Why Your Analysis Report May Not Match Your P11D(b) / EXB Submission

If you notice a discrepancy between the figures shown in BrightPay's analysis reports and the totals on your P11D(b) / EXB year-end submission, this is usually caused by one of the following:

1. Employees on multiple payrolls under the same PAYE reference

If you run more than one payroll in BrightPay under the same PAYE reference (for example, a monthly and a weekly payroll for the same employer), each payroll produces its own P11D data. The EXB submission aggregates benefits across all payrolls under that PAYE reference, so the P11D(b) total will be higher than the figure shown in any single payroll's analysis report. To see the combined total, check the EXB submission file directly rather than relying on a single payroll's report.

2. The benefit value on the payrolled benefit has been overridden in payroll without updating the total benefit value

If the cash equivalent amount on a benefit has been manually overridden whilst processing payroll — for example, to adjust the amount being taxed through the payslip — but the total benefit value on the P11D record itself has not been updated to match, the two figures will diverge. The analysis report reflects the payrolled benefit value processed each period, while the P11D(b) will use the cash value in the employee's record. Always ensure that any manual override to a benefit's payroll value is accompanied by a corresponding update to the total benefit value in the employee's record, and review both figures as part of your year-end reconciliation.

3. The P11D(b) / EXB includes both payrolled and non-payrolled benefits

The EXB submission and resulting P11D(b) Class 1A NI liability covers the total value of all taxable benefits — including both benefits processed through the payroll and those reported via P11D. Certain benefits cannot be payrolled and must always be reported via P11D, ie accommodation and beneficial loans (including directors' loans). These benefits will appear in the EXB total and contribute to the Class 1A NI liability, but they will not appear in payroll analysis reports because they are never processed through the payroll. If your EXB total is higher than your analysis report, check whether any non-payrollable benefits have been recorded — these are expected to be absent from payroll reports and do not indicate an error.

4. Employees added or removed after the EXB was generated

If an employee record was added, edited, or deleted after you generated the EXB submission, the analysis report will reflect the current state of the data whereas the submitted EXB reflects the data at the point of submission. Any retrospective changes — including correcting a benefit value or adding a missed employee — will not automatically update a submission already sent to HMRC. You would need to log into your PAYE account and amended the amount there, as HMRC will only allow 1 submission per PAYE scheme.

5. The Class 1A NI calculation date and mid-year amendments

The P11D(b) calculates Class 1A NI on the total taxable benefits as at the end of the tax year. If benefit values were adjusted — for example, a car benefit amended mid-year or a private medical premium updated — the analysis report may show the current amended payrolled value while the EXB captured an earlier figure on the employee's record. 

6. Carry-forward data from the previous tax year

If P11D benefit data was carried forward from the prior tax year and not reviewed before year-end processing, outdated benefit values may have been included in the EXB submission. The analysis report will reflect whatever has been payrolled in BrightPay, but P11D benefits that were accidentally imported from the previous tax year will still be added to the P11D(b) total. Always review carried-forward benefit records as part of your year-end checklist before generating the EXB.