Penalties delayed after hundreds get RTI non-filing notices

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Accountants and payroll providers have been receiving a rash of incorrect PAYE “no-filing” notices as tax body representatives have been calling for a delay to the imposition of automatic penalties under the real time information (RTI) regime.

On Friday morning (7 February), AccountingWEB member 0098087 reported getting a load of RTI non-filing notices for the period ending 5 Feburary, even though their payment run was on the 7th and their RTI returns on the same day.

 A quick survey of the 49 comments that followed established that around 80 similar notices have been incorrectly issued to these AccountingWEB members.

They are not alone.

In recent weeks, AccountingWEB’s Any Answers page has seen RTI-related queries, complaints and rants about...

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HMRC response

This just came in from an HMRC spokesman. Further clarifications are being sought, but this is what we got:

"HMRC has issued an electronic warning message to employers who have not submitted the number of returns expected during the January tax month. The messages are intended to be a helpful reminder to employers in case they have forgotten to make their PAYE submission on time. They are not penalty notices.

Customers who have received one of these messages should not worry, but should ensure that they have sent us one or more of Full Payment Submissions (FPS) for the last month. If they haven’t paid any employees in the tax month then they need to tell us by submitting an Employer Payment Summary (EPS)

In a What’s New item on 10 December, we explained that there were a few instances where an employer may receive a non-filing message although they have filed on time.

These include: 

when an FPS has been sent in advance for this tax year - for example, a sole director/employee planning to take the same earnings each month may have submitted 12 FPS in April for the full year where HMRC has received an Employer Payment Summary (EPS) before 14 October 2013 that reports a 'period for inactivity' - for example, if an employer has sent an EPS in August 2013 to report a period of inactivity from September 2013 to February 2014 

In either instance, if an employer receives a non-filing message they do not need to take any further action. 

In addition, if employers have notified HMRC recently that their business has ceased, then they can ignore the electronic message and do not need to contact HMRC.

We are listening to feedback from stakeholders that these messages are not as useful as we had hoped they would be, and we are looking at how best to make improvements to the messages to ensure they effectively support employers to meet their obligations in the future.

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I have a client who was sent one

Told him to ignore it but we don't need this rubbish. Role on my £1 million premium bond win/lottery win/great auntie dying/euro millions/ PPI claim.....

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Yes, couldn't agree more

memyself-eye wrote:

Told him to ignore it but we don't need this rubbish. Role on my £1 million premium bond win/lottery win/great auntie dying/euro millions/ PPI claim.....

this is now no place for the likes of you and me!

And that, in my humble opinion, is a real shame.

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On track for my forecast!

I merely note that the performance of RTI is pretty well on track to my forecasts made roughly a year ago in posts on this site.

The brown sticky stuff and the fan are moving closer in the wacky world of RTI.

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This system seems to have so many flaws. Typically out of my company I  pay two fees  say £6500 pa each in total  with two payment instalments per year to the two directors. Made one payment in Oct  2013 and tried to do second in February 2014. For one director no problem payments under NIC limits so no NIC liability and can pay gross sum. For other payee the RTI says there is both employer and employee NIC liability despite being under the payment thresholds. Seems to want payment once one pays in total for year about £4000! Have checked that all personal details etc.  are same for both directors but RTI wants to charge NIC. Have given up for February and will try again in March. My basic thought is to ignore what I know to be incorrect calculated employee and employer NIC charges but no doubt that will in due course lead to demands for payment of the spurious sums. Still it will be entertaining. The old system was so much better!


(I have registered nil returns for all pay periods when there were no payments in case that was confusing the system)

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Good piece John-well delivered

Couldn't agree more, however, in my humble opinion, HMRC needs to make a complete overhaul of how the RTI system works. It is becoming a complete waste of time and resources to all stakeholders involved- HMRC included. The sooner they (HMRC) sort it out, the better for all.



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Perhaps when penalties start...

Every time HMRC get it wrong we should issue them (HMRC) a £100 penalty notice, (or reduce our tax payments by the same value) let's see how quick HMRC & the government fix it then...(Disclaimer: this post is meant tongue in cheek!!)

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RTI per se ...

... isn't the problem, it is the deadlines and penalty regime that needs overhauling, the actual nuts and bolts work fine - the biggest problem is the payrolls where the paperwork is done after the payment, and that happens quite a lot - especially in the restaurant/pub and building trades.

