RTI payroll in the UK: Full Payment Submission and EPS deadlines, penalties, and corrections

Under RTI payroll (Real Time Information), every UK employer reports pay to HMRC (HM Revenue & Customs, the UK tax authority) each time employees are paid. Each tax month (the 6th of one month to the 5th of the next) has three deadlines: the Full Payment Submission (FPS) on or before payday, the Employer Payment Summary (EPS) by the 19th, and payment to HMRC by the 22nd. Each deadline has its own penalty rule, and each kind of error has its own correction route.

The Full Payment Submission: what it reports and when it is due

For every employee paid in the pay run, the FPS reports the period's pay and its income tax, National Insurance (UK social security contributions) and student loan deductions. The FPS also shows the year-to-date totals, the tax code and the National Insurance category letter applied, and it lists new starters and leavers. Every employee paid must be included, even someone earning less than £96 a week.

Regulation 67B of the Income Tax (PAYE) Regulations 2003 sets the FPS deadline: the submission must reach HMRC on or before the day the employee is paid. A weekly payroll therefore means a weekly FPS, even for small employers that pay HMRC quarterly. The FPS "payment date" field shows the usual payday, even when a bank holiday means staff are paid a day early.

When an FPS can be sent after payday

HMRC accepts a late FPS only in a limited set of situations, most of which have a "late reporting reason" code. Three common cases:

• Payday falls on a weekend or bank holiday: report on the next banking day, using code G.
• The employer has a reasonable excuse, or has not yet received its PAYE reference (the employer's Pay As You Earn registration number): report as soon as possible, using code G.
• Pay depends on the work done on the day (harvest workers paid by the amount picked, for example): report within 7 days, using code F.

A late FPS without a valid reason can lead to an online penalty warning and a penalty.

The Employer Payment Summary and the 19th

The EPS reports amounts that reduce what the employer owes HMRC. An employer sends an EPS when it:

• reclaims statutory maternity, paternity, adoption, shared parental, parental bereavement or neonatal care pay (usually 92% of the amount paid, more for smaller employers that qualify for Small Employers' Relief);
• claims the Employment Allowance (a reduction of up to £10,500 in the employer's National Insurance bill), once per tax year;
• paid nobody in a tax month, in which case the EPS replaces the FPS for that month.

The EPS must reach HMRC by the 19th of the following tax month: for the tax month of 6 October to 5 November, by 19 November. If the EPS is late, the reduction does not apply to that month's bill. An employer that pays nobody in a tax month and sends no EPS can face a late-filing penalty and a "specified charge", HMRC's estimate of the PAYE due.

The PAYE payment deadline: paying HMRC by the 22nd

The PAYE bill (tax and National Insurance reported on the FPS, minus EPS reductions) is due by the 22nd of the following tax month when paid electronically, or the 19th when a cheque is sent by post. Employers that usually owe less than £1,500 a month can ask to pay quarterly, but still file an FPS every payday.

HMRC late-filing penalties by number of employees

Schedule 55 to the Finance Act 2009 sets late-filing penalties by headcount:

HMRC charges no penalty when:

• the payments on a late FPS are within 3 days of payday (HMRC may still penalise employers that file this late regularly);
• a new employer sends its first FPS within 30 days of paying an employee;
• the late return falls in the first tax month of the tax year in which any return is late.

There is at most one penalty per tax month for each PAYE scheme, however many returns that month were late. A return still missing 3 months after its filing date can incur a further penalty of 5% of the tax and National Insurance it should have reported.

Worked example. A client employer with 15 employees pays monthly on the 25th. In tax year 2026 to 2027 its May FPS was late: the first late return of the year, so no penalty. The FPS for the 25 September payday is then filed on 4 October, 9 days late:

1. The FPS is outside the 3-day allowance, and September is not the first late month of the year, so a penalty applies.
2. 15 employees fall in the 10 to 49 band: £200.
3. A second late FPS in the same tax month would not add to the £200.

Had the September FPS still been missing 3 months after payday, with £10,000 of PAYE and National Insurance to report, HMRC could add 5% × £10,000 = £500.

Late-payment penalties and interest

Schedule 56 to the Finance Act 2009 sets the late-payment penalties. A default is a payment made late or short, and the first late payment in a tax year does not count as one. Each later default costs a percentage of the amount paid late: 1% for the first to third default, 2% for the fourth to sixth, 3% for the seventh to ninth, and 4% from the tenth. An amount still unpaid after 6 months attracts an extra 5%, and a further 5% after 12 months. HMRC also charges daily interest on the late amount from the due date.

On a £10,000 monthly bill, the second late payment of the year is the first default: 1% × £10,000 = £100, plus interest.

Correcting mistakes during the year and after 5 April

The employer corrects a wrong figure in the current tax year on the next regular FPS, by updating the year-to-date totals. A wrong payment date needs an additional FPS with late reporting reason H, sent by the 19th of the tax month after the original report.

After the tax year ends on 5 April, a mistake in the final FPS found by 19 April is fixed with an additional FPS showing corrected year-to-date figures and "0" in pay for the period. From 20 April, the employer sends an FPS for the earlier year with the correct year-to-date amounts. The FPS route applies to every tax year from 2020 to 2021 onward; the Earlier Year Update (EYU), which reported only the difference, is no longer accepted for those years. HMRC charges an inaccuracy penalty only where the employer failed to take reasonable care or made the error deliberately.

Summary

• FPS: on or before every payday; late only with a valid reason code.
• EPS: by the 19th of the following tax month, to claim reductions or report a month with no payments.
• Payment: by the 22nd electronically, the 19th by post.
• Late filing: £100 to £400 per tax month by headcount, none for the first late month of the year.
• Late payment: 1% to 4% from the second late payment of the year, plus 5% at 6 and 12 months.
• Corrections: corrected year-to-date figures on a further FPS, in year and for closed years from 2020 to 2021.

A single late FPS, sent within 3 months of payday, costs at most £400 in late-filing penalty. Each further late month can add another penalty. Flux files the FPS on or before each payday and sends the EPS by the 19th whenever one is needed, so a partner's clients meet both filing deadlines without anyone tracking them by hand.