Here are some questions that customers have asked over the last few months. The answers are correct to the best of our knowledge but could be subject to change.
Where can I find out about RTI and the impact for my payroll department?
HMRC have published extensive information on RTI for Employers here: HMRC site
When must my organisation be compliant for RTI?
Organisations with fewer than 5000 employees must be compliant in the first pay period after 6th April 2013.
Employers with more than 5000 and over employees must be compliant by 1st October 2013.
Oracle recommend that all our customers move to RTI processing by the end of August 2013 to be sure of being compliant.
Timeline for sending the FPS:
The FPS must be sent to HMRC before the Employee receives payment in their bank account, what if this is not possible due to payment at a weekend, in cash or by BACS fast payment?
HMRC have relaxed this rule in certain circumstances.
See HMRC DOC.
“In summary, employers will have up to 7 days or the next routine payday to report:
- Payments are made on the day of the work and vary depending on the work done, where it is impractical to report in real time – such as
- a crop picker paid in cash at the end of the day, when their pay is based on how much they have picked; or a casual worker in a pub paid at the end of the night
- Payments are made to employees for whom employers do not have to maintain a Deductions Working Sheet (P11).
There will also be extra time to report payments of benefits and expenses subject to Class 1 NICs but not taxed under PAYE. These can be reported the next time the regular payroll is run, or 14 days after the end of the tax month the payment was made in – whichever is earlier. Notional payments can already be reported to the same timescale. “
What needs to be done if there is an error in the amount paid to an Employee and the BACS transaction is cancelled and a new payment is made?
If a BACS payment is cancelled then the FPS and the BACS payment totals will not balance, this is acceptable. The correction can be made on a Supplementary run with a corrected BACS transmission for the Employee in the same pay period and then the accumulation of the 2 submitted FPS and BACs reports will agree.
If some employees are paid by cheque the FPS and BACS figures will not agree is this acceptable?
Yes this is fine. HMRC are aware that there are instances when employees may receive a cheque or cash payment.
Preparation for RTI
Do I need to upgrade my BACs software?
Your BACS software must be upgraded to allow for the Hash reference field to be included in the submission file. You should contact your BACS software provider as soon as possible as the lead time for an upgrade could delay your RTI go-live.
Do I need to allow for additional processing time for RTI reports?
You will need to schedule additional processing time for running the Full Payment Submission EDI extract after each pay run.
How long will the implementation and testing of the new RTI software take?
The software has been tested vigorously by Oracle Development and also by our customers who took part in the RTI Pilot program. The experience from customers on the pilot indicates that you should allow between 8-12 weeks for testing RTI depending on the complexity of your pay processing. If you have the complexity of Aggregated Assignments testing may take longer.
If my Go live Date for RTI is in the 2013/14 tax year can I start testing before April 2013?
Yes, Oracle is advising customers to start testing as soon as possible. The changes for 2013/14 are minimal compared to the overall specification delivered for 2012/13. However further configuration is still required for the 2013/14 tax year.
The 2012/13 RTI GA patch is the pre-requisite for the 2013/14 RTI posting.
EAS: Employee Alignment Submission
Do all Employers have to submit an EAS?
All large Employers (over 250 employees) must submit an EAS before sending their first FPS. This is a one-off submission.
When should we send the EAS to HMRC?
The EAS must be sent before the First FPS is sent to HMRC. Once the EAS has been sent there is a maximum limit of 30 days before the First FPS is sent to HMRC. Experience from the Early Adopter customers shows that it is worthwhile making sure that the FPS is running error free before sending the EAS. It is also worthwhile planning to send the EAS as close to the First FPS as possible. This will allow the maximum time for sending the FPS in case any issues occur. For example:
Send EAS 2nd of Month First FPS on 22nd of Month – this leaves only 10 days to resend the FPS if there are any issues.
Send EAS 15th of the month, send FPS 22nd of the month this allows 22 days to resend the FPS.
Can we send the EAS in test mode and will we receive confirmation from HMRC that the run is successful?
Yes, you can send the EAS as many times as you wish in test mode. You will only receive a message back from HMRC if the file is rejected. No news is good news.
How long will it take for HMRC to send notification of a rejected file?
This depends on the type of rejection. If it is a technical issue with acceptance through the EDI channel then the notification will be within 20-30minutes. If it a data issue this will take longer. It could be a day or more.
HMRC are validating more data on the Live submissions than they are on the Test submissions, therefore you may have a test submission accepted and the Live submission rejected. The software application has data validation delivered and an error report is produced for your reference. Therefore any rejections may be due to erroneous data, for example an invalid Employer Tax Reference.
Should we still continue to send electronic P45s to HMRC once the EAS has been sent and before the First FPS?
No, stop sending the P45s to HMRC once your Live EAS has been successfully submitted to HMRC. Continue to give the Employee their copy of the P45.
If the EAS is rejected due to a few records having incorrect data does the whole file need to be re-submitted?
Yes, resend the whole file. Unless you are using Split scheme submission, (facility only available from April 2013), in which case you just need to send back the part file that was rejected. EG: sent 4 EAS files, part 2 is rejected. Resubmit part 2 only.
FPS: Full Payment Submission
If an Employee receives an Advance of Pay or a late payment, when must this transaction be reported on an FPS, in a separate return or the next time the regular payroll is run?
