Being an employer → RTI mechanics
RTI Mechanics — FPS + EPS + Year-End + Penalty Regime
Real Time Information (RTI) is the digital filing regime introduced from April 2013. Employers must file a Full Payment Submission (FPS) on or before each payday, plus an Employer Payment Summary (EPS) where they reduce HMRC liability (e.g. Employment Allowance, statutory pay reclaims, CIS deductions suffered) or have a nil payment period. Year-end: final FPS or EPS by 19 April; P60s to employees by 31 May; P11D/P11D(b) for benefits by 6 July. Late-filing penalties: £100 (1-9 employees), £200 (10-49), £300 (50-249), £400 (250+) per month, plus 5% surcharge if more than 3 months late (Sch 55 FA 2009 + Sch 24 FA 2021).
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In plain English
Under RTI you tell HMRC about every payment to every employee, every time you pay them — not once a year as under the old end-of-year P35 regime. The FPS is the headline file: payments, deductions, NI, tax code, hours worked, leaver/starter info. It must reach HMRC on or before the payday — even one day late triggers a penalty (subject to a 3-day grace concession HMRC has historically applied for small employers, though don't rely on it). The EPS is the offset file. It tells HMRC about reductions to your liability — Employment Allowance, recoverable SMP/SPP etc, Apprenticeship Levy allowance allocation, CIS deductions you've suffered as a subcontractor — and any nil payment period (so HMRC doesn't chase you). EPS is filed by the 19th of the following tax month. Year-end: by 19 April you mark your final FPS for the year. By 31 May employees must receive their P60. By 6 July, if you've provided any taxable benefits-in-kind that aren't payrolled, file P11D for each employee + P11D(b) for the Class 1A NIC liability. Mandatory payrolling of benefits arrives April 2027 (delayed from April 2026), which will replace most P11Ds. Penalty regime under Schedule 55 FA 2009 + Sch 24 FA 2021: monthly band by employee count (£100/£200/£300/£400) for each unfiled FPS, plus 5% additional charge if >3 months late.
How it works
FPS — Full Payment Submission
Filed on or before each payday. Contains: employee personal details + NI number; tax code + tax basis; payment + deductions; NI category + NICable pay; hours worked band; starter declaration / leaver date. New starters generate an FPS that effectively replaces the old P45/P46 process.
EPS — Employer Payment Summary
Filed by 19th of following tax month. Use cases: claiming Employment Allowance (£10,500 from April 2025); recovering statutory pay (SMP/SPP/SAP/ShPP/SPBP/SNCP) + SER reclaim (109% from April 2025); allocating Apprenticeship Levy allowance; declaring CIS deductions suffered; declaring a nil payment period (no payments to anyone that month — prevents HMRC chasing).
Monthly payment to HMRC
Pay the net liability (PAYE + employee NI + employer NI − statutory pay recovered − EA − CIS suffered) by 22nd of following tax month (electronic) / 19th (post). Use the Accounts Office reference. Quarterly payment available if monthly liability is under £1,500/month average.
Year-end procedure
Mark the final FPS/EPS for the tax year by 19 April. Issue P60 to every employee on payroll at 5 April by 31 May. For BiKs/expenses not payrolled: file P11D per employee + P11D(b) for Class 1A NIC by 6 July; pay Class 1A by 22 July (electronic) / 19 July (post).
Penalty regime
Monthly band per unfiled FPS: 1-9 employees £100; 10-49 £200; 50-249 £300; 250+ £400. Concession: first late FPS in a tax year may not be penalised (HMRC operational). 5% additional charge on tax/NIC unpaid >3 months late. Specified charges issued where HMRC has no FPS data. Daily penalties available for sustained non-compliance.
Who this applies to + key conditions
- Operating a PAYE scheme (registered employer)
- Submitting via HMRC-recognised RTI-capable software
- Capable of filing FPS on or before each payday (digital, not paper)
- Maintaining employee data per GDPR (special category data: NI number, tax code)
Statute + manual references
Primary: Income Tax (PAYE) Regulations 2003 (SI 2003/2682) — Real Time Information requirements as amended.
Related: Finance Act 2009 Schedule 55 — late filing penalties; Finance Act 2021 Schedule 24 — refined RTI penalty regime; Income Tax (Pay As You Earn) (Amendment No. 2) Regulations 2012 (SI 2012/822) — RTI introduction; Social Security (Contributions) Regulations 2001 (SI 2001/1004) — NIC reporting
HMRC manual: PAYE Manual (PAYE40000+ RTI); CWG2 Employer Further Guide; PAYE76025 (penalties)
Common mistakes + traps
- Filing FPS after payday — triggers penalty even by one day (no formal grace concession in statute)
- Forgetting to claim Employment Allowance each new tax year — must be re-claimed every April via EPS
- Not filing nil EPS in months with no payments — HMRC assumes underpayment and issues specified charge
- Missing P11D / P11D(b) deadline 6 July — Sch 24 FA 2007 penalty regime
- Failing to mark final FPS at year-end — HMRC treats year as open + chases for additional periods
- Confusing FPS hours-worked bands — incorrect band can flag PAYE for NMW review
Worked example
Alpha Ltd, 6 employees, monthly payroll, claims Employment Allowance
Alpha Ltd runs monthly payroll on the 28th. Tax month 1 (6 April–5 May 2025): gross pay £18,000; PAYE £2,400; employee NI £900; employer NI £1,950; SMP paid £750 (Karen on maternity leave) — Alpha is a small employer so SER reclaim applies at 109%.
- Step 1 — File FPS on or before 28 April with all 6 employee records.
- Step 2 — File EPS by 19 May claiming: Employment Allowance £10,500 (for the year, allocated across months); SMP recovery £750 × 109% = £817.50.
- Step 3 — Calculate net HMRC liability for month 1: £2,400 (PAYE) + £900 (employee NI) + £1,950 (employer NI) − £1,950 (EA absorbs employer NI this month) − £817.50 (SMP+SER) = £2,482.50.
- Step 4 — Pay HMRC by 22 May (electronic) using Accounts Office reference + month 1 indicator.
- Step 5 — Repeat monthly until EA £10,500 exhausted (then employer NI starts being paid in full); at year-end, file final FPS + EPS by 19 April 2026; issue P60s by 31 May 2026.
Outcome: Alpha files on-time FPS + EPS, claims EA + SER, pays net £2,482.50 in month 1, avoids penalty exposure entirely.
How this connects to the rest of the framework
RTI obligations begin from PAYE scheme set-up.
Employment Allowance £10,500 is claimed via EPS — must be claimed each tax year.
SER reclaim (109% from April 2025) is recovered via EPS.
P11D/P11D(b) filing is part of year-end RTI; mandatory payrolling from April 2027 will absorb most BiKs into FPS.
Subcontractor CIS deductions suffered are reclaimed via EPS.
Frequently asked questions
What happens if I miss the Self Assessment deadline?+
Do I need an accountant or can I file Self Assessment myself?+
How do payments on account work?+
What if I file FPS one day late?+
Do I need to file an EPS if I have no adjustments?+
When is mandatory payrolling of benefits effective?+
Can I use HMRC Basic PAYE Tools for RTI?+
Free + regulated-body resources
- GovUK — running payroll →
Operational entry-point for RTI
- PAYE Manual →
Internal HMRC reference
- CWG2 Employer Further Guide →
Definitive operational PAYE reference
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