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Couldn't agree more.The principal of RTI is not bad but the penalty regime/deadlines may be acceptable for a single firm who does their own payroll but as I keep writing a bureaucratic nightmare for agents. Today's announcement of not introducing fines until October doesn't actually hit the root of the problem

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I have doubts over whether the RTI system is working;

Some months ago we started to receive underpayment notices from the hmrc debt department.  When I eventually spoke with them it turns out that the rti information they have collected for our company is completely inaccurate.  Our two payrolls are run by our accountants who run hundreds of other payrolls too.  The case was passed to  a dedicated team on 15th Jan but they are so busy they have not got to ours yet, as of 11th Feb.

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Why does it seem that HMRC are constantly increasing their workload whilst decreasing the amount of staff?


Also, a quick consensus with my "not quite on time payers" indicates that they are likely to just become increasingly frustrated with HMRC rather than feeling encouraged to pay more promptly.

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Have encountered all the problems listed above and worry come April that my time will be spent checking up after messages rather than doing the work in the first place............

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RTI notices

I get notices from HMRC every month although the returns are in on time. What happens when payroll software is set up for the payment to be made on the 31st although on occasion the wages are not processed until the 1st of the month because of different shifts and part-time hours - are we going to get penalties for this. I think HMRC need to rethink and allow returns to be submitted by the 5th of the following month

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Out of date information on Employers' Dashboard

I spoke to HMRC last week as the Employer's dashboard for my firm was showing a large amount of unpaid PAYE. The person I spoke to basically said not to worry about the information on the Employer's dashboard - they know it is wrong! This is in two respects:-

Firstly, they only update the dashboard about twice a month for EPS returns (on 6th and 22nd), so are often a couple of weeks behind with showing this information; 

Secondly they had problems processing/updating month 8 payments - the dashboard was showing this as outstanding, though the payment cleared through our bank before the due date in December. Needless to say the dashboard did not show we had paid the month 9 amount either, even though this also was cleared through our bank before the due date.

It seems ridiculous for HMRC to impose fines for late payment when the online information provided to employers by HMRC does not allow employers to check whether their EPS returns or payments have been received and processed correctly by HMRC.

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Nuts & Bolts

Sorry I don't agree that the nuts & bolts are OK. It is still a ludicrous system that defies logic. But there again I was an engineer before I was an accountant.

They could have done away with the need to have both Employer and Accounts Office Reference numbers, the need to know if it was Shipley or Cumbernauld, the need to file an EPS after the FPS, the need to file an FPS with zero pay before you can file an EPS saying that you haven't paid anyone, the need to bring forward the processing day to the last banking day before a weekend or Bank Holiday - big businesses do this, small ones would usually run payroll on the next working day - there's another penalty! I'm sure we all have our own favourites.

All bonkers and smells more like a Heath Robinson affair held together with loads of elastoplast in a Third World country than a flagship system for one of the top countries in the world....and the laugh is that we are all paying these people through our taxes.


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We received non filing notices for two of our clients even though the EPS had been filed for the period in question, as no payroll we processed in the period. These clearly say non filing notice and not a warning message. We have received these before and when queried with HMRC, the response was "yes we can see you have filed the correct information at the correct time, please just ignore those notices"! Really helpful as always.

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RTI not the problem?
This is welcome news to me as one of those who has incorrect data on their account with HMRC. I fail to see how this is down to anything other than RTI. I didn't have this problem before it was introduced and I get hassled by debt management because I haven't sorted it out. It's not my problem. It's been escalated to their dispute team but they're still chasing me, although I now know that they can't so tell them so fairly politely.

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Perhaps They can Also Look At Monthly Filing Only

Perhaps, now that they will have extra time to reflect and prepare for penalties.  They will consider what most of us who are actually processing this work are saying.  Change the system so that even for weekly payrolls, a once a month RTI report will do. 

The submitting a report every time an employee is paid rather than once a month, is so hard to monitor.  Even if clients are told NOT to pay outside of payroll day, they don't always listen. 

A Penalty regime being based on not submitting an FPS when 1 employee is paid out of sinc, is just a license to print money in my opinion.

If HMRC introduced once a month reporting only,I feel the majority of the moaning would stop. The system would be easier to process for all, and speaking for the individuals who are processing their own payroll - more people would be able to get it right.

As a stand alone accountant, it has become a nightmare when wanting to take a week or two's break from work.  I never take a holiday from work towards the end of a month to ensure these and other HMRC deadlines are met.  But this has really caused a problem, and I can only foresee the small companies receiving penalty after penalty because of the current required frequency, once penalties come into force.

