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HMRC launch survey on RTI ‘on or before’ rule

August 21, 2013


HMRC has launched an online survey to find out how difficult the ‘on or before’ rule for reporting PAYE in real time is proving for tax agents and employers. The professional bodies ICAEW and CIPP, among others, have urged their members to respond to the survey in order to give HMRC an accurate picture of how this central element of HMRC’s implementation of RTI is affecting them. The ‘on or before’ rule requires employers to report PAYE on or before the date of payment to their employees.

The results of the survey will be used by HMRC to help them assess the impact of RTI reporting deadlines, and to inform discussions over what changes, if any, HMRC will decide are needed.  This includes what happens next with regard to the temporary relaxation of the ‘on or before’ rule for some small businesses, which will run out in April 2014. HMRC clearly stated when it extended the limited relaxation of the ‘on or before’ reporting rule to April 2014 that it would not be extended a second time.

Quoted in Economia, Paul Aplin, the ICAEW Tax Faculty Technical Committee Chair, said that “The RTI rule that requires employers to report payments to employees on or before the time they are made is a significant problem for small employers, many of whom could have to increase their payroll frequency from 12 times a year to 52 – or more.”  The temporary relaxation of the ‘on or before rule’ allows employers with fewer than 50 employees to make monthly reports to HMRC even if they normally pay their staff daily, weekly or fortnightly.

Paul Aplin, honoured with an OBE in 2009 for his work on behalf of both the accountancy profession and the UK businesses it serves, has been a leading figure in efforts to ensure the views and concerns of business on RTI have been adequately represented to HMRC.

The survey, which is hosted by independent online survey company SurveyMonkey, closes on Friday the 13 September and is expected to require approximately ten minutes to complete.  The responses are confidential, and ICAEW has urged its members to take advantage of this opportunity to make their views known to HMRC by filling out the survey.  Paul Aplin said that it "was felt that a survey would be the best way of finding out the extent and nature of the problems and of identifying solutions." The survey can be found at

Guidance published by the ICAEW Tax Faculty website states that to fill in the survey agents and payroll service providers will need to know: the number of payroll clients they act for; the frequency of the pay cycle each of these payroll clients operate to pay their employees (e.g. weekly, fortnightly, four weekly, monthly, quarterly or annually); how many of these payroll clients have either increased or decreased the pay frequency of employees as a result of RTI, and how many clients make additional payments to their employees in the interim between normal pay dates.

Paul Aplin said "It is vital that anyone who has concerns about the on or before rule completes the survey, especially if they will face problems once the current easement ends."  ICAEW and other employer representatives are continuing to work with HMRC to devise permanent solutions to the problem of the increased reporting burden placed on smaller employers by RTI.

HMRC has asked the professional bodies, including the ICAEW and CIPP to "pass on their thanks’ to all their members for their ‘hard work in making real time reporting a success."

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