Company-paid health insurance is a benefit in kind: P11Ds and the P11D(b) must reach HMRC by 6 July after the tax year ends. Class 1A National Insurance — 15% of premiums — is due by 22 July electronically (19 July by post). A late P11D(b) costs £100 per 50 employees per month late.
- ✓P11Ds and P11D(b) due to HMRC by 6 July following the tax year; employees get copies by then too.
- ✓Class 1A NIC at 15% of premiums is payable by 22 July (electronic) or 19 July (post).
- ✓Late P11D(b) penalties run at £100 per 50 employees for each month or part-month late.
Why health insurance triggers P11Ds at all
When a company pays private medical insurance premiums for employees or directors, the cover is a benefit in kind: the employee is taxed on the value, and the employer owes Class 1A National Insurance at 15% on it. Unless you've registered to payroll the benefit voluntarily, this is all reported after the tax year ends — a P11D per employee who received the benefit, plus one P11D(b) declaring the total Class 1A due.
This applies however small the scheme. A two-director husband-and-wife company paying £1,750 a year in premiums files two P11Ds and one P11D(b), the same as a 50-person firm. The amounts are smaller; the deadlines are identical. The employee pays nothing at the time — the income tax on the benefit is typically collected later through an adjusted tax code.
The deadline calendar
For premiums paid in the 2025/26 tax year (6 April 2025 to 5 April 2026), the dates were:
| Date | What's due |
|---|---|
| 6 July 2026 | P11Ds submitted to HMRC for every employee who had company-paid health insurance |
| 6 July 2026 | P11D(b) submitted, declaring total Class 1A NIC on all benefits |
| 6 July 2026 | Employees given their P11D copies (or the equivalent information) |
| 19 July 2026 | Class 1A NIC payment cleared, if paying by post |
| 22 July 2026 | Class 1A NIC payment cleared, if paying electronically |
The same pattern repeats every year: benefits provided in the tax year to 5 April are reported by the following 6 July and the Class 1A paid by 22 July. HMRC requires online submission — paper P11Ds are no longer accepted. Employees' tax codes are then usually adjusted so they pay the income tax on the benefit through PAYE across the following year.
Note the asymmetry in the July dates: 6 July is a filing deadline, but 19 and 22 July are cleared-funds deadlines — the money must have reached HMRC by then, not merely left your account. And when the 22nd falls on a weekend or bank holiday, payment needs to clear by the last working day before it.
What you actually report for health insurance
For private medical insurance, the figure on each P11D is the cost to you of that employee's cover — their share of the premium the company paid in the tax year, in the P11D's private medical treatment or insurance section. It's usually straightforward, with a few wrinkles worth knowing:
- Use the premium, not the claims. What the employee claimed on the policy is irrelevant; the taxable value is generally the premium the company paid for their cover.
- Family cover counts in full. If the company pays for an employee's partner or children, the whole family premium is generally reportable on that employee's P11D.
- Employee contributions come off. Amounts the employee is required to pay toward the premium (and actually pays) generally reduce the reportable figure.
- Mid-year joiners and leavers. Report what was paid for their cover during the tax year — your insurer's premium statement usually breaks this down by member.
- Class 1A on the total. The P11D(b) sums every employee's benefit; the company pays 15% of that total as Class 1A NIC.
Your insurer or broker can normally produce a per-member premium split on request — worth asking for in May so June isn't a scramble. If the company also pays a policy excess or medical bills directly, those amounts are generally reportable too. The wider tax picture, including corporation tax relief on premiums, is in our tax deductibility guide.
Sort the scheme; we'll flag the deadlines
Penalties if you're late
A late P11D(b) attracts a penalty of £100 per 50 employees (or part-batch of 50) for each month or part-month it's outstanding. So a 10-person scheme filed three months late faces £300; a 60-person scheme the same amount of time late faces £600. HMRC typically issues the first penalty notice once the return is around four months overdue — by which point £400 per 50 employees has already accrued.
Late payment of Class 1A NIC accrues interest from the due date, with percentage-based penalties possible the longer it remains unpaid. Careless or incorrect returns carry their own penalties — potentially up to £3,000 per form in serious cases. Penalty rates and HMRC practice change from time to time, so treat these as the current published figures rather than fixed constants, and check gov.uk for the latest.
April 2027: P11Ds for benefits are on the way out
From April 2027, payrolling of benefits in kind becomes mandatory: health insurance will be taxed through payroll in real time, with the benefit value added to taxable pay each period, rather than reported once a year on P11Ds. Class 1A will also move to an in-year process. The July P11D cycle described above continues until then — the final P11D round for health insurance is expected to cover the 2026/27 tax year, due by 6 July 2027.
Companies can already payroll benefits voluntarily by registering with HMRC before the start of the tax year, which removes the P11D requirement for those benefits (the P11D(b) for Class 1A still applies for now). Our payrolling benefits 2027 guide covers the transition, and what it means for employees' tax codes, in full.
Frequently asked questions
When is the P11D deadline for health insurance benefits?
6 July following the end of the tax year. Premiums paid in 2025/26 (ending 5 April 2026) had to be reported to HMRC by 6 July 2026, with employees given their P11D information by the same date. Submission must be online — HMRC no longer accepts paper P11Ds.
When is Class 1A National Insurance due on health insurance?
By 22 July following the tax year if you pay electronically, or 19 July if paying by post — payment must have cleared by then, not just been sent. Class 1A is charged at 15% of the total benefit value declared on your P11D(b).
What is the penalty for filing health insurance P11Ds late?
A late P11D(b) costs £100 per 50 employees (or part thereof) for each month or part-month outstanding — £300 for a small scheme three months late. HMRC's first penalty notice often arrives around four months in, with roughly £400 per 50 employees already accrued. Rates can change, so check gov.uk.
What figure goes on the P11D for private medical insurance?
The premium the company paid for that employee's cover during the tax year — their per-member share from the insurer's premium statement, entered in the private medical section. Family cover paid by the company is generally reported in full on the employee's form; required employee contributions reduce the figure.
Does a small company scheme still need P11Ds for health insurance?
Yes — the P11D regime applies from the first employee covered. A two-director company paying £1,750 in premiums files a P11D for each director plus a P11D(b), exactly like a larger firm. The only current exception is benefits you've registered to payroll voluntarily before the tax year began.
Do directors have to report company-paid health insurance on a P11D?
Yes. Directors receiving company-paid cover are within the benefit-in-kind rules like any employee, so each needs a P11D and the company pays Class 1A at 15% on the premium value. The director then pays income tax on the benefit, usually via a tax code adjustment.
What happens if we forgot to file P11Ds for our health insurance scheme?
File immediately — P11D(b) penalties accrue at £100 per 50 employees for every month or part-month, so acting now caps the damage. Pay the Class 1A plus any interest, and consider a disclosure note to HMRC. Persistent or careless failures can attract further penalties, so speak to your accountant.
Do employees pay tax on health insurance through their tax code after a P11D?
Usually, yes. Once P11Ds are filed, HMRC typically adjusts each employee's tax code so the income tax on the health insurance benefit is collected through PAYE over the following year. A £600 annual premium costs a basic-rate taxpayer £120 in tax, spread across their payslips.
Will P11Ds still be needed for health insurance after April 2027?
No — mandatory payrolling of benefits starts in April 2027, taxing health insurance through payroll in real time instead of annual P11Ds, with Class 1A also moving in-year. The last expected P11D round for medical cover reports the 2026/27 year, due by 6 July 2027.