What a Full Payment Submission is and how to file it

Around 30.2 million people are paid through the UK's Pay As You Earn system, and every one of those payments is reported to HMRC in real time ^[1]. The document that carries that report is the Full Payment Submission, and it must reach HMRC on or before the day each employee is paid ^[2]. Miss it, and the penalty starts at £100 a month ^[3].

The Full Payment Submission, almost always shortened to FPS, is the backbone of Real Time Information (RTI). Before RTI, employers told HMRC about pay and deductions once a year. Since RTI, they report every pay run as it happens, which means every figure is visible to HMRC the moment payroll runs rather than months later.

This article explains what the FPS reports, exactly when it is due, the situations in which HMRC allows it to arrive after payday, what a late or missing submission costs, and how an employer corrects a mistake once the submission has gone. The mechanics apply to every UK employer running PAYE, from a single-director company to a payroll bureau filing for hundreds of clients.

Key takeaways

• The FPS reports each employee's pay, deductions and year-to-date totals to HMRC on or before payday ^[2].
• National Insurance information must be included once an employee is paid £96 or more a week, the secondary threshold for the 2026-27 tax year ^[4].
• HMRC allows a late FPS in a fixed set of situations, each flagged with a late-reporting reason code ^[5].
• Late-filing penalties run from £100 to £400 a month depending on headcount, with a three-day easement and a first-failure waiver ^[3].
• Errors are fixed by sending a corrected FPS with updated year-to-date figures, not by editing the original ^[6].

What a Full Payment Submission is

What the FPS reports

The FPS is an electronic return sent from payroll software to HMRC that lists every payment made to employees in a pay run and every deduction taken from it ^[2]. It covers everyone on the payroll, including workers paid less than £96 a week, because HMRC uses the submission to keep each employee's tax record current ^[4].

Each FPS carries a defined set of data for every employee. The core fields are the employee's name, National Insurance number, date of birth, address and tax code, the pay for the period, and the running year-to-date totals for pay, tax, National Insurance and student loan deductions ^[4]. Alongside the individual data, the submission identifies the employer through the PAYE reference and the Accounts Office reference, so HMRC can match the return to the right scheme ^[2].

National Insurance detail is only required once earnings reach the threshold. For the 2026-27 tax year the secondary threshold, the point at which employer National Insurance becomes due, is £96 a week, £417 a month or £5,000 a year ^[4]. Understanding how those contributions build is easier with a grounding in how employer National Insurance works, because the FPS is where those figures are declared to HMRC.

Where the FPS sits in the PAYE cycle

The PAYE tax month runs from the 6th of one month to the 5th of the next, and the FPS is the first of two possible returns inside that cycle ^[7]. The FPS goes on or before payday. The second return, the Employer Payment Summary, is only sent when the employer needs to reclaim or adjust an amount ^[8].

Once the FPS is filed, HMRC builds the amount the employer owes for the month. From the 10th of the following month the employer can view what is due in the online PAYE account, and payment must reach HMRC by the 22nd if paying electronically, or the 19th if paying by post ^[7]. The table below sets out the rhythm of a standard month.

A business running this cycle by hand carries real risk, because a single missed submission cascades into a specified charge and a penalty. HMRC-recognised payroll software for SMEs files the FPS automatically as part of the pay run, which removes the manual step where errors usually begin.

When to send the FPS

The on-or-before rule

The governing rule is simple to state and strict in practice: the FPS must reach HMRC on or before the date the employee is paid ^[2]. The submission must always show the employee's normal or contractual payday, even when the actual payment lands earlier or later, for example when a payday falls on a weekend or bank holiday and the money is moved forward ^[5].

An employer can send the FPS ahead of payday, which helps when the payroll team is away, but sending too early creates its own problem. If any figure changes between the early submission and payday, for instance an employee leaves or a tax code updates, a corrected FPS has to follow ^[4]. There is also a hard stop at the year boundary: reports for a new tax year must not be sent before March ^[2].

The situations where a late FPS is allowed

HMRC accepts that some payments cannot be reported on or before payday, and it publishes a defined list of circumstances in which a late FPS carries no penalty, provided the correct reason code is entered ^[5]. Every late submission must state its reason. Without a valid code, HMRC treats the return as simply late ^[3].

The reason codes narrow a broad principle into specific cases. The table below lists the codes an employer is most likely to use.

Code E, a temporary relaxation for micro-employers, was withdrawn from 6 April 2016 and is no longer available ^[3]. For a genuinely unpredictable payment, such as an employee whose pay is calculated on the day for piece work, the relevant code lets the employer file within seven days without penalty ^[9]. A payroll bureau managing many clients has to apply these codes correctly across every scheme it files for, which is why bureau tooling needs to support the full code set rather than the common two or three.

What happens when an FPS is late

The penalty structure

Late FPS penalties are charged per PAYE scheme per tax month, and the amount depends on the number of employees in the scheme ^[3]. An employer running more than one scheme can be charged separately for each. The scale is fixed and published, so the exposure is easy to quantify.

Beyond the fixed penalty, a missing FPS can trigger a specified charge, which is HMRC's own estimate of what it believes the employer owes, built from previous filing and payment history ^[3]. A specified charge does not remove the obligation to file. Only sending the missing FPS for that month replaces the estimate with the real figure and supports any appeal ^[3]. Repeated late filing can also affect employees directly, because their Universal Credit award draws on the RTI data the employer submits ^[10].

