HMRC lets employers exclude globally mobile staff from 2027 BiK payrolling

Employers will be able to keep globally mobile employees outside mandatory payrolling of benefits in kind from 6 April 2027GOV. A new HMRC service, available from November 2026, lets employers voluntarily exclude globally mobile employees from the real-time regimeGOV; those employees continue to be reported through the existing year-end forms P11D and P11D(b). The exclusion is optional: employers that do not use it bring globally mobile employees into mandatory payrolling like everyone else.

The exclusion sits inside the phased start of mandatory real-time reporting of Income Tax and Class 1A National Insurance contributions on benefits in kind and taxable expenses. From 6 April 2027, Phase 1 covers company cars, car fuel, vans, van fuel and employer-provided medical benefits, alongside taxable expensesGOV. From April 2028, Phase 2 extends mandatory payrolling to most other benefits in kind, except employment-related loans and accommodation, which stay voluntaryGOV.

Employers that go further than the mandate during Phase 1 face a linked obligation. An employer choosing to payroll benefits voluntarily that are not mandated in Phase 1 must also payroll the associated Class 1A National Insurance contributions in real time from 6 April 2027GOV. Voluntary payrolling of the benefit without real-time Class 1A settlement is therefore not an option: the two move together from the same date.

The related update to the Full Payment Submission field list adds one new data item for carsGOV. Benefit type F (cars) now includes a 'Fuel type.' field alongside make and model, date first registered, CO2 emissions, zero-emissions mileage, car identifier, amendment indicator, calculated price, accessory prices, employee capital contributions and payments for private use, availability dates, cash equivalents of car and fuel, engine size and free-fuel dates, plus pay-period and year-to-date totals for cars and fuel. Benefit types G (vans) and I (private medical treatment or insurance) and the new Class 1A fields are unchanged: total real-time Class 1A due in the pay period on payrolled benefits, the year-to-date amount, and the Class 1A Adjustment Box. Employers complete only the fields for benefits they actually provide.

For payroll planning, three dates matter. The exclusion service for globally mobile employees opens in November 2026GOV, so decisions on those employees can be made before the April 2027 start. Technical specifications confirming the final FPS data items follow in autumn 2026, and payroll software must then carry the new fields, including fuel type and the real-time Class 1A totals, for the 6 April 2027 go-live. Legal basis: HMRC interim guidance on mandatory payrolling of benefits in kind (Annex 3 FPS fields; excluding globally mobile employees; voluntary payrolling) and the phased-introduction and default-operation guidance setting Phase 1 from 6 April 2027 and Phase 2 from April 2028.