This will depend on the type of transaction. See the explanation from HMRC here.
If an Employee has more than one Payment After Leaving will this be accepted by HMRC?
Yes, as long as the Payment After Leaving Flag is shown you can submit any number of Payments on the FPS for employees who have already left employment.
Irregular Payment Flag,
What happens if the Irregular Payment Flag is not set on an Employee record and they have no pay for over 13 weeks?
HMRC will assume that the Employee has left your employment and create a Leaver record for them. The next time they are paid and their record is included on the FPS HMRC will create a new starter record. As the FPS will not include the new starter declaration the record will be rejected and the FPS will have to be resubmitted with a correction for that Employee with the New Starter declaration.
If the flag is set on an Employee record does this have to be taken off each time an Employee has a payment generating a record on the FPS?
No, the flag can be left on an Employee record indefinitely if the Employee has an irregular payment pattern.
Can I set this flag for ALL my employees to save with the administration overhead?
HMRC do not want to see this flag set for all employees unless this is a genuine reason; i.e. all your employees work irregular times – such as temp contracts. The FPS will be accepted if all employees have the flag , however HMRC may contact the Employer for an explanation.
An Employee record can only be sent on the FPS if there is a payment in the pay period. How can the Irregular Payment Flag be sent to HMRC if Payroll is only aware of this requirement once the Employee is not receiving any payments? .
HMRC have now stated that an Employee record can be included in the FPS with zero pay as long as the Period Number is included with the file. Therefore you can send the Employee record with the Irregular Payment Flag Indicator even if tthe Employee is not being paid in the period the FPS is sent.
Will HMRC accept double-barrelled first and last names?
Yes, as long as there is a hyphen or one space between both names.
What happens if there is no 2nd line of an address?
The system will move other lines of the address up to Address line 2 if possible. If there is only one line of the address available the record will be rejected.
Are quotation marks accepted as part of an address?
Yes, but NOT as the first character in Address line 1 and 2. They system will strip out any quotation marks found in the first character of address lines 1 and 2.
Corrections to Data:
How do I correct a change in an Employee’s start date?
If you have incorrectly reported the date an employee first started working for you, you should update your payroll records to reflect the correct start date. You must not, however, report the corrected start date on your next FPS to HMRC as this will result in a duplication of the employee's record on HMRC's systems and the record being rejected as the Starter Declaration will be missing.
What happens if an Employee decides not to leave after the Leave Date has been sent on an FPS?
HMRC guidance is:
"If you have taken an employee off your payroll in error (for example, an employee changes their mind and decides to continue working for you) and you have already notified HMRC of their leaving date on an FPS, you should continue making payments using the same payroll ID and submit FPS but do not enter a new start date.
You cannot use this method if you have given the employee a P45, in this case you will need to make the employee a new starter and give them a different payroll ID."
Employee leaving date is wrong
If you have incorrectly reported the leaving date of an employee you should update your payroll records to reflect the correct leaving date. You must not, however, report the corrected leaving date on your next FPS to HMRC as this will result in a duplication of the employee's record on HMRC's systems.
EPS: Employer Payment Summary
Must the EPS be sent to HMRC every pay period?
No, only if:
- There will be a difference between the amount due to HMRC for Tax and NI on the FPS and the actual amount you are paying HMRC due to the Employer recovering statutory payments or operating CIS.
- It is the final EPS of the tax year
- The PAYE scheme has seized.
NINO Verification Request
Is this the only way to request a validation of an NI No.?
The NI numbers will be checked by HMRC when you send the EAS and also each time you submit an FPS. You should use the NINO Verification Request if you need to verify the NI No., maybe for New Starters, in readiness for the pay run and FPS. Please note there is a limit on each submission of 100 employee records.
When can I start using the NINO Verification Request?
A few days after you have submitted your FIRST FPS.
NINO verification Reply
How long will it take for HMRC to respond to a NINO Verification Request?
HMRC advise that this could take up to 2 weeks. It will depend on whether further investigation is required or whether a NINO is easily found. This will not impact future FPS submissions.
Will the details received from the NINO reply automatically update the Employee record?
Yes, the employee record will be updated with the NI NO. However there could be a response from HMRC stating that: No NI Number is available, wait for HMRC to investigate.
Tax Year End
How do I tell HMRC that I am sending the final submissions for the tax year?
You must set the flag for Final Submission for the Tax Year on the FPS and also on the final EPS.
If I have sent a final FPS and a final EPS and need to make a correction how can I do this?
You can send further FPS returns as long as the Final Submission Flag is set up until the 19th April. You can send a Final EPS at any time up to 6 years after the end of the tax year. EPS only needs to be sent again if the corrected FPS changes the Statutory Payments Recovery & subsequent NIC compensation values.
How do I correct the previous year’s values after the 19th April?
If there are corrections after the 19th April you will need to complete the Earlier Year Update. You can then send a corrected EPS after the EYU has been submitted if required, (if the Statutory Payments recovery and subsequent NIC compensation values have changed).
Will the EYU change each tax year?
Yes, the current lEYU posting is for the 2012/13 tax year. The specification for the 2013/14 tax year has not been published by HMRC. As the FPS and EPS have changed for the 2013/14 tax year then expect the EYU to change also.
Are P60’s still required?
Yes, the P60s must still be sent to the Employee.