Professional September 2024

COMPLIANCE

Consultation update: real time information (RTI)

The CIPP’s policy and research team sheds light on the recent HM Revenue and Customs (HMRC) consultation on collecting hours worked through RTI submissions

I mproving the data HMRC collects has been an ongoing discussion since 2022, and the CIPP policy and research team and our members have been eagerly involved in it. Lora Murphy and Samantha O’Sullivan provided an update on the team’s work so far in a previous issue of Professional . You can read it in your printed issue 97 (February 2024) or view it online here: https:// ow.ly/HmJs50SpW5U. Technical consultation 2024 This year’s consultation was a ‘technical’ one, which means it looked at amending legislation to require businesses to change the information they provide to HMRC through both income tax self- assessment and pay as you earn (PAYE) RTI submissions completed by employers / agents. The consultation launched on 14 March and closed on 9 May 2024. The consultation documents stated that the changes would commence no earlier than the start of the 2025/2026 tax year, with all draft regulations stating a

Why is HMRC collecting this data? As set out in the original consultation in summer 2022, HMRC wants to: l improve tax administration and compliance, helping customers to get their tax right first time l improve the resilience and responsiveness of the tax system to future economic shocks l improve wider government policy making and outcomes through better understanding of the labour market for policy interventions The focus is on making improvements to data that HMRC already collects through RTI. This is to ensure that HMRC minimises the additional burdens for businesses where possible and limit the scale and range of changes required to systems and software. Employee hours draft regulations Replace current requirement to report normal hours worked per week in bands including ‘other’ band for irregular patterns of employment or where payment is not hours related. HMRC will now ask for hours paid to employees in a numerical format e.g. 158 hours paid in that period where that information is held. This will be for: l salaried / contracted employees l employees paid by the hour. The current draft regulations say where that information is not held to report nil hours

commencement date of 6 April 2025. The CIPP’s response was solely focused on the RTI element of the consultation, which is all about employers / agents being required to provide more detailed information on employees’ hours paid via RTI submissions. The Institute’s response can be found within the policy hub pages of the website: https://ow.ly/kMIu50SvfRJ. Gathering your thoughts HMRC was keen to seek views from the CIPP and its members on this consultation. The policy and research team was delighted to facilitate a think tank with our full, fellow and Chartered members on this very topic on 2 May 2024, focusing solely on the RTI element of the consultation. Colin Connor, head of new data policy, strategic data policy at HMRC, covered: What changes are HMRC proposing? Employee hours paid – Changing current requirement to request through RTI data on number of hours paid to employees (rather than hours in bands).

“Feedback since HMRC published draft regulations shows that the attempt to accommodate ambiguous circumstances by asking employers / agents to report reasons for nil hours makes the requirements complex and burdensome”

| Professional in Payroll, Pensions and Reward | September 2024 | Issue 103 16

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