General and Background Information

HMRC recommends that a P46(car) return is made on a quarterly basis at the very least, although the P11D Organiser can be used any day throughout the Tax year to report P46(car) change records at any frequency you choose; this will help to keep employees tax codes and car records as up to date as is possible with HMRC. Information sent is based on the system recognising key changes to previously submitted information about an employee and the provision of a company car - e.g. a car being provided for the first time, a car being replaced with a new one or a car being withdrawn and also other changes like the provision/withdrawal of a fuel card.

The P11D Organiser has the facility to submit benefit & expenses data to HMRC via the internet through a process known as File By Internet (FBI). The system generates an XML return that is sent via the internet to the Government Gateway for each PAYE Reference as a separate submission needs to be made. Since April 2018, if you are payrolling the benefit in kind for cars and car fuel, then the P46(car) routine will exclude those people not excluded from "Payrolling" from the submission process.

Details of how to register can be found at the following website: - or

Accessing the HMRC Filing Facility

Go to the "HMRC Filing" menu option at the top of the application and then select "1. P46(car) Filing By Internet - FBI" 

Note: If this "HMRC Filing" menu option is not visible, your user profile may not have the required "Role" assigned (HMRC FILING). Please contact your system administrator to add this role to your user account. If you are the user administrator, please refer to the user and security guide: Adding Users, The Admin User and System Security

Creating a Submission

Prior to making a live submission to the Government Gateway, you must "prepare" your submission. The Prepare Submission functionality is only a test submission and is a safe way of checking your return as it is not sent to the HMRC live Gateway. This preparation process will build a submission (XML) file, validate it for any errors and then test your connection to the live gateway as well as checking your user credentials for any errors (Government Gateway username and password) 

Your Government Gateway user name and password can also be checked directly with the site here Click this link

Select the PAYE Reference to send using the drop-down selector

Click the Prepare Submission button.


During the prepare submission process, data validation rules will be run and the system may display a number of separate pop-up dialogue boxes to inform you of any records or information that should be checked or that require correction before a live submission is attempted. 

Validation example – Invalid Username and/or password

During first submission or whenever the Gateway credentials need setting you will be presented with the following dialogue

Click Yes and you will need to provide the following before the submission will succeed: -

  • Return email address
  • Government Gateway Sender ID
  • Government Gateway Password

Use this link to the gateway website to check your HMRC Gateway username and password:
Check the box if you would like the system to remember your Gateway Password - you can enter it each time you submit if you would prefer.

Validation example - There are no P46(car) records to be reported 

If the system states that the submission is empty, there are either no new P46(car) records to be sent that have not already been sent in a previous submission, or the system can find no records that would be automatically triggered to be sent to the Gateway. For example, the system cannot automatically detect a car allocation being "withdrawn" on the 5th April or a car "provided for the first time" on 6th April.  The system will also ignore any records set with allocation dates that are set for a future date (greater than today's/system date) in keeping with the Government Gateway's validation rules.

Validation example – Car record has a vehicle with a CO2 value greater than 190
Cars with greater than 190 CO2 value are not necessarily invalid, they may be perfectly correct records with high CO2 values, but the system is flagging these up so that you are aware of them. If you are expecting cars at the high end of the CO2 range then clicking "NO" will bypass this check and allow the records to be submitted when the live submission is made. If you were not expecting cars records at the high end of the CO2 range then clicking "CANCEL" button will cancel the test at this point and offer to create a lookup of the records that are being referred to by the validation rules. Any necessary corrections can then be made to the car details records and any subsequent "prepare submissions" will not find any such "warning" records.  Validation - Resolving validation problems

Having run all of the validation rules, the system will prompt to create a look-up of any records causing the validation problem so that you can check the record to correct the suggested problems and then prepare a new validation/error free submission file.

