Expenses & Benefits (P11D/PSA) for the NHS

Employment Taxes

NHS organisations typically provide a range of benefits in kind and reimburse expenses across diverse staff groups. Without clear rules and reliable processes, obligations can be missed and liabilities can escalate quickly. We help Trusts, ICBs and arms-length bodies set up practical controls for benefits and expenses, so you remain compliant, staff are treated fairly and the evidence stands up to internal/external audit and HMRC.

What needs to be managed

Benefits and reimbursed expenses that are not fully covered by an exemption create an obligation to account for tax and National Insurance. Depending on the benefit and your chosen route, that may be via annual P11D forms (with tax collected through coding), via a PAYE Settlement Agreement (PSA) where the organisation bears the tax/NIC for eligible items, or via payrolling of benefits. From 6 April 2027, payrolling most benefits is due to become mandatory (subject to final HMRC specifications and guidance). NHS bodies should prepare now to avoid year-end bottlenecks and to ensure records and data flows are ready.

Our approach

We start by mapping what benefits you provide, how information moves from providers and departments to payroll, and how exceptions are handled. We then confirm which items are exempt, which should be reported, and where a PSA is appropriate. For Trusts moving to payrolling, we help design a practical process: registration/notifications, valuation methods (including salary sacrifice), data timetables, payroll configuration and pre-submission checks. Where HMRC is already engaged, we prepare your position, quantify exposures and support proportionate disclosure and remediation.

National Minimum Wage (NMW) interactions with salary sacrifice are covered in NMW for the NHS.

Outcomes

Clear, documented policies and responsibilities. Fewer late corrections. Valuations and records that are ready for audit and HMRC review. Staff communications that reduce queries and improve understanding of tax codes, payrolled items and year-end statements.

Typical deliverables

  • P11D/PSA policy pack tailored to NHS roles and scenarios, with guidance for managers and payroll.
  • Payrolling benefits framework: valuation rules, data timetables, RTI checks and evidence logs.
  • Sampling and evidence packs for year-end, with a remediation plan where issues are found.
  • Targeted training for payroll/HR/benefits leads; practical briefing notes for line managers.
  • Employee communications: templates explaining how benefits are taxed, and what to expect on payslips/tax codes.

Next steps

If you would like a focused review, we can confirm priority risks, set immediate actions and provide a realistic implementation timetable aligned to your payroll cycles.

Go to: Employment Taxes for NHS Organisations (hub) · IR35 for NHS · NMW for NHS · VAT Services (hub)

NHS Expenses & Benefits (P11D/PSA) FAQs

Do NHS organisations still need P11Ds if we payroll benefits?

If all relevant benefits are payrolled correctly, P11Ds are not required for those items (except for benefits HMRC still excludes). Any non-payrolled items must still be reported.

What can go into a PAYE Settlement Agreement (PSA)?

Items that are minor, irregular or impracticable to attribute to individuals. Some benefits are excluded. We’ll confirm what is suitable for PSA and what should be exempted or reported instead.

When will payrolling benefits become mandatory?

HMRC intends to mandate payrolling most benefits from 6 April 2027 (final technical specs are pending). Preparing now—valuation rules, data timetables, RTI checks—reduces year-end risk.

How does salary sacrifice affect benefits and NMW compliance?

Salary sacrifice changes the taxable value of certain benefits and can reduce cash pay. You must ensure NMW is still met after sacrifice; we’ll set controls to check this before payroll finalises.

What records should we keep for audit and HMRC?

Keep valuations, data feeds from benefit providers, payroll configuration notes, evidence of exemptions, PSA workings and staff communications. Retain for at least the statutory period and align with audit requirements.

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