HMRC’s Step-by-Step Guide for employers is now on version 4. Here is a summary of the changes:
In version 3, there were 5 steps:
- Essential information
- Before you make your claim
- Calculating a claim
- Making a claim
- What to do next
In version 4, there are 7 steps:
- Check you can claim
- Decide who will claim
- Prepare to make your claim
- Calculate your claim
- Make your claim
- After you’ve claimed
- Making additional claims
There is no longer an example given. There was previously one included in the step ‘calculate your claim’.
For working examples, employers should see the guidance ‘Work out 80% of your employees’ wages to claim through the Coronavirus Job Retention Scheme’ (last updated 30 April 2020) or use the calculator itself.
Making the Claim (Step 5 version 4)
As I pointed out in my post of 11 May 2020, there has been a positive change with the addition of the line:
You can save and return at any point during your claim, so if you don’t have all the information you need to complete a claim first time, or you want to take a break during a claim, you can save it and come back later.
This replaces the line in version 3 that said it all had to be done in one session.
Amending the Claim
E-Mail correspondence from Jim Harra, HMRC Chief Executive and Permanent Secretary dated 11 May 2020 said:
We understand that sometimes you might make an error in your claim, and we’re working on a process to enable you to amend a claim. In the meantime, please don’t amend your next claim to reflect any errors that you may have made in a previous one, as this could delay payment. If we spot an error then, where possible, we’ll contact you or your agent to correct the claim.
Version 4 still says:
You can’t make changes to your claim once it is submitted.
Presumably, this is a work-in-progress project and we can look forward to more updated guidance a version 5 in due course.
Reporting via Real Time Information (RTI) (Step 6)
Version 4 includes the line:
To ensure employees’ wages are correctly reported to HMRC you should check if you need to report payments on the PAYE Real Time Information system
This is confusing and implies that RTI has changed as a result of the CJRS and there is additional reporting. This is not correct. When payment is made to employees, the Full Payment Submission (FPS) has to be sent to HMRC on or before payday, quoting the correct payment date. The payment date is vital for the workings of the Universal Credit system and always has been.
Employers may want to refer to the guidance ‘Reporting employees’ wages to HMRC when you’ve claimed through the Coronavirus Job Retention Scheme’ which includes the following sections:
- If you’re using the grant to pay wages
- If you’re using the grant to reimburse wages already paid
- If you have not paid your employees’ full wages yet
Employers need to consider that withholding payment of wages without agreement with employees is a breach of employment law. If employees are not paid on their contractual payday then they have suffered an unlawful deduction from wages. Being taken to an Employment Tribunal (in Great Britain) or Industrial Tribunal (in Northern Ireland) is a very real possibility for unlawful deductions.
Employers also need to be fully aware that more workers may be claiming Universal Credit, the main trigger for which is the earnings declared on the FPS. If employers are sending an FPS for a payment that has not been made, not only is the individual not receiving their wages but their Universal Credit payment will be affected.
Version 4 is a very different version that any other that has been published so far. Employers are likely to be using the guidance in versions 1, 2 or 3. I would definitely recommend downloading version 4.