tax on salary.
Can we start payrolling benefits before April 2027?
Yes — voluntary payrolling has been available for several years. To payroll benefits voluntarily in a given tax year, you need to register with HMRC before the start of that tax year. The deadline to register for voluntary payrolling in 2026 to 2027 was 5 April 2026. The next opportunity to opt in early would be before 6 April 2027, at which point it becomes mandatory anyway.
What is a trivial benefit and does it need to be reported?
A trivial benefit is one that costs less than £50, is not cash or a cash voucher, is not provided as a reward for work or performance, and is not a contractual entitlement. Where all conditions are met, it is exempt from income tax and National Insurance and does not need to be reported. For directors of close companies, there is an annual cap of £300 on trivial benefits.