HMRC guidance addresses PAYE reporting errors during payroll changes

The guidance sits alongside the existing Income Tax (Pay As You Earn) Regulations 2003. Regulation 67B generally requires an RTI employer to report relevant employee payments on or before payment, subject to its exceptions; regulation 67E provides for correcting inaccuracies. GfC22 is practical guidance, not an amendment to those rules or a new reporting deadline.^[1][4][5]

A key control is preserving the link between an employee and their payroll record. Where a payroll ID changes, HMRC says employers should select the payroll-ID-change indicator, supply the old ID and ensure it matches previous submissions. This matters when a group changes payroll software or provider, restructures or merges businesses: an unlinked ID can create a duplicate employment record.^[2]

A PAYE scheme merger and a succession are not interchangeable. HMRC's linked guidance says employers moving staff to a different employer reference must send the final Full Payment Submission under the old reference before the first submission under the new one. The first new-reference submission restarts year-to-date figures from zero, while payroll deductions using a cumulative code use the old pay and tax details.^[3]

For inaccuracies within regulation 67E, the existing rule requires an employer who becomes aware of the error to provide the correct information in the next return for the tax year concerned. However, GfC22 says duplicate employment records or information linked to the wrong person cannot be repaired merely by sending another submission: employers should ask HMRC to correct the PAYE record.^[2][5]

Groups should also reconcile the PAYE scheme and payment references. Misallocated payments can leave a credit in one scheme and a debt in another. If a charge is disputed, HMRC says it will usually pause recovery while investigating, but employers should continue paying amounts they do not dispute. The practical consequence is a payroll-data and reconciliation review, not an assumption that tax liability has disappeared.^[2]