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Statutory Payroll Reporting: An Overview
Your complete guide to statutory payroll reporting, covering every obligation that touches your payroll and HR function
In brief: Statutory Payroll Reporting: An Overview is a guide covering every legal reporting obligation that touches payroll and HR. Statutory reporting is a year-round, cross-functional responsibility—not something owned solely by finance—meaning that the errors in payroll data ripple into audited accounts, gender pay gap figures, and employees’ personal tax positions.
We cover the main obligations in detail: FPS and EPS (the RTI submissions to HMRC), P60s, P11Ds, the gender pay gap report, auto-enrolment declarations, and the Apprenticeship Levy. For each one it explains what it is, when it’s due, what typically goes wrong, and how to close the gaps.
It closes with a full deadline calendar mapping every submission to its owner, and a reminder that HMRC doesn’t send reminders—the first sign of a missed submission is usually a penalty letter arriving months later.
What is statutory payroll reporting?
Statutory payroll reporting is the legal obligation on UK employers to submit financial and workforce data to government bodies and regulators. The word statutory means required by statute, or in other words, required by law. If you miss it, there are consequences. HMRC doesn’t send reminders and The Equality and Human Rights Commission doesn’t offer grace periods.
Reporting isn’t a single annual event. It’s a year-round obligation made up of multiple submissions to multiple regulators, each with their own deadlines, formats, and rules. Some happen every payday, others only happen once a year. Some only apply above a certain headcount threshold.
The key regulators you’re reporting to as an employer are:
- HMRC for PAYE, real time information (RTI) submissions, P60s, P11Ds, and corporation tax
- Companies House for annual accounts and the confirmation statement
- The Pensions Regulator for auto-enrolment declarations and re-enrolment
- The Equality and Human Rights Commission (EHRC) for gender pay gap reporting
- The government reporting service where gender pay gap reports are published
⚠️ Important
Statutory payroll reporting isn’t just an accounting or finance team responsibility. The reports that touch payroll and HR are your responsibility—and the penalties for getting them wrong come to the employer, regardless of whether you outsource.
Statutory vs management reporting
These two are often confused. But, knowing the distinction is important as the consequences are very different.
Management reporting is produced for internal use, helping leadership understand how the business is performing. There’s no prescribed format, legal deadline, or external filing. Your monthly management accounts, headcount dashboards, and HR metrics all fall into this category.
Statutory payroll reporting is the opposite in almost every respect. The format is set by law or regulatory guidance with a fixed deadline to an external audience. And if you don’t do it, or don’t do it correctly, you face financial penalties, enforcement action, or both.
The two often use the same underlying data—which is exactly why payroll accuracy matters so much. Your people data feed into both.
The statutory reports payroll and HR teams own
The following obligations sit with payroll and HR teams, either as direct owners or as critical data providers. Each one has a specific deadline, a specific penalty structure, and a specific failure mode.
Full Payment Submission (FPS)
Full payment submissions (FPS) are submitted to HMRC on or before every payday for every employee you pay. It tells HMRC who you’ve paid, how much, what tax and National Insurance (NI) you’ve deducted, and what each employee’s year-to-date position looks like.
The deadline is strict: on or before payday. A late FPS—even by a single day—can trigger a penalty. HMRC uses FPS data to reconcile against what you actually pay them each month.
- FPS submitted after payday: even one day late triggers the penalty clock.
- FPS submitted with incorrect year-to-date figures, then corrected with a second FPS showing only the difference. HMRC reads FPS as cumulative totals, not incremental payments.
- Final FPS of the year not marked as final: HMRC continues expecting submissions into the new tax year.
- Bureau submits FPS but the employer never checks the HMRC Business Tax Account. Meaning errors can go undetected for months.
The most effective control is to automate FPS submission alongside your BACS payment so they’re triggered together, and neither can run without the other. If your software doesn’t support this, build same-day submission into your payroll sign-off process as a mandatory step.
Employer Payment Summary (EPS)
The employer payment summary (EPS) is submitted by the 19th of the following tax month whenever you need to adjust what HMRC expects to receive from you—because you haven’t paid anyone that month, you’re claiming Employment Allowance, or you need to reclaim statutory payments such as Statutory Maternity Pay (SMP) or Statutory Sick Pay (SSP).
The EPS is also how you notify HMRC that your final submission of the year has been made. Missing this step means HMRC continues expecting submissions into the new tax year.