Why won't HMRC listen to the people operating this system.

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Monthly Filing
Well said Caroline. It's threads like these that keep me sane knowing I am not the only one thinking these things. I, too, have to dove tail in a holiday working round HMRC.
It seems to me a funny old system where employers can get fined for paying their staff when it suits them.

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Perhaps if HMRC had to pay penalties to our clients when they get things wrong, say £100 plus £10/day until they get it right, it might focus their minds.

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HMRC 'helpful reminders'
HMRC's attempts at being helpful are about as useful as a mahogany frying pan and just as daft.

One of my clients is in his second year of RTI despite not needing to be. The day he pays his staff is the day he pays HMRC. Needless to say, the pay for April 2013, made on 26 April, has been allocated to 2012/13. He is shown as having an overpayment for that period and is being threatened with ritual disembowelment in a public place by rusty teaspoon for being consistently late with his payments in 2013/14. This is because some halfwit is incapable of realising that HMRC is allocating the wrong payments each month because one was allocated to the previous year.

Interestingly, his account for 2012/13, which showed an overpayment, is no longer available to view however the threats continue. Attempts to discuss with someone with a brain cell have proved difficult. The last suggestion was to bring the payments up to date and write in for the 2012/13 refund.

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HMRC just doesn't understand how microbusinesses work

Frankly RTI was always going to be a disaster for microbusinesses and some small businesses primarily because Government and HMRC don't understand how such businesses work.

My wife and I run a micro business.  We both (theoretically) take a monthly salary.  However, if we have a slow month or one of our corporate clients decides it will delay payment to its suppliers, then there just isn't the money to pay the salaries.  That's the harsh reality for thousands and thousands  of small/micro businesses!

So what do we do about RTI?  We run an accounts package that does the payroll. OPTION 1 - If I simply delay the payroll run until the cash is in the bank then my payroll package won't submit the automatic return to HMRC until the payroll is run. Since I haven't paid a salary, technically I shouldn't need to report and there is no tax due.  But, unless I submit a 'no salary' RTI return, I get a reminder - and ultimately (when HMRC decide to go ahead) I would get a penalty.

OPTION 2 - If I run the payroll and put the salary into a 'deferred salary account' or into the 'directors loan account' my payroll package submits the RTI as though salary has been paid and I get a demand for payment - even though it isn't due - and again (presumably) I would get fined for late payment.

Both my payroll package and the HMRC on-line RTI basic tool have a setting to say the employee is paid on an irregular basis - but this doesn't seem to have any effect at all! 

...Leaving us between the proverbial rock and a hard place.

So what I am forced to do is keep automatic RTI reporting switched off in my payroll software and use the basic on-line tool each month.  And I thought this government was committed to making it easier for small businesses!


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HMRC did try RTI out....

HMRC did at least attempt to check the effect of RTI on employers - I believe they tried it on Tesco - yes that is a fairly typical employer!!!

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Non-filing notices

We received a non-filing notice for period ended 5 December on a payroll we set up on 6th December with first payments being made on the 11th!

Something clearly went wrong about that time as our own account shows no payments being received for the 5 December period.

The notices are not hard to deal with but it's unnecessary work all the same.

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wrong returns better than no returns

I'm pleased about the delay it does mean a bit more time to try and train the recalcitrant clients but I've come to the conclusion that it will be safer to submit incorrect returns than no returns at all. 

And surely that reduces the whole point of the system to a bit of a mockery, but what else can we do?



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RTi - Generic notices

As a payroll bureau we are now getting loads of these notices not to mention phone calls from debt management - who always choose to phone at 8 o'clock on the morning so that they can leave a message rather than talk to anyone. We are receving notices on schemes that have had a final submission made with a cessation date in, we are getting messages where we have submitted nil EPS and we are now getting notices on all our payrolls who have chosen to use a pay day between the 1st and the 5th of the month - HMRC clearly expect everyone to run payroll by the month-end and cannot cope with normal paydays in the this range.  As for the dashboard - I hardly know where to begin - missing payments, RTI figures that bear no resemblance to our submissions, specified charges, altered payments - you name it. And we cannot even view this as an agent but have to wait for the client to get the login or apply to add the PAYE service to their existing login. We operate payrolls for a number of overseas companies with branches in the UK and like another blogger said - I am embarrassed by the quality of our tax collection agency - it is humiliating to explain to New Yorkers that this is how our system works.A penalty reigeme on top of this just starts to smack of straight forward fraud. Dreadful way to treat professionals and dreadful way to treat employers.Plus - how are HMRC going to explain an increase in the number of P800 notices that RTI is invariably going to generate - we have more employees on wrong tax codes than ever due to duplication of employments by HMRC - and I thought the whole point of this was to reduce P800s? I look forward to how they will manage that in the media. Fed up in payroll land and with auto-enrolment dropping another pile of work on the payroll team...

