Compliance guidance, not a new tax rule
Published on 22 October 2026, GfC22 is addressed to employers, payroll providers and advisers. HMRC describes Real Time Information errors that can create differences between payroll records and its PAYE account, including missing, duplicate or incorrect submissions and incorrectly handled payroll events. The document is administrative guidance. It must be used alongside the existing rules and does not itself create a new liability or a new appeal route. [GFC22]
The legal starting point remains regulation 67B of the Income Tax (PAYE) Regulations 2003. Subject to the exceptions in the legislation, an RTI employer must deliver the Schedule A1 information no later than the relevant payment, using an approved method of electronic communication. The obligation therefore concerns the data actually reported. Payroll configuration and control of the file sent to HMRC are part of tax risk management, rather than matters that can always be repaired by a month-end accounting entry. [REG67B] [SCHEDULEA1]
Employee identifiers and employment events are tax data
GfC22 emphasises the consistency of identity and employment data. An incorrect National Insurance number, a payroll identifier replaced without the appropriate indicator, a wrong starting or leaving date, or the unjustified restart of an employee record can create a second record at HMRC. Payroll may be correct internally while the administrative account is wrong. Before resubmitting anything, the employer should compare the employee, payroll identifier, year-to-date figures and dates reported in every FPS. [GFC22] [SCHEDULEA1]
The same care is required when software changes, payroll is transferred or a business is reorganised. HMRC distinguishes PAYE scheme mergers from successions. Regulation 102 addresses ordinary succession where the employee remains employed in the same business within the meaning of the provision and allocates obligations between the former and new employers. The classification cannot be selected merely for technical convenience: the wrong route can produce duplicate employments, inconsistent cumulative figures and disputed charges. [GFC22] [REG102]
Use the correction route that matches the error and tax year
Regulation 67E is not a general power to rewrite any historical return. It applies to the inaccuracies and omissions within its defined scope. Where a covered error is identified during the tax year, the employer must provide the correct information in the next return for that year. If it has not been corrected before 20 April following the end of the year, a specific return must be made as soon as reasonably practicable, with the prescribed information and through an approved method of electronic communication. [REG67E]
HMRC’s operational guidance explains the mechanics. For wrong pay or deductions in the current year, it directs the employer to update year-to-date figures in the next regular FPS. For tax years from 6 April 2020 to 5 April 2026, it says to submit another FPS with the correct cumulative figures. The employer must still check the year, error type and fields being changed: mechanically repeating both period and cumulative amounts may create another duplicate. [CORRECTFPS] [REG67E]
A correction prepared in payroll software is not enough. It must actually be transmitted, accepted and reconciled with HMRC’s records. In Siva v HMRC, the First-tier Tribunal noted that the employer said the matter had been fixed “on the computer”, while HMRC’s records showed no amendment. The decision is fact-specific and non-binding, but it illustrates a decisive operational point: retain the technical acknowledgement, submitted file, sending time and the result of the subsequent reconciliation. [SIVA] [REG67E]
A disputed charge does not disappear when it is challenged
When a difference arises, the employer should first reconcile its payroll journal, submitted FPS and EPS files, acknowledgements and HMRC PAYE account. GfC22 says HMRC will usually pause recovery of the disputed amount while it investigates. That administrative practice does not remove the need to pay PAYE that is not disputed. The guide warns that failing to pay that part increases the risk of interest and penalties, but it does not itself define a penalty rate, statutory trigger or available defence. [GFC22]
The dispute must then be classified legally. In Siva, the tribunal distinguished collection of an amount arising from the employer’s own FPS from an appealable HMRC decision. It held that the reported amount remained due unless and until the returns were actually amended. This First-tier Tribunal decision does not establish that every RTI dispute lacks a remedy. Its practical lesson is that the disputed act, legal basis and available procedure must be identified before a strategy is chosen. [SIVA]
FieldworkHub, by contrast, concerned a substantive determination under regulation 80. The First-tier Tribunal reduced it to nil because HMRC had not established the regulatory obligation supporting the figures claimed. That decision is also non-binding and factually different. It demonstrates that the existence of a figure in HMRC’s system does not, by itself, prove the statutory basis for a determination. It does not invalidate every FPS-generated charge or replace the correction route in regulation 67E. [FIELDWORKHUB] [SIVA] [REG67E]
Build the evidence file before approaching HMRC
For each period, the useful file contains payroll journals before and after correction, the FPS and EPS files actually transmitted, acceptance acknowledgements, employee identifiers, year-to-date figures, joining and leaving dates, and the HMRC PAYE account statement. A migration or reorganisation also requires a timeline, old and new references, the classification adopted and any HMRC instructions. Those records distinguish a data error, duplicate record, payment allocation problem and genuine dispute over the law. [GFC22] [SCHEDULEA1] [REG102]
A disciplined sequence is to freeze the extracts, locate the difference by employee and period, verify the applicable correction rule, submit one controlled correction and then reconcile the result. If the employer cannot correct the issue directly, GfC22 points to HMRC’s service for correcting an employer PAYE bill. This remains general guidance: a determination, collection notice or litigation deadline requires separate procedural analysis and should not be treated as a routine payroll incident. [GFC22] [REG67E] [FIELDWORKHUB]