Real Time Information (RTI) requires employers to report payroll data to HMRC on or before each pay day. The Full Payment Submission (FPS) is the primary mechanism — and late submissions attract automatic penalties.
The basic rule: on or before payday
An FPS must reach HMRC on or before the date employees are paid. This applies to every pay run, regardless of frequency — weekly, fortnightly, four-weekly, or monthly.
For employers paying on the last working day of the month, this means the FPS must be submitted that same day. If payday falls on a weekend or bank holiday, the FPS should be submitted on the last working day before the payment date.
Employer Payment Summary (EPS)
If no employees are paid in a tax month, an EPS must be submitted to inform HMRC. An EPS is also used to reclaim statutory pay, report Construction Industry Scheme (CIS) deductions, and notify HMRC of a temporary cessation of payroll.
The EPS deadline is the 19th of the following month.
Late filing penalties
HMRC applies a penalty based on the number of employees and the number of defaults in the tax year:
- 1–9 employees: £100 per default
- 10–49 employees: £200 per default
- 50–249 employees: £300 per default
- 250+ employees: £400 per default
Employers receive one penalty-free default per tax year. From the second default onwards, penalties apply automatically. HMRC typically issues a penalty notice quarterly.
Common pitfalls
- Submitting after payday (even by minutes) constitutes a late filing
- Using the wrong payment date in the FPS — always report the actual pay date, not the processing date
- Forgetting to submit an EPS for months with no payroll activity
- Failing to report leavers — a leaver not reported on time can cause complications with HMRC records
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