- A nil EPS not submitted when no employees were paid: HMRC continues expecting an FPS and may raise a query or issue a penalty, even though there was genuinely nothing to report.
- EPS submitted after the 19th deadline: HMRC won’t apply the relevant reduction—such as a statutory payment reclaim—to your bill in time, meaning you overpay and need to submit a correction, making sure that HMRC amend the details on their end.
- EPS submitted without a corresponding FPS already in place when employees have been paid: the EPS is always an adjustment to a pay run, not a replacement for one. Submitting it in isolation causes reconciliation issues.
- Employer claims Employment Allowance without confirming eligibility each year: the claim doesn’t always carry over automatically, and claiming it incorrectly creates a discrepancy that can take months to unwind.
The most effective control is to build EPS submission into your standard month-end checklist as a mandatory step—reviewed before the 19th, not after. If you use a bureau, pass all the information they need well in advance of that date; late data from the employer is one of the most common reasons submissions miss the deadline. Legal responsibility for accuracy and timing sits with you regardless of who presses submit. A good payroll solution will prompt you when an EPS is needed, validate figures against your FPS, and maintain a clear audit trail of every submission.
P60
Every employee still on your payroll on 5 April must receive a P60 by 31 May. It summarises their total pay, tax, and NI for the tax year.
P60 errors are usually inherited, not created at year-end. Payroll corrections made during the year that weren’t properly applied carry silently through into year-to-date figures. The employee sees the wrong number. They call HR. You’re now reconstructing months of payroll history.
P60s can’t be reissued if lost. If an employee loses theirs, you can provide a duplicate, but it must be clearly marked as a duplicate copy.
P11D and P11D(b)
If any of these are not taxed through payroll—company cars, private medical insurance, gym memberships, interest-free loans—you need to report these to HMRC on a P11D by 6 July following the end of the tax year. The P11D(b) is the accompanying declaration of Class 1A NI owed on those benefits, with payment due by 22 July.
P11Ds are often treated as a finance-only task—but if your payroll team processes any expenses or benefits during the year, P11D preparation involves you too. Missing the 6 July deadline triggers an automatic penalty of £300 per return, plus £60 per day for continued failure.
Worth knowing:
Payrolling benefits in kind (registering them with HMRC so they’re taxed through payroll rather than reported via P11D) significantly simplifies this process. Rather than gathering and submitting individual P11D forms, the system generates the P11D(b) automatically from data already held in the system—making the submission much quicker. It’s important to note that the P11D(b) and the associated Class 1A National Insurance charge are still due by the same deadline; payrolling removes the data-gathering burden, not the obligation itself.
Payrolling benefits is becoming mandatory in April 2027. Getting ahead of that requirement now reduces year-end complexity and penalty risk.
Gender pay gap report
If you employ 250 or more people on the snapshot date (5 April for private sector employers, 31 March for public sector), you must publish a gender pay gap report every year.
The report requires six specific statutory calculations: mean and median pay gaps, mean and median bonus gaps, the proportion of men and women receiving bonuses, and pay quartile distribution.
Every gender pay gap calculation draws on payroll data. If your hourly rates aren’t held accurately or your bonus payments aren’t consistently recorded, your report will be wrong before you’ve even started. The submission may be HR’s responsibility, but the accuracy depends on payroll.
There’s no fixed EHRC (Equality and Human Rights Commission) penalty for late or missing submission. But the EHRC can take enforcement action, seek court orders, and—perhaps more damaging in practice—publicly name non-compliant organisations. The reputational consequence of a named enforcement action typically arrives faster than the legal process.
Auto-enrolment declaration of compliance
When you first set up a workplace pension scheme, you must complete a declaration of compliance with The Pensions Regulator within five months of your staging date or duties start date. You’ll also need to re-enrol eligible employees every three years and complete a re-declaration.
Ownership typically sits with HR, but payroll alignment isn’t optional. The contribution data flowing through payroll determines whether your declaration is accurate.
Apprenticeship Levy
If your annual wage bill exceeds £3 million, you’re liable for the Apprenticeship Levy which is 0.5% of your total pay bill, with a £15,000 annual allowance offset against it.
Despite being managed day-to-day by training or people teams, the levy is a payroll obligation. It’s calculated on total earnings (including bonuses and commission), declared monthly via the EPS alongside other PAYE adjustments, and paid through PAYE. If your organisation is part of a group structure, connected employers share a single £15,000 allowance, so confirm how this is allocated before filing.
