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      HMRC’s call for evidence on PSAs is the latest in a series of developments relating to the tax compliance reporting of employee benefits and expenses. Alongside the phased introduction of mandatory payrolling of benefits in kind (PBIK) from April 2027, it signals HMRC’s continued focus on how employers report, calculate and govern benefits and expenses compliance.

      PSAs are voluntary arrangements that allow employers to settle income tax and Class 1B National Insurance contributions on certain benefits and expenses on behalf of employees, rather than reporting those items through payroll or on Form P11D. They are commonly used for items that are minor, irregular or impracticable to allocate to individual employees.

      The call for evidence, which closes on 15 September 2026, asks how PSAs operate in practice, how employers decide what to include, and whether the current framework is clear, consistent, and proportionate. HMRC have stated that the exercise is not about changing how benefits and expenses are taxed, but it may inform future changes to PSA guidance, processes or compliance expectations.This makes the call for evidence an issue for employers to be aware of. It provides an opportunity to explain where PSAs work well, where they create practical challenges, and what changes could support proportionate compliance while preserving useful flexibility.

      Caroline Laffey

      Partner, Employer Reward Services

      KPMG in the UK

      What HMRC want to understand

      The call for evidence focuses on practical operation, including:

      • Scope and interpretation - how employers apply the ‘minor, irregular or impracticable’ criteria and decide whether items should be included in a PSA, reported through payroll or included on Form P11D;
      • Administration and processes - how PSAs are agreed, amended, maintained and calculated each year;
      • Compliance effort - the time, cost and resource required to gather data, prepare calculations and manage review controls; and
      • Clarity and consistency - whether further guidance, examples or alternative approaches could support more consistent application.

      Why it matters

      For many employers, particularly those with large or complex workforces, PSAs are an important compliance tool. Any future changes could affect how benefits and expenses are identified, governed, calculated and reported. This is particularly relevant as employers are also preparing for wider changes to benefits reporting through PBIK.

      The call for evidence also gives employers an opportunity to provide practical evidence on how the current PSA framework operates in real business environments, including where data, systems, timing or governance create challenges.

      Practical considerations for employers

      Employers may wish to use the call for evidence as a prompt to take the following actions:

      • Review PSA scope - check whether items included in the PSA remain aligned with the relevant criteria and identify any borderline items requiring review;
      • Assess governance and data readiness - consider who owns the PSA process, how decisions are documented and whether data flows and controls are robust enough for both PSA reporting and wider benefits reporting changes; and
      • Capture practical evidence - document where the current PSA process creates administrative burden, timing issues or data limitations, as well as where it operates effectively.

      Next steps

      KPMG is currently considering its response to this call for evidence. Employers with practical examples, operational challenges or specific concerns may wish to consider whether these should be reflected in feedback to HMRC. If you would like KPMG to consider particular points as part of its response, please contact the authors or your usual KPMG contact.

      For further information please contact:

      Our tax insights

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