Employers have unsuccessfully tried to submit forms P45/P46 to HMRC for employees who started or left their employment in 2012-13, that is, for a period before they were mandated to report in real time. Rejections from the Revenue have been correctly issued by HMRC.
What actions should be taken
If you are already mandated to submit PAYE in real time and have outstanding P45/P46 forms relating to 2012-13 for your employees, do not submit them.
Instead of submitting P45s you should enter the leaving date on the employee’s 2012-13 P14
If you have already submitted your 2012-13 P35 and P14s without a leaving date then you do not need to take any further action
You should not include the employee on your first Full Payment Submission (FPS) or Employer Alignment Submission (EAS)
The employment will then be automatically ceased at 5 April 2013 following HMRC’s processing of your first FPS or EAS
You should not submit revised P14s
You should include details of the employee in your EAS and/or first FPS and either show a date of starting of 6 April or leave this field blank
If you are not yet mandated to submit PAYE in real time you should continue to submit forms P45/P46 to HMRC up to the date of your mandation.
Further guidance is available from the Albert Goodman Payroll department.