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Delayed returns notices

I've now received two of these. I rang HMRC after the first one, pointing out that - in common with many businesses - it isn't always possible for us to pay on the same day of the month (last day is usual in our case) and that we always run the PAYE and make the submission consecutively whenever it is done. (We also make our payments quartetly as we always have done...)


The lady on the phone said not to worry and to ignore the notices.


I also pointed out that the description of how to read these RTI notices given in the notification email bore no relation to how you actually have to do it. She said she would pass that comment on, but the most recent email still mentions a number of items you should select or click through on the HRMC site that do not exist (either at all, or in the places mentioned).


Menawhile there are over 300 people employed in the Cabinet Office attempting to bring cohesion and simplicity to the government's web offerings - shame they don't actually appear to be working on any of the web-sites people actually have to use day-to-day!


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RTI - Irregular payments

In theory, declaring employees to be paid irregularly, and sending an EPS to say 'no payment', is how we should cope with director's pay etc.

But the thing I find ludicrous is that I can only send a 'no payment' for LAST month or NEXT month, but not THIS month.  Why???  So if we decide there's no money to pay ourselves this month, we get a warning because we can't send an EPS until 6th of next month.

Even if we delay payment until 5th, we get a warning ... but HMRC are the ones whose months go from 6th to 5th!!

My suggestion to HMRC: small companies can do quarterly VAT and quarterly PAYE/NI payments.  Would RTI on a quarterly basis really be so awful? 

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Aweb has changed its tune!!!!!!!!!!!!!!!

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all this...and....

its still raining

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Incorrect Generic Notices

I had bunch of these in December and spent an hour on the 'phone with the HMRC helpline getting notices on client files saying HMRC were  error.

To my horror, this happened again last week - including generic notices for clients that were sent incorrect notices two months ago!  This time there was a 45 minute wait to get through (so many complainants...) and an hour to have HMRC fault noticed put on client records.  I feel really sad for HMRC staff stoically manning the 'phones.  Perhaps the HMRC managers responsible should spend a day at the front line to understand the impact of getting it wrong. Fat chance.


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Debt management have just phoned and told me that my account is now correct - and it is for all four companies that have had outstanding issues since month 6. Time for a well earned drink tonight!
At least all I have to deal with now are the generic notifications where they tell me off for not submitting an FPS despite having submitted an EPS with no payments.

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Incorrect Generic Notices

As a sole practitioner I'm so fed up with RTI and these notices and phoning HMRC and I deal with less than 10 payroll clients!  When the 'concession' to file weekly payroll by the 5th of the month comes to an end, I and others like me, will never be able to go on holiday without taking the laptop or tablet along too!

Then, when attempting to have a PAYE overpayment reallocated to be told that the client information online can't be relied on.....!    Do I need to continue?!!

Whinge over...for this week!


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This proves that the timetable for RTI was unworkable from day one. It's just like Universal credit. Shambles. This is what happens when you have incompetents running the country. See flooding response.

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As far as I am concerned HMRC are shite.

They have made us unpaid workers for them and owe us no duty of care. If we were employed by them to submit the information charging us penalties if we forget, would be sueable. Giving your employee stress is illegal these days. And isnt this called slave labour. Its been in the news recently.

When I am late it is for a reason.

An employee might have left and I am chasing the leaving date before the Full Payment Submission.

Or I was given info about the payroll run and I am querying it, although I have done it I want to check before I do the FPS..

I am a human being and if I am taken out of my routine it might happen that I forget to do the FPS. I am not a machine, I have a faulty memory. I read on the internet that when you are over 60 things can start to go wrong, they call it cognitive impairment. What is going to hapopen when we as a workforce work til 70 before retirement.

HMRC have gone one step too far with the penalty regime.

I tell you this if they penalise me super glue will be put in their locks

And other should do it as well.


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Thank God I'm retiring

I'm retiring in 4 years, can't come soon enough.