Once the prepare submission process is complete, the system will pop-up a dialogue box to confirm and offer to view the "P46(car) report" to screen 

The P46(car) report confirms all of the car records that are to be included when you decide to send the the live submission to the HMRC Government Gateway.

The report provides a "reason" for each record together with a key to explain these numeric values (e.g. 3 is a Replacement car) 

STEP 3 – Preparation complete

At the end of the validation the submission window will confirm the file has been validated, the size of the file, and confirm the number of employee and P46(car) records. 

It will also note any “Warning” records for CO2 values etc. that were referred to during the validation process.

Submission window

Once a preparation submission has been successfully run and the records validated, the status window will display and confirm this validation and provide a summary of the return.

Additional Functionality 

After the report has been generated and displayed, a series of buttons will now be enabled on the FBI screen (M L X & V) these can be used to:-

L: List of submitted employees 
V: View the submitted .xml file (using Internet explorer)
Printer icon: Submission report including Class 1A NIC value, Correlation ID, & submission acknowledgement

Email icon: Functionality to e-mail a copy of the submission report together with a copy of the .XML file for future reference

Accepted: A drop-down button to access and select all previous submissions (historical returns in date/time order)

View ERROR: In the event of a submission error during the Live submission (see below) the Send Submission button will be replaced with View Error button to display the validation issues generated by the Gateway during submission in the XML file.

Creating a Live Submission

Having successfully prepared a submission and dealt with any validation issues, you are now able to send a “Live” submission using the “Send Submission” button. 

This process will poll the Government Gateway and transmit the .XML file to the Gateway. The Gateway will then issue an immediate acknowledgement email to confirm the successful submission and the system statistics window will also confirm the date & time the file was both acknowledged and received at the live Gateway.   

STEP 1 – Enter User credentials
Complete the fields for Email address, Gateway Sender ID and Gateway Password

STEP 2 – Validation
Having entered the user credentials, click the “Send Submission” button. Validation rules will now be run and the system may display a number of separate pop-up screens to point out any records that may require attention before continuing to transmit the live submission.

STEP 3 – Submission Complete
At the end of the validation the “Status” window will confirm the submission file has been validated, the size of the file, and confirm the number of records for each section of the P11D. It will also note any “Warning” messages for CO2 values etc. that were referred to during the validation process.

HMRC Email acknowledgement 

The Gateway will issue an immediate acknowledgement email to confirm the successful submission and the system status window will also confirm the date & time the file was both acknowledged and received at the live Gateway.

P46 (car) FBI submission report

It is recommended that you either print the submission summary report using the Printer button 

Alternatively send yourself an email attaching the submission report and a copy of the .XML file that was sent to the Gateway using the Email button (envelope icon). 

Changes Identified from previous data 

In addition to the standard expected P46 records/categories, the system will also look to validate the car details profile compared with the previous tax year and report any anomalies or changes affecting the car or taxable record. 

Any anomalies that the system refers to include any changes that have been made to the profile of the car such as the CO2 value or PRICE of the car that has been altered from the previous year. These records are referred to and displayed in the Test Submission P46(car) FBI report. Any recognised changes would then be included in the FBI transmission to the Government Gateway in the subsequent LIVE submission.  

A P46(car) summary report is automatically displayed to screen as a representation of the XML submission file. This report's key has 2 main indicators:-


1: Not required

2: Car is provided for the first time

3: Replacement car

4: Second car

5: Car has been withdrawn


A: Standard replacement car

B: Fuel benefit provided

C: Fuel benefit withdrawn

D: CO2 value changed

E: List price changed

F: Private use contribution changed

In the example report below, the record for Gail Adams is reporting a "replacement car" that has a "list price changed" from the tax record in the previous Tax year. (3 E)

The record for Justina Delacruz is reporting a "replacement car" that also has a "Fuel benefit withdrawn" from the tax record in the previous Tax year. (3 C)

Both these records differ from what was reported to HMRC previously at the EOY return so the software will rectify this by making this P46(car) submission to inform HMRC.