Professional September 2024

COMPLIANCE

In an email to software developers, it has now been confirmed that HM Revenue and Customs’ (HMRC’s) planned changed to RTI hours reporting will be delayed until 2026 at the earliest.

Read more here: https://ow.ly/olJt50T356t

and complete a field inputting a reason why the pay does not relate to hours e.g. payment for a company car. The reportable reasons were added to the regulations as HMRC was told not all employees’ pay relates to paid hours. Modifying the approach Further 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. HMRC has listened and recognise that the requirement to provide employee hours has gone further than intended. HMRC plans to modify the approach to simplify the requirement by reducing the number of reportable descriptions where employee hours are not directly linked to the payment made. HMRC is also exploring soft landing / transition options after industry representatives advised the timescales may be challenging. High-level implementation timeline Please note this timeline was discussed prior to an incoming and now passed general election, so will more than likely change l draft regulations and Explanatory Memoranda published for consultation on 14 March 2024, the the consultation closed on 9 May 2024 l focus on RTI changes at present with initial requirements shared with external group of software developers for review and comment March 2024

l requirements finalised in workshops June 2024 and final technical data specifications and test environments shared with developers October 2024 l industry guidance published September / October 2024 l technical guidance produced alongside final technical specifications October 2024 l go-live – first paid hours data supplied via RTI in returns / system in April 2025. CIPP quick poll The CIPP’s policy and research team polled visitors to the News pages of the website, by asking “Do you feel prepared for the RTI changes?”. The results showed that: l 34.7% of respondents already have the hours worked data l 65.3% of respondents will need to obtain the information to adhere to the new reporting requirements l of the 65.3%, a resounding 38.8% stated that gathering the data will put additional admin burden on payroll professionals. Our response The CIPP responded to the consultation on 3 May 2014, just before the closing date. We did submit our response alongside the Business Application Software Developers Association (BASDA), with a joint covering letter to state both organisations fully support the respective findings set out in each organisation’s response. The policy team chose this method as the CIPP largely represents payroll professionals, the people responsible for gathering the data and processing it through the payroll. BASDA represents payroll software developers, who

will map where the data payroll professionals’ input into the software goes, when it lands with HMRC via RTI submissions. Based on the feedback gathering via the think tank held in May, and the policy team’s own personal concerns, the main proposals made were: l urgent clarification should be provided to communicate why this extra data needs reporting and what it will be used for l consultation with software developers is imperative, as pay elements / components could be mapped with the reportable descriptions as laid out in the draft paragraph 21A (3)(b) of Schedule A l legislative sandboxes should be implemented to ensure this works in practice l implementation should not be considered prior to April 2026 to allow appropriate time for testing and employer process changes to capture the data. What’s next? The general election has been and gone, and with a new Government now in force, could this mean these measures are postponed, brought forward or even abolished altogether? The policy team is hugely invested in the large change these measures could bring for the profession. We will keep you up to date as soon as we have a response or provide further information on this consultation. The one thing we can assure you of is, we have heard your feedback, and we are representing you with a passion. The last thing we will do is allow changes to be implemented which will bring about additional admin burden, without having our say to push back where we can. n

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| Professional in Payroll, Pensions and Reward |

Issue 103 | September 2024

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