Unused levy funds expire after 24 months in your Digital Apprenticeship Service account. Accurate reporting isn’t just a compliance issue—it affects what your organisation can actually spend on training.
Annual accounts and corporation tax return
These sit with your finance team, but they depend on your payroll data. Wage costs, employer NI, and pension contributions all flow from payroll into the profit and loss account. Your corporation tax return uses payroll costs as a deductible expense.
The dependency runs in one direction only: finance needs clean payroll figures. When a payroll run is corrected but not reconciled, when a bonus is processed in the wrong period, when a leaver’s final pay creates an unresolved variance—those errors don’t stay in payroll. They flow into the audited accounts. The auditors find them. The CFO asks questions. And ultimately, the answers lead back to payroll.
Your statutory payroll reporting deadlines: the complete calendar
Here’s a calendar with all reporting deadlines payroll or HR teams need to manage, mapped to who owns each one, with prep milestones built in.
| Submission | Deadline | Owner |
|---|---|---|
| Full Payment Submission (FPS) | On or before every payday | Payroll |
| Employer Payment Summary (EPS) | 19th of following tax month | Payroll |
| PAYE payment to HMRC | 22nd of following tax month (electronic) | Payroll/Finance |
| P60 issued to employees | 31st May | Payroll |
| P11D submission to HMRC | 6th July | Payroll/Finance |
| P11D(b) Class 1A NI payment | 22nd July | Payroll/Finance |
| Gender pay gap report | 5 April (private) / 31 March (public) | HR/Payroll |
| Auto-enrolment re-declaration | Within 5 months of re-enrolment date | HR |
| Annual accounts (private company) | 9 months after year end | Finance |
| Corporation tax return (CT600) | 12 months after accounting period end | Finance |
It’s worth remembering that HMRC does not send reminders. For RTI penalties, late filing notices, and PAYE charges, the first you’ll know is when a letter arrives, often months after the missed submission. Check your HMRC Business Tax Account monthly, not just when you’re expecting something.
What are the penalty rates?
Per PAYE scheme, per month:
- 1–9 employees: £100
- 10–49 employees: £200
- 50–249 employees: £300
- 250+ employees: £400
£300 per return, plus £60 per day for continued failure
No fixed fine, but the EHRC can take enforcement action, seek court orders, and publicly name non-compliant organisations. The reputational damage tends to be faster than the legal process.
Interest charged from the day after the due date. Surcharges apply for repeated late payment.
How your payroll data feeds into statutory payroll reports
Payroll is the source of truth for multiple statutory reports running simultaneously. The same underlying figures flow into multiple obligations at the same time. Understanding these dependencies is what separates organisations that manage statutory payroll reporting well from those that discover problems after the fact.
| Data from payroll | Feeds into | Consequence of error |
|---|---|---|
| Pay and deduction figures | FPS, HMRC records | HMRC reconciliation fails, penalty notices issued |
| Year-to-date totals | P60 | Employee P60 wrong, manually corrected only via duplicate |
| Benefits in kind data | P11D | Underreported benefits leading to unpaid Class 1A NI, overpayments or over deductions, and incorrect tax codes |
| Hourly pay, bonus, headcount | Gender pay gap report | Statutory calculations incorrect, EHRC risk |
| Wage costs, NI, pension contributions | Annual accounts | Figures are wrong, making auditors query and board exposure |
| Pay figures submitted via FPS | Universal Credit (DWP) | Employee benefits payment incorrect resulting in a HR complaint |
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Common mistakes and what actually prevents them
These are the errors payroll and HR teams make most often. The good news is that most are preventable with the right processes in place.
| Mistake | Consequence | Prevention |
|---|---|---|
| FPS submitted after payday | Monthly RTI penalty | Automate FPS alongside BACS payment so there's no payday without same-day submission |
| Correcting FPS by submitting the difference, not corrected YTD totals | HMRC reconciliation fails, duplicate payment demand | Always submit corrected year-to-date figures, not the adjustment |
| Final FPS of tax year not marked as final | HMRC expects submissions into new tax year | Add 'mark final submission' as mandatory step in year-end checklist |
| P60s generated before YTD reconciliation | Employees receive incorrect P60s, manual corrections required | Run YTD reconciliation as a prerequisite step; this can't be skipped |
| P11Ds treated as finance-only | Payroll-processed benefits missed and an automatic £300 penalty per return | Include P11D as a payroll milestone in post-year-end calendar |
| Wrong headcount for gender pay gap snapshot | Incorrect report leading to EHRC risk | Test headcount calculation against statutory definition before snapshot date, not after |
| Rate updates missed on first April payroll | Incorrect payslips, NI deductions, statutory payment rates from day one | Build a pre-April checklist: NI thresholds, student loan rates, SMP/SSP/SPP rates—or use a system that does this automatically |
| Assuming outsourcing transfers the obligation | HMRC writes to you, not your bureau | Agree a submission SLA; verify via HMRC Business Tax Account monthly |
Who is responsible for what?