They missed the chance to build a new system from the ground up with logical ( to us humans) things such as payroll month from 1st to the 28th/29th/30th/31st, filing one report FPS, instead of 2 which need to be in different date ranges, changing paydate to suit cashflow, etc, etc.


When the penalty regime comes in I wonder how many small accountants like us will look at the penalties (horrendous) against the rewards (not enough) and give up on running payrolls for clients at all? Reminds me of the late 90's when the Government brought in new regulations for the width of doorways in care homes - lots of small ones went to the wall and suddenly they realised that they didn't have enough care home beds......will there be enough payroll bureaux left to keep HMRC in business?


As I said I'll be retiring in 2018, somehow I don't think RTI will be sorted by then, so my thoughts will be with the poor souls I leave behind.

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They can't build a system from the ground up

They can't build any system from the ground up, as something that it integrates with is certain to change before it's all finalised. I think they have a department that is solely dedicated to changing things, and they have to keep themselves in work.

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RTI - incorrect notices

Same problems in my practice. Incorrect generic notices. Late filing notices also wrong. I too have the "holiday" problem. It cannot be sensible to proceed without a change to a "5th of the month" basis being adopted. I sincerely hope that the feedback here is being reported to the correct people in order to restore confidence and common sense. 

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Well when I posted last Christmas about getting payrolls early for Christmas I was lambasted as I should not be doing weekly payrolls.

We have to always find hotels with Wifi now. No holidays for us.

As for the HMRC. The whole organisation is wrong. Closing enquiry centres is disgraceful. They should be helping people not trapping them and the politicians are all going along with the Daily Mail inspired load of old crap.


Makes me sick.

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My payroll person said from day one it should be like CIS. 19th of the following month. Shambles. Osborne's insane idea. Man is a total fool. No work experience. Knows nothing of the real world, just like the rest of the cabinet.


Just like his centralised deductions idea. Madness. The lunatics really are running the asylum.

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My payroll person said from day one it should be like CIS. 19th of the following month. Shambles. Osborne's insane idea. Man is a total fool. No work experience. Knows nothing of the real world, just like the rest of the cabinet.


Just like his centralised deductions idea. Madness. The lunatics really are running the asylum.

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HMRC IT Systems not fit for purpose

I would have liked to have said IT system, but it is a series of systems of different ages stuck together with sticking plaster.  The right hand doesn't know what the left hand is doing.  Reports of errors to one department can't be corrected if the data is incorrectly uploaded from another department, so they just have to resort to internal emails and hope someone on the receiving end does something.

There is no ownership of issues and no authority to resolve complaints given to the frontline staff at HMRC.  For them it is just on to the next ear bashing from the next complainant, which must be completely soul destroying work.   I despair at the mess that poses as an IT system.  Who is approving the way the systems interact with the outside world?  Do they have crayons and a colouring book, because the results are infantile.

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stinking plaster

'All bonkers and smells more like a Heath Robinson affair held together with loads of elastoplast'.

Of course it is. If they had designed a system that actually worked and required one quintillionth of the manpower and manual intervention that present 'systems' require think what further damage they would have been required to visit upon their fiefdom.

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When is an RTI submission due?

Can somebody help me with this very simple question?  I know the FPS is due before the employee is paid - but when is that deemed to be? - and how does HMRC become aware of this?  Is it (a) the date that the payment file is submitted to the company's bank (b) the date funds are committed by the company's bank or (c) the date the employee receives the money in their bank account.  And how am I expected to notify HMRC the correct date?  Why HMRC has to have this immediately I cannot imagine - why can't they just back down and allow employers to submit by 19th of the month as others have suggested  - or I would even accept an earlier date of say 8th of the month to ensure that they have more up-to-date info.

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When is an RTI submission due? Answer...

Simonwwhitt, the answer is not necessarily any of the dates you quoted.  In the majority of cases it will be (c).  The "payment date" field on the FPS should be the employee's contractual payment date, hence my saying that (c) will be the date.  However where this date falls on a non-banking day, HMRC still require the contractual pay date not the actual pay date.  HMRC use this date to determine whether you have filed "on or before" payday.

You are not required to notify HMRC of the correct date.  Remember that the driver behind RTI was Universal Credit despite HMRC comments to the contrary and that RTI was an "improvement" to the PAYE system.