The easements that stop a penalty

HMRC applies several easements that prevent a penalty even when an FPS technically arrives after payday. The most useful is the three-day easement: a penalty is not charged if all payments on the FPS are within three days of payday, though employers who habitually file inside that window can still be contacted or considered for a penalty ^[3].

Two further easements protect new and occasional filers. A new employer is not penalised for a first FPS sent within 30 days of paying an employee, and every employer gets one waived failure per tax year, so the first late report in the year carries no penalty ^[3]. The annual-scheme exception is narrower, and businesses registered as an annual scheme do not receive the first-failure waiver ^[3]. An employer that disagrees with a penalty can appeal on defined grounds, including ill health, an IT difficulty, or having no payments to report ^[3].

How to correct a Full Payment Submission

Fixing an error in the current tax year

The RTI model does not allow an employer to delete or overwrite an FPS once it is sent. Corrections work forward, through the year-to-date totals. To fix most mistakes, the employer sends an updated FPS carrying the corrected year-to-date figures, which HMRC uses to adjust the record ^[6].

The method depends on when the error is caught. If it is spotted in the same pay period, the next regular FPS carries the right figures and no separate action is needed. If an employee was paid the wrong amount, or a leaver was missed, an additional FPS can be sent before the next regular one ^[6]. When an employer needs to flag that a submission itself is a correction to an earlier one, the appropriate late-reporting reason code signals that to HMRC ^[5]. Getting deductions such as student loan repayments right the first time reduces how often a correction FPS is needed at all.

The final FPS of the tax year

The last FPS of the year does more work than a normal monthly return. It carries an end-of-year indicator that tells HMRC the year is complete, and it is the trigger for producing each employee's P60 ^[2]. Getting that final submission right matters, because errors carried into year-end are harder to unwind once the P60s are issued.

If a mistake surfaces after the final FPS has gone, the employer sends a further FPS with the corrected year-to-date figures for the affected employees ^[6]. This is also the point at which any additional full payment for the year, such as a late bonus, must be reported so the annual totals reconcile ^[6].

Special FPS situations

New starters and leavers

A new starter changes the FPS. The first submission that includes a new employee must carry their starter information, so HMRC can set up the record and issue the correct tax code ^[4]. Where the employee has a P45 from a previous job, the figures from it feed into that first FPS. Where they do not, a starter declaration provides the detail instead ^[4].

A leaver is handled the same way, on the FPS rather than through a separate form. The employer marks the leaving date on the final FPS that includes the employee, and that submission generates the P45 ^[11]. The FPS also carries optional flags for events such as an employee reaching State Pension age or becoming a director, which can affect how deductions are calculated ^[4]. Whether payroll runs weekly or monthly, an on-demand payslip service still has to align each payslip with the pay reported on the FPS.

Additional and annual schemes

Not every employer files twelve monthly FPS returns. A business where all staff are paid once a year in the same tax month can register as an annual scheme, which needs only one FPS and one EPS for the year ^[12]. Registration is arranged with the HMRC employer helpline using the 13-character Accounts Office reference ^[12].

Changing pay frequency also touches the FPS. An employer that moves staff from weekly to monthly pay should tell HMRC, because a gap in expected submissions can prompt a non-filing notice ^[12]. For platforms and developers embedding payroll into their own products, an HMRC-recognised payroll API handles the FPS scheduling, the reason codes and the year-to-date arithmetic behind a single call, so the host product does not have to build RTI compliance from scratch.

Conclusion

The Full Payment Submission is not a form an employer fills in occasionally. It is a live, per-pay-run report that keeps every employee's tax record and every business's PAYE liability current, which is exactly why HMRC treats lateness and inaccuracy so firmly. The reason codes, the easements and the correction rules all exist because real payroll is messy, and the system is built to absorb that mess as long as the employer signals what happened.

The practical lesson is that FPS discipline is less about knowing every rule and more about removing the manual steps where the rules get broken. When the submission is generated automatically from the pay run, filed on or before payday, and corrected through year-to-date figures without hand-editing, the penalty scale becomes something an employer reads about rather than pays.

Frequently asked questions

Do employers still need to send an FPS if no one was paid that month?

No. In a tax month where no employee is paid, the employer should not send an FPS at all. Instead an Employer Payment Summary is sent to tell HMRC that no payments were made ^[8]. Sending nothing risks HMRC estimating a charge and issuing a penalty for a missing submission ^[3].

What is the difference between an FPS and an EPS?

The FPS reports the pay and deductions for each employee and is sent on or before every payday ^[2]. The EPS is a separate, less frequent return used to reclaim or reduce what is owed, for example to recover statutory pay or claim the Employment Allowance, or to report a month with no payments ^[8]. Most employers send an FPS every month and an EPS only when a reduction applies.

Can an FPS be sent after payday without a penalty?

Yes, in defined circumstances. HMRC publishes a list of situations, each with a reason code, in which a late FPS carries no penalty, such as an unpredictable payment calculated on the day ^[5]. There is also a three-day easement and a first-failure waiver each tax year ^[3]. Outside those cases, a late FPS without a valid reason code can attract a penalty.

How long does an employer have before HMRC closes a PAYE scheme?

If a new employer sends no reports for an extended period, HMRC can close the PAYE scheme. Employers who know in advance that no one will be paid for a stretch should record a period of inactivity on an EPS to avoid non-filing notices ^[8]. Filing an FPS or EPS at the right point keeps the scheme open and the record accurate ^[10].