HMRC's system requiring UK employers to report PAYE information (pay, tax, NI, and deductions) electronically on or before each payday, replacing the previous end-of-year reporting model.
Key Takeaways
Real Time Information changed how UK payroll works. Before 2013, employers reported PAYE information to HMRC once a year through an end-of-year return (the P35). HMRC didn't know what employees earned or what tax was deducted until months after the tax year ended. This made it difficult to issue correct tax codes, calculate benefit entitlements, and detect errors or fraud. RTI fixed that by requiring employers to report with every pay run. When you run payroll on the 28th of the month, HMRC gets the data on the 28th of the month. They see each employee's gross pay, tax deducted, NI contributions, student loan deductions, and pension contributions in near real time. The transition was significant. Over 2 million PAYE schemes had to upgrade their payroll software or processes. HMRC invested over GBP 300 million in the RTI infrastructure. The rollout started in April 2012 with pilot schemes and became mandatory for all employers by October 2013. Today, RTI is the backbone of UK payroll compliance. It connects employer payroll data to HMRC's tax systems, DWP's Universal Credit calculations, and the Student Loans Company's repayment tracking. When an employer files an FPS, it doesn't just satisfy a reporting obligation. It triggers tax code updates, benefit payment adjustments, and loan balance changes across multiple government systems.
The FPS is the primary RTI submission. It's sent on or before every payday and contains detailed information about each employee who was paid.
For each employee paid in the period: their name, NI number, date of birth, and address. Pay details: gross pay, taxable pay, tax deducted, employee NI contributions, employer NI contributions, student loan deductions, pension contributions, and statutory payments (SSP, SMP, SPP, etc.). Employment details: start date, leaving date (if applicable), pay frequency, tax code, NI category, hours worked (for NMW compliance). The FPS also contains employer-level data: the employer PAYE reference, Accounts Office reference, and payment period.
The FPS must be submitted on or before the date employees are paid. If payday is the last Friday of the month and that falls on March 28, the FPS must reach HMRC by March 28. For monthly payrolls with a consistent payday, this is straightforward. For weekly payrolls, it means weekly submissions. Employers paying different groups on different dates need separate FPS submissions for each pay date. Late FPS submissions trigger automatic penalties.
If you submit an FPS with incorrect data, you can correct it by including the corrected figures in your next regular FPS. The payroll software should indicate which records are being corrected. For errors in previous tax years, an Earlier Year Update (EYU) is required. HMRC can accept EYUs for up to 6 years after the end of the relevant tax year. Avoid submitting multiple FPS submissions for the same pay date unless absolutely necessary, as this can cause processing issues in HMRC's systems.
The EPS is the secondary RTI submission, used to report information that reduces or adjusts the employer's PAYE liability.
An EPS is needed when: you're reclaiming statutory maternity, paternity, adoption, shared parental, or parental bereavement pay. You're claiming the Employment Allowance (up to GBP 5,000 off your employer NI bill). You're claiming NI credits for apprentices under 25 or employees under 21. You didn't pay any employees in a tax month and want to tell HMRC so they don't expect a PAYE payment. You're reporting CIS deductions suffered. The EPS must be submitted by the 19th of the month following the tax month. Tax month 1 (April 6 to May 5) requires an EPS by June 19.
The FPS reports what you paid employees and what you deducted. The EPS reports adjustments to what you owe HMRC. Think of it this way: the FPS creates the liability (total tax, NI, student loan deductions), and the EPS reduces it (statutory pay recovery, Employment Allowance, NI holiday). Both submissions feed into HMRC's calculation of what the employer owes for each tax month. If the EPS reductions exceed the FPS liability, HMRC issues a refund or credit.
HMRC enforces RTI deadlines through an automated penalty system that scales with employer size.
| Number of Employees | Monthly Late Filing Penalty | Applies From |
|---|---|---|
| 1-9 | GBP 100 | Second default onwards (first is penalty-free) |
| 10-49 | GBP 200 | Second default onwards |
| 50-249 | GBP 300 | Second default onwards |
| 250+ | GBP 400 | Second default onwards |
Understanding the penalty structure helps employers respond correctly when things go wrong.
Each tax month where an FPS is late counts as one default. The first late FPS in the tax year is penalty-free (a grace period). From the second default, monthly penalties apply. If a late FPS remains outstanding for more than 3 months, HMRC charges an additional 5% penalty on the tax and NI outstanding. After 6 months, another 5%. After 12 months, another 5%. For FPS inaccuracies (not just lateness), HMRC can charge separate inaccuracy penalties of up to 100% of the additional tax due, depending on whether the error was careless, deliberate, or concealed.
Employers can appeal RTI penalties within 30 days of the penalty notice. Valid grounds include: the filing was actually submitted on time (provide the submission reference), reasonable excuse (such as the death of a close relative, serious illness, fire or flood destroying records, or HMRC system outages). HMRC is generally reasonable about system-related issues and will cancel penalties if their own systems were down. Commercial software failures aren't automatically a reasonable excuse, but HMRC considers each case individually. Appeals are submitted through the employer's PAYE online account or in writing.
RTI submissions must be made through HMRC-recognized payroll software. Manual submissions aren't possible for most employers.
Commercial payroll software (Sage, Xero, QuickBooks, BrightPay, IRIS, etc.) handles RTI automatically. When you finalize a pay run, the software generates and submits the FPS to HMRC using the Government Gateway. HMRC's own Basic PAYE Tools is free software for employers with 9 or fewer employees. It handles FPS, EPS, and year-end submissions but lacks the features of commercial software. Bureau payroll providers and accountants submit RTI on behalf of their clients using their own software. The employer remains legally responsible for the accuracy and timeliness of submissions, even when outsourcing.
RTI submissions use the Government Gateway, HMRC's online authentication system. Employers (or their agents) need a Government Gateway user ID and password, an active employer PAYE scheme, and payroll software that can produce submissions in HMRC's required XML format. Submissions are acknowledged by HMRC with a receipt reference. If the submission fails validation (wrong format, missing fields, NI number mismatches), HMRC returns an error message. The employer must fix the error and resubmit. Most payroll software handles validation checks before submission to prevent rejections.
RTI data feeds directly into benefit calculations, making accurate and timely submissions even more important than just avoiding penalties.
DWP uses RTI earnings data to calculate Universal Credit payments each month. When the employer submits the FPS, DWP receives the earnings data and adjusts the claimant's UC payment accordingly. Late or inaccurate FPS submissions directly affect employees' UC payments. An employee who receives too much UC because the employer filed the FPS late may face an overpayment recovery from DWP, creating financial hardship.
HMRC uses RTI data to monitor whether employees' tax codes are correct throughout the year. If RTI shows an employee earning significantly more or less than expected, HMRC may adjust their tax code. Before RTI, these adjustments happened at year end, often resulting in large underpayment or overpayment notices. RTI enables in-year adjustments, spreading the tax impact more evenly. However, this means FPS errors can trigger incorrect tax code changes, causing problems for both the employee and the employer.
Even with modern payroll software, RTI submissions regularly encounter problems. Here are the most frequent issues and their fixes.