How to set up a gifting policy and gift register (with a free template)

You might think the terms "gifting policy" and "gift register" might take the glitz and glow out of sending presents... but we promise, doing things by the book doesn't have to be a buzzkill! This is about saving you a headache later, so you can enjoy the "awhhh you shouldn't have! <3" reactions without the underlying anxiety that you might have overspent...

Quick answer: A gifting policy sets out who can send gifts, for which occasions, how much they can spend and who approves it. A gift register is the record of what was actually sent: date, recipient, occasion, value including VAT, approver and whether it counts as a tax-free trivial benefit. Together they keep spend fair across teams, stop gifts tipping into taxable territory, and give finance a clean answer at year end. You can set both up in an afternoon, using the template below.

Why does a business need a gifting policy?

Because if you don't have one, every time you need to send a gift, you have to make a new decision. And despite that being way too much mental load to handle, it means that things can drift and mistakes can be made. 

One manager sends £20 for a birthday, another it's a little too excited and sends £60. Or one of the team leaders is fastidiously marking every single work anniversary, where another continuously forgets. Someone sends a cash bonus "as a gift" and doesn't realise it's taxable, and didn't even think to ask. None of this is about people being careless, or irresponsible. it's just the inevitable outcome when there's no written policy to refer to.

A policy fixes three things at once:

• Fairness: people in different teams get treated the same way for the same moment
• Tax: gifts stay inside HMRC's trivial benefits rules unless you've decided otherwise
• Budget: spend is planned, not discovered in a card statement in January

Don't stress. You don't need reams and reams of information for this. A couple of pages more than enough for the majority of businesses.

What should a gifting policy include?

Let's make this easy. We've laid out a simple outline you can borrow and adapt as you need: 

1. Purpose: Just a few sentences on why you might send a gift in the first place: saying thanks, acknowledging life moments, welcoming new starters. 

2. Occasions: Many organisations have a few things they send gifts for as a matter of principle, like:

• birthdays
• new babies
• weddings
• work anniversaries
• leaving
• bereavement
• illness
• Christmas
• other holidays

List them out, and you'll make sure that there aren't any gaps and no one's forgotten. Remember, you want to be inclusive  

3. Amounts: take away the questions and the approval chain, and determine a set value for each occasion you're deciding to recognise. Also, just a tip: if you keep each gift at or under £50 including VAT, it can qualify as a tax-free trivial benefit - as long as it isn't cash or a cash voucher and isn't a reward for work or performance. For context, in Huggg's UK Employee Gifting Benchmarks 2026, 52.9% of employers spent between £50 and £200 per employee per year.

4. Who can send gifts: Are you focused on manager-led recognition, or is peer recognition something you're interested in? If it's managers, do they have a set budget each, or are all gifts sent from one person?  there's no right or wrong answer. It just depends on the size of your organisation and how quickly you want gifts to arrive when the right occasion happens.

5. Approvals:  need to decide who has to sign off on gifts, and what needs to be signed off. A typical practise we see is automatically allowing anything under the set amounts, but requiring sign-off for any higher values.

6. Recording: Every gift sent goes in the register - we'll cover the details of that in the next section.

7. Gifts to and from clients and suppliers: Something to be aware of... a lot of organisations log gifts and hospitality received as part of the "adequate procedures" the Bribery Act 2010 expects. The Ministry of Justice's guidance recognises that reasonable and proportionate hospitality is a normal part of business, so the aim is transparency, not a ban.

Our employee gifting handbook covers the strategy side, such as which moments matter most and why. The policy is the admin that makes it happen consistently.

What should a gift register record?

The word "register" might give you primary school flashbacks, but all we're saying is keep a simple log of the gifts that have been sent, and to who. Basically, you're  providing a way to quickly answer these questions: who got what, when, why, and was it within the rules?

Free gift register template

We'd suggest making ten columns into a spreadsheet, one row per gift:

1. Date sent
2. Recipient name
3. Team or cost centre
4. Occasion (birthday, work anniversary, thank you, Christmas)
5. Gift and supplier
6. Value including VAT
7. Sent by
8. Approved by (if above the standard amount)
9. Trivial benefit? Yes or no
10. P11D needed? Yes or no, with a note on why

Add an eleventh column for client or supplier gifts, so one register covers both.

How to fill in the tax columns

Mark trivial benefit: yes when the gift is £50 or less including VAT, isn't cash or a cash voucher, isn't a reward for work or performance, and isn't in the person's contract. If any of those fail, mark it no, and P11D needed: yes, unless the company is covering the tax through a PAYE Settlement Agreement.

Two details catch people out:

• The £50 is per gift, not per year, for most employees. Directors and office holders of close companies have a £300 annual cap
• The limit includes VAT. A gift listed at £48 counts as £48

This isn't tax advice, and edge cases are worth a word with your accountant. Our guides to trivial benefits and gift cards and employee gifts and tax go through the rules in detail.

Who should own the gift register?

One person, with a deputy. In most small and mid-sized companies, that's the office manager, PA or someone in the People team.

What matters is that sending and recording happen in the same step. A register that relies on managers remembering to report back will be half-empty by March. If gifts go through one place, the register more or less fills itself in.

How to make the policy run itself

The best policy is the one nobody has to think about. A few things help:

• Give managers a budget, not a form. A set amount per quarter, with the policy's rules built in, means they can send a thank-you the same day without asking
• Make a reason mandatory. If every gift needs an occasion picked from a list, your register's "occasion" column is never blank
• Review it twice a year. Check spend against budget, look for teams that never send anything, and update the amounts if prices have moved

This is how recognition budgets work on Huggg. You give a manager or team a pre-funded budget with limits and a refresh period, and every send needs a reason code. The platform's reporting then gives finance the record of who sent what, to whom, and why, with P11D tracking. You only pay for the gifts you send, and the platform itself is free.

One honest note for finance: if your policy uses gift cards or a gift with choice, there's usually no VAT to reclaim. Both are classed as multi-purpose vouchers, because nobody knows at the point of sale what the recipient will spend them on. Budget on the full price.

A one-page checklist

Before you publish your policy, check you've covered:

• The occasions you'll mark, written down
• A standard amount for each, at or under £50 including VAT where you want it tax-free
• Who can send, and whether they have their own budget
• What needs approval, and who gives it
• A register, with an owner and a deputy
• A line on client gifts and gifts received
• A date to review it

If you'd like to see how budgets, reason codes and reporting work in practice, talk to us.

FAQs

Does a small business need a formal gifting policy?

It doesn't have to be formal, but it should be written down. Even a few lines on occasions, amounts and who approves what will stop spend drifting between teams and keep gifts inside HMRC's trivial benefits rules.

What should a gift register include?

At minimum: the date, recipient, team, occasion, gift, value including VAT, who sent it, who approved it, whether it counts as a trivial benefit, and whether it needs to go on a P11D. Add a column for client and supplier gifts so one register covers everything.

Who should keep the gift register?

One named owner with a deputy, usually the office manager, PA or People team. It works best when gifts are sent and recorded in the same place, so the register doesn't depend on people reporting back.

Should gifts received from suppliers go in the register?

Many businesses log them, as part of showing adequate procedures under the Bribery Act 2010. Reasonable and proportionate gifts and hospitality are a normal part of business; the register simply makes them visible.

Last reviewed: October 2026.