I suppose we all are asking ourselves this question. What happens when you don't get a P46 for a new employee from the client for a couple of weeks. How will this work with RTI. Can we backdate or not. Surely a better way to go would be to file on the 19th of the following month just like CIS.
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One of many
This is one of many operational issues around RTI for which there's no clear answer at present.
The RTI starter message includes the equivalent of the existing "P46 not signed or no boxes ticked" state, which currently results in a tax code of 0T week/month 1 being used, so I suppose the same process might be followed.
Along with other payroll software developers, we're currently engaged in regular and detailed discussion with HMRC about the finer points of RTI, and although it's easy to be critical of HMRC they do seem to be listening to us on this occasion, and are putting significant effort into resolving these queries.
Neil.
There's only so much you can do
I tell my clients to ask for a P45 or a completed P46 on the first day or before. If they don't provide one when I have to do the wages I process the payroll with what I have got.