The Commissioners for HM Revenue and Customs have made the Social Security (Contributions) (Amendment) Regulations 2026 to create a limited paper filing route for Class 1A National Insurance returns where an employer ceases trading during the tax year. The instrument comes into force on 6 April 2026 and applies only in cessation cases defined in regulation 73 of the Social Security (Contributions) Regulations 2001 (SSCR 2001). Regulation 80 remains the anchor for the content of the Class 1A return (P11D(b)). (gov.uk)
Legally, the change inserts a new paragraph into regulation 80 of the SSCR 2001 so that, where regulation 73 applies, the employer may either file using the approved electronic method set out in regulation 80(1A) or send the return to HMRC in hard copy. This addition does not alter what must be reported for Class 1A; it alters how that return may be delivered when the business has ceased mid‑year. (gov.uk)
The policy impact is narrow. Since 6 April 2023, HMRC has required all P11D and P11D(b) submissions to be made online through PAYE Online or compliant software, a position restated in HMRC’s Employer Bulletin in April 2025. The 2026 amendment carves out a paper option only for employers within regulation 73, leaving the online‑only requirement untouched for all others. (gov.uk)
For practitioners, the key threshold question is whether regulation 73 applies. Regulation 73 sets the timetable for payment and the making of a Class 1A return when a business ceases, while regulation 80 stipulates the information required and points to form P11D(b) as the vehicle HMRC provides. If regulation 73 does not apply, the ordinary online filing rule stands. (gov.uk)
Timing remains critical. In a standard year, the Class 1A return is due by 6 July following the tax year and payment is due by 19 July (or 22 July if paying electronically). In cessation cases, follow the regulation 73 timetable rather than the standard cycle and keep working papers evidencing the calculation up to the cessation date. (gov.uk)
The paper route is intended to be pragmatic where digital channels are unavailable or impracticable at the point of winding up-for example, where system access or software subscriptions lapse after payroll has closed. In such cases, being able to send a signed paper P11D(b) to HMRC provides a route to compliance without reopening digital infrastructure tied to a defunct PAYE scheme.
Penalty provisions are unchanged. Late or missing Class 1A returns remain subject to regulation 81(2) penalties, which HMRC imposes in monthly tranches up to 12 months and then under a separate head thereafter. The paper option does not create additional grace periods or reduce the penalty exposure for late filing. (gov.uk)
HMRC signals that a Tax Information and Impact Note will be published on GOV.UK. Until any operational guidance is issued, employers and agents should assume existing P11D(b) design, signature and record‑keeping standards apply, with the only difference being that eligible cessation cases may post the return instead of filing it online. (gov.uk)
Practical steps for 2026/27 cessations include confirming that regulation 73 has been triggered, finalising Class 1A calculations to the cessation date, choosing the return method (electronic or post) and aligning payment with the regulation 73 timetable. Where HMRC has issued a reminder but there is no liability, firms should use HMRC’s ‘no return’ service to avoid penalty action. (gov.uk)
Scope and extent remain UK‑wide through the 1992 Social Security contributions legislation for Great Britain and Northern Ireland cited in the instrument. For most employers and payroll teams, day‑to‑day processes are unaffected; this is a targeted exception for the small subset of employers exiting mid‑year who need a workable alternative to the online channel.