So the scheme when live as of 6-6:30 this morning.
the immediate issues I can see. Eligibility is based on when RTI's were submitted on or before the 19th of March 2020. If you've employed someone on a monthly basis on say 18th of March 2020, but you submit your monthly RTI on the 31st of March 2020. This employee would not be eligible for the scheme.
also, say if you started the payroll in Feb, requested PAYE reference numbers from HNRC and they were not provided till the 25th of March 2020 (as we know HMRC's processing times are iffy if best). You do not gain access to the scheme.