Statutory payroll reporting involves multiple teams, and in a lot of organisations the handoffs between them are where things go wrong. Here’s how responsibility typically divides—and where the legal accountability sits.
Payroll team
Payroll is the data source everything else depends on. FPS accuracy determines what HMRC expects to receive. Year-to-date figures determine what appears on every P60. Hourly pay and bonus data determine whether the gender pay gap report is correct before HR have even opened the template.
HR team
Your HR team are responsible for:
- Gender pay gap data collection and report submission
- Declaration of compliance
- Starter and leaver processing (which directly affects FPS accuracy)
- Headcount data for gender pay gap snapshot
- Employee records accuracy (NI numbers, addresses, employment status)
If a new starter isn’t set up correctly in HR, they’ll be wrong in payroll—and wrong in every statutory submission that follows.
Finance team
- Annual accounts preparation
- Corporation tax return
- VAT returns
- Liaising with external auditors
Finance depends on payroll figures being clean before year-end close. A payroll correction after the accounts is signed creates an auditor query, not just a payroll one.
If you outsource payroll
The statutory obligations don’t transfer to your payroll bureau. As the employer, you remain legally responsible for every submission made on your behalf. Your Service Level Agreement (SLA) should explicitly cover submission timescales, RTI error notification, data portability if you change provider, and record retention for the full HMRC-required period. Checking your HMRC Business Tax Account monthly is not your bureau’s job—it’s yours. RTI errors appear there before penalty notices are issued, and acting at that stage is significantly cheaper than acting on the letter.
Year-end and reporting checklist
The statutory payroll reporting calendar converges at year-end. The checklist below covers the actions your payroll and HR teams need to complete from March through July. It’s good practice to treat each item as a prerequisite for the next.
Payroll audit trails: the records that protect you
An audit trail is perhaps one of the most important compliance requirements as without it, you’re unable to demonstrate what happened within your business.
HMRC can open a PAYE compliance check at any point. And, when they do, the first thing they request is payroll records. If those records are incomplete, inconsistent, or exist only in the memory of the person who ran payroll three years ago, you’re in a much weaker position than an employer who can produce a clean, timestamped record of every decision.
Here’s what a complete payroll audit trail looks like:
| Record type | What it should capture |
|---|---|
| Payroll run log | Date and time each run was processed, who authorised it, what was included, whether any manual overrides were applied |
| RTI submission log | Date and time of each FPS and EPS submission, HMRC acknowledgement status, any rejection codes received |
| PAYE payment record | Date, amount, and reference for each PAYE payment to HMRC; reconciled against FPS liability |
| Employee change log | Any change to pay rate, tax code, NI category, hours, or employment status—with effective date and authorisation |
| Correction and rerun record | What was corrected, why, in which pay period, and what the net impact was on YTD figures |
| Year-end documents | P60s generated, P11Ds submitted, EPS final indicator, reconciliation sign-off |
| Benefits and expenses log | All benefits in kind provided throughout the year, by employee, with valuation basis documented |
Retention periods
HMRC requires payroll records to be kept for varying periods depending on the type of data: statutory pay records (such as parental and sick pay) must be retained for a minimum of three years, whilst general payroll, tax, and auto-enrolment records must be kept for six years from the end of the tax year they relate to. In practice, the simplest and safest approach is to retain all payroll records for six years.
If HMRC opens a formal investigation rather than a routine compliance check, records can be requested going back further still.
The retention obligation applies regardless of whether payroll is run in-house or outsourced. If your bureau closes, changes system, or loses historical data, the obligation to have those records remains yours.
GDPR doesn’t override the HMRC record retention requirement. Personal payroll data must be kept for as long as HMRC requires it, even if the employee has left. The lawful basis is compliance with a legal obligation—and your data retention policy should document this explicitly.
