Fleet managers and leasing companies continue to be hit by a lack of zero-emissions range data for plug-in hybrid vehicles, significantly complicating the submission of P11d forms to HMRC. 

Despite the importance of this electric-only range figure, the fleet sector continues to be plagued by missing data

The issue – which is expected to increasingly come under scrutiny from HMRC – impacts PHEVs registered on or after 6 April 2020 emitting 50g/km or less of CO2. For such vehicles, their electric-only range directly affects the level of Benefit-in-Kind that needs to be paid by the driver – and thereby the fleet’s Class 1A National Insurance Contributions as well.

Yet, despite the importance of this electric-only range figure, the fleet sector continues to be plagued by missing data.

Although the issue was highlighted by the Association of Fleet Professionals (AFP) in March 2021, there has still been no solution and the only place the all-important electric-only range figure can be found is on the Certificate of Conformity (CoC) provided with the car when first delivered. It’s not on the V5 nor the DVLA or VCA websites.

And as the first P11d reporting for cars delivered to fleets since 2020 falls due for submission later this year, apparently it’s an issue that’s increasingly on HMRC’s radar – particularly as the number of PHEVs on fleets starts to rise. Despite the pandemic and the overall 29.4% downturn in UK new car registrations, PHEV demand grew by 91.2% last year, hitting 66,877 units, of which a significant proportion went to fleets.

These figures are already rising for 2021. SMMT data for the first five months of the year shows PHEV registrations were up 214.1%. Although the impact of the pandemic on both last year’s and this year’s uptake does muddy the waters, the fact remains that a total of 46,068 PHEVs were still registered from January to the end of May.

According to reports, such growing uptake of PHEVs means that the correct application of the electric-only range on the P11d is something that HMRC is increasingly becoming interested in. And something it will potentially be taking action on in the next few months.

Compounding the issue is the fact that the electric-only range can vary significantly depending on the particular vehicle’s equipment, because of the WLTP testing routine. This can be due to anything from a different wheel size to air conditioning or even a sunroof, which can impact the range and therefore potentially impact which BiK bracket it sits in – realistically from 7% to 13% for the current 2021/22 tax year.

Speaking to Fleet World, one fleet manager said: “When there’s a big difference between the bandings and there will be a lot more PHEVs, suddenly it will become a material difference, so HMRC will be wanting to get their ducks in a row.”

When it highlighted the issue in March, the AFP said that some data providers were gearing up to provide the information on a third-party basis. But speaking to Fleet World, Cap HPI said it’s got no plans in this area.

However, the AFP added that the ideal solution would be for the figure to be included on the vehicle’s V5 and said it was speaking to HMRC about this approach.

Meanwhile, while HMRC said it didn’t have a formal comment, it did point fleets to its Employer Bulletin 82 issued last year. This says that fleets should use the Certificate of Conformity. But if they don’t have this information, it says they should either go to their leasing provider or the car manufacturer if the vehicle is outright-purchased.

But one fleet manager speaking to Fleet World said it should be down to the VCA to provide the data.

They commented: “The main problem is that VCA is not doing its job properly. Their website simply does not include data for all current (and recent) new cars. Several manufacturers have – quite literally – no fuel or emissions data at all currently listed. The basic solution is obviously that VCA should have a mandate to demand these data and manufacturers must provide it promptly for propagation.”

Yet the VCA has denied it has an obligation to provide such data. A spokesperson said: “The data that is published by VCA is supplied by manufacturers on a voluntary basis, and there is no requirement under UK law to supply this information to us. Efforts are ongoing to ensure that the information we publish is as complete as possible.”

And the VCA also pointed fleets to the Certificate of Conformity.

A logical step

Tusker is also urging for help on the issue; it too has been trying to seek clarity for some time now and been liaising with HMRC over a solution.

Kit Wisdom, Tusker’s operations director, said the information it shared in March 2020 remains relevant but added that the CoC remains an inconsistent way to capture the EV-only range for a vehicle.

“Either it is not provided with a vehicle on delivery or it’s only provided to the driver, which is not helpful to a leasing company or for P11d reporting purposes. Or the actual document is not standardised and difficult to read,” he commented.

Instead, Tusker is calling for the DVLA to ensure that vehicles’ electric-only range are documented on the V5 document, like the AFP.

Wisdom said: “The V5 is the best place for important vehicle specific technical details to be captured including CO2 emissions.

“We also feel it is a logical step for the specific electric-only range of a PHEV to be recorded on the respective vehicle’s V5 document. Additional fields have been or can be added to the V5 so a PHEV’s electric-only range should also be included.”

While it seems no instant solution is at hand, fleets running PHEVs are being warned not to rest on their laurels and instead take matters into their own hands, according to the industry expert speaking to Fleet World.

In particular, this means implementing protocols over the retainment and use of the CoC.

They commented: “For any fleets adopting plug-in hybrid vehicles, they should be certain that either the Certificate of Conformity, or a copy of it, is sent to HR or payroll and the fleet department; as opposed to just being a piece of paper that’s thrown out the first time the car is valeted.”

And they added: “There is a potential backlash to this; if drivers (and companies) find their expected ‘low-BiK PHEVs’ are suddenly quite high-BiK because of the missing EV range data, after the P11ds are submitted.

“Who is going to be held accountable for that potential mess? It won’t be VCA or DVLA or the manufacturers who have to deal with HMRC…”

NOTE: The DVLA and SMMT were also contacted for comment.