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"Not available" on the Dashboard

Its good to hear so many others are experiencing the same as we are.  Debt management have made contact by phone and letter around a dozen times since Christmas for one client who is fully paid up but of course the dashboard doesn't say that because they haven't allocated the payments properly.  This client was continually harassed last year for late payment of several thousand pounds which had been paid.  On further investigation "not available" on the dashboard for the previous year "hid" almost the exact amount of missing payments.  That information wasn't volunteered until I had asked specifically why information was available for two years and not one year.  I am now requesting information for another client who has "not available" shown on one year.

RTI is ok until you return to a client for a monthly visit and find you forgot to press "submit" last month.  There's always a lot to get done and it only takes a simple distraction for that final task to get forgotten.  I, too, am human and agree with all the points philfromleeds makes, except perhaps the superglue! 


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Late filing notices for closed PAYE schemes

 I have received late filing notices for closed PAYE schemes. 



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Well, so far under RTI only one of our clients has received an underpayment notice and it was actually correct! So, the system can work.

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Misspelling and other issues

That's "stepurhan", not "stephuran" as it shows in the article.

I will point out that the quote from me in the article is roundly criticising HMRC. I feel I have to do this because I am now going to say things that are likely to get "HMRC lackey" accusations hurled at me again.

There are a lot of reasons to object to the way RTI is operating at the moment. Many are covered in this thread, and I am as gung-ho as anyone about no penalties until the system is proved to work properly. A delay to a specific date is not enough. It should be an open-ended delay until HMRC are able to demonstrate that penalties being levied in error will be, at most, a tiny fraction (no system this size will be 100% perfect)

But people keep on insisting on trotting out reasons that have nothing to do with RTI and having everything to do with not having sensible (or legal, even under the pre-RTI rules) payroll procedures. Here are two examples from this thread.

Joyce Annand wrote:
What happens when payroll software is set up for the payment to be made on the 31st although on occasion the wages are not processed until the 1st of the month because of different shifts and part-time hours - are we going to get penalties for this.
Yes, you will get penalties, and quite rightly so. If you are not paying employees on the 31st, then reporting you are paying them on that date is wrong. If you are paying employees on the 31st, how are you calculating what to give them if you aren't doing the calculations until afterwards? If your payroll program cannot cope with changing dates, change your payroll program.

Marlowe52 wrote:
OPTION 2 - If I run the payroll and put the salary into a 'deferred salary account' or into the 'directors loan account' my payroll package submits the RTI as though salary has been paid and I get a demand for payment - even though it isn't due - and again (presumably) I would get fined for late payment.
Why would you not go for Option 2? If you have credited the salary to a director's loan account it HAS been paid legally. Though the cash has not gone out, the company has created an absolute right for you to receive it. This also gives you a record for NIC purposes and a deductible expense for CT, even if you are not able to physically pay the salary out for a whole tax year. This is basic CT planning and I think you need to speak to your accountant. If you haven't got an accountant, this is just one example of why you should get one.

So please, if you are going to whinge about HMRC getting their house in order, do the same yourselves. HMRC have a lot to answer for, but complaining about things that are actually your own fault undermines our arguments by giving them easy counter-targets.

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We don't go for OPTION2 for precisely the reason you suggest


Thanks for the lecture on how we should be handling our payroll.  Unlike civil servants and some corporate employees, small business owners do not live in a world of certainty regarding their income.  If I don't have enough cash to pay the Directors salaries, I would have thought it would have been fairly obvious that I don't have the money to pay the tax on those salaries I haven't yet paid either.  I'm not entirely sure your assertion is correct that, if I make a note in the accounts (deferred payroll account) that salaries are owed but have not yet been paid, then that means "it HAS been legally paid".  In many cases, the Directors might simply later forego their salary if the business did not pick up, or more cash was required to invest in expanding the business. I'm certain others far better qualified than I will have a more accurate view on this.

As it turns out, the argument is somewhat hypothetical anyway.  As I said in my post, that isn't the strategy we have adopted - precisely because of the uncertainty on when salary is deemed legally paid.  We record salaries in the accounts when we actually have the cash to pay them and we use the HMRC on-line Basic RTI tool to report the fact they have been paid.  But, as many, many people have pointed out in this thread, irregular payments reported through RTI are not working.  I've just had a number of' estimated ('specified') charges that were showing on our company PAYE account removed but I still have a mismatch between the PAYE/NIC paid and calculated by my payroll software and the amount owing calculated by HMRC.

I thought by choosing a reputable payroll software package I was "getting my house in order" - but, as you point out, apparently not!

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