HMRC has been trying to resolve a logjam that is likely to occur when real time information (RTI) filing gets under way in earnest in early April 2013.
As is usual at the turn of the tax years, HMRC schedules several days of downtime for its web gateway to update its mainframe computers so with new rules, rates and functionality. HMRC and its contractors have undertaken to complete the job between 3-6 April. But, fortunately, because 6th April falls on a Saturday, the HMRC technology has a day or two in reserve to complete the work before payroll people get into work on Monday the 8th.
With Easter falling on 31st March, and millions of companies under orders to start filing their RTI submissions from 6th April, the potential for chaos and frustration will be particularly acute in 2013.
Nobody will be able to submit RTI returns until the overhaul is complete, and those already filing under the RTI pilot scheme will also be affected as the validation tests for 2013-14 will be different to the ones that are currently being applied.
The requirements of RTI are to send data to HMRC “on/before” a payroll is run is carried out. So those who complete weekly payrolls in the new tax year won’t be able to file their RTI submissions before the HMRC system is ready to accept them.
HMRC explained that there will be a controlled 'go-live' exercise as the upgrade goes live. “This may mean that coding notices and other outbound notifications issued by HMRC may take a little longer than normal whilst the submissions are fully processed,” they said. However, if the success/failure response from HMRC’s computers is not immediate, it urged users not to press re-send until the validation outcome is known, as this could create duplicate returns.
In an effort to play down fears around the start of RTI, HMRC emphasised that employers will join the scheme according to their normal payroll routine during the month between 6th and 30th April. Those who pay between the 1st and the 5th will not be required to start until the next regular payday - which could fall in May (see guidance below). Many larger employers will come on board in stages between April and October.
There is also no question of anyone getting caught by penalties, as HMRC has vowed not to levy penalties for late/inaccurate RTI submissions to HMRC until 2014 (except for the final payment due each year, for which the penalty regime will be the same as the one currently operating for P35/P14).
RTI returns for 2013/14 should not be submitted before 6 April 2013.
Where an Employer Alignment Submission (EAS) is required, it should be submitted on or after 6 April. Please remember that the EAS should be submitted at least 24 hours before the first FPS. Important: any EAS sent on or after 6 April must be in accordance with the latest version of the validations to apply for 2013/14.
If payroll is processed before 6 April for payday on or after 6 April 2013, the following action should be taken
- Employers do not need to send an FPS containing details of the first payment date in circumstances where the payroll is processed before 6 April. The first RTI submissions for 2013-14 should be submitted on or before the next routine payday. The first submission should contain “this period” details relating to the next routine payment date and include YTD information for payday(s) processed before 6 April for payment on or after 6 April 2013. YTD information should also be included for employees who have left since 6th April 2013. Or:
- If your software does not allow the non-submission of an FPS for a payment date, the EAS and FPS/First FPS should be submitted after 6 April and before the next routine payment date. It is not necessary for these submissions to be received on 6 April.