Real Time Information has two submissions and no return. A Full Payment Submission goes to HMRC on or before the contractual payment date for every payment of earnings, carrying pay, tax, National Insurance, student loans, statutory payments, starters, leavers and payroll IDs. An Employer Payment Summary reports what reduces the amount due – statutory payment recovery and NIC compensation, the Employment Allowance claim, Apprenticeship Levy, CIS deductions suffered – and is due by the 19th of the following tax month. An EPS is required even for a month with no payments, or HMRC raises a specified charge on estimated figures. Payment of PAYE and National Insurance is due by the 22nd electronically or the 19th by post. There is no P32 return: the P32 survives only as a software-generated reconciliation report, and it should be reconciled against the PAYE liabilities and payments screen in the Business Tax Account every month, because that is where a duplicate submission or a lost Employment Allowance claim shows up. Late filing penalties run from £100 to £400 a month by scheme size, with the first failure in a year unpenalised and a three-day easement; late payment penalties escalate from 1% to 4% by number of defaults, with a further 5% at six months and again at twelve.
Benefits in kind are where the most widely repeated error currently sits. Mandatory payrolling was announced for April 2026 and deferred to April 2027, and it is now phased: cars, car fuel, vans, van fuel and employer-provided medical benefits from 6 April 2027; most other benefits from 6 April 2028; employment-related loans and living accommodation remaining voluntary permanently. For 2026/27 payrolling is still voluntary, the registration window for the year closed on 5 April 2026, and an employer who did not register must file P11Ds and a P11D(b) by 6 July 2027 with Class 1A payable by 22 July. Registration for voluntary payrolling in 2027/28 opened in November 2026. Any guide telling you payrolling is mandatory now is a year out of date.
Off-payroll working is unchanged for April 2026. Where a worker provides services through an intermediary to a medium or large private-sector client or any public authority, the client determines status and issues a Status Determination Statement, and the deemed employer operates PAYE on the fee and pays employer National Insurance and Apprenticeship Levy on top. Two points cause most of the errors. Deemed employers do not deduct student loan or postgraduate loan repayments – the individual settles those through Self Assessment – and this is a very common payroll mistake. And the small client exemption uses the Companies Act definition, whose thresholds were uprated for financial years beginning on or after 6 April 2025, which expands the pool of clients counting as small and shifts the IR35 burden back to contractors for more engagements, flowing through with the usual lag from the two-consecutive-years test. CEST was last amended on 30 April 2025, returns an inconclusive result in a material proportion of cases and does not test mutuality of obligation, so a CEST print-out on its own is a weak defence.
The umbrella company change did commence, on 6 April 2026, and it is a tax measure rather than an employment-rights one. Where a worker is supplied through an umbrella company, responsibility for ensuring PAYE is operated correctly moved from the umbrella to the recruitment agency – specifically the agency holding the contract with the end client, the one highest in the chain – or, where there is no agency, to the end client. HMRC can recover any underpayment from them. The umbrella remains the employer and must still operate PAYE, and must supply the agency or client with the information needed to check it. It applies to all new and existing supply chains for payments made on or after 6 April 2026, and it does not apply where the off-payroll working, managed service company or salaried member rules already do. A separate employment-rights measure bringing umbrellas within the definition of an employment business is scheduled for 2027; the two should not be conflated. Finally, on termination payments: the £30,000 exemption covers statutory redundancy pay and genuine ex-gratia severance, but unpaid wages, accrued holiday, bonuses, restrictive covenant payments and payment in lieu of notice are always fully taxable and Class 1 NICable, and Post-Employment Notice Pay is calculated by formula and treated as earnings with no access to the exemption. Employer Class 1A at 15% is due on the excess above £30,000, in real time, on the FPS.