HMRC’s National Minimum Wage enforcement teams request the same payroll records as a PAYE compliance check: hourly rates, hours worked, deductions, and pay period data. If your records can’t demonstrate NMW compliance for every worker category, including those on irregular hours or piece rates, you’re exposed in any enforcement visit. NMW record-keeping isn’t a separate obligation; it runs through the same audit trail.
What should you do if you've already missed a deadline?
Missing a statutory deadline doesn’t mean the penalty is inevitable or fixed. What you do in the hours and days after matters, let’s look at a few key scenarios:
Submit as soon as possible with a late reporting reason code. HMRC's systems record both the original deadline and the actual submission date. The penalty for a late FPS is based on the number of employees and the number of defaults in the tax year. A single late submission handled promptly is a better outcome than one that drags into the following month so be sure to pay it as soon as possible.
Submit immediately. The £300 per return penalty and the £60 per day continuation penalty both accrue from 6 July, and every day of delay after discovery adds to the liability. Interest on unpaid Class 1A NI will accrue separately.
Publish your report as soon as possible. The EHRC's enforcement process begins with a formal investigation notice—getting the report published before that stage significantly limits your exposure. There is no fixed financial penalty, but the named enforcement action is public.
If you voluntarily identify a PAYE underpayment before HMRC does, voluntary disclosure typically results in a more favourable outcome than HMRC discovering it themselves.
Don’t wait to hear from HMRC before acting. Penalty mitigation almost always depends on demonstrating that you identified the problem and corrected it promptly—not that you responded when contacted.
Payroll software and statutory payroll reporting
Your payroll software is the engine that drives most of your statutory reporting obligations. It needs to do more than calculate pay correctly. And, if it doesn’t, it might be time to look for a new provider.
At a minimum, your payroll system should:
Submit FPS and EPS directly to HMRC via RTI-compliant integration
Generate P60s and P11Ds with accurate year-to-date figures
Hold hourly rate, bonus, and pay quartile data in the format required for gender pay gap calculations
Manage auto-enrolment eligibility and contributions
Maintain a complete audit trail of all submissions and payroll runs as HMRC can request payroll records going back at least three years
Ideally it should also automate FPS submission alongside BACS, flag employees approaching auto-enrolment thresholds, and surface any RTI errors long before they become penalties. If you’re doing any of this manually, you’re carrying unnecessary risk in your statutory reporting process.
Cintra’s payroll and HR software submits FPS and EPS directly to HMRC, generates P60s and P11Ds from live payroll data, and produces gender pay gap calculations for you, all from a single platform. We’re well-versed in exactly how complex statutory reporting can be, so we came up with a solution to alleviate some of the headache. See how it works in a demo with a member of our team today!
Frequently Asked Questions
Your payroll team is responsible for the Full Payment Submission (FPS) on or before every payday, the Employer Payment Summary (EPS) where required, P60s by 31 May, and P11Ds by 6 July. PAYE payments are also due by the 22nd of each tax month.
The FPS reports what you've paid employees and what deductions you've made. It goes to HMRC on or before every payday. The EPS adjusts what HMRC expects to receive from you. It's used to claim Employment Allowance, reclaim statutory payments, or tell HMRC you haven't paid anyone in a given month.
Yes. You need to send an EPS by the 19th of the following tax month to tell HMRC no payments were made. If you don't, HMRC will assume you owe them a PAYE payment.
HMRC applies an automatic penalty of £300 per return, with a further £60 per day for continued failure after 6 July. Interest also accrues on any unpaid Class 1A NI.
Both, in practice. HR typically owns the report submission and narrative, but the underlying data—hourly pay, bonus figures, headcount—comes from payroll. The report is only as accurate as the payroll data it's built on.
No. The legal obligation remains with you as the employer. Your bureau acts as your agent, but if submissions are late or incorrect, HMRC holds you responsible. Always verify submissions through your HMRC Business Tax Account.
HMRC requires you to keep payroll records—including details of pay, tax, NI, and deductions—for at least three years from the end of the tax year they relate to. Employee personal data should be retained in line with your GDPR data retention policy.
Management accounts are produced internally for business decision-making. They have no prescribed format, no external filing, no deadline. Statutory accounts are required by law, prepared to a set standard, filed with Companies House, and must give a true and fair view of the company's financial position.
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