8 | YOUR CIPP
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The CIPP’s Advisory Service team provides answers
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Reissuing digital P45s Q: When employees leave, we supply digital P45s. Previous guidance indicates that a lost paper P45 cannot be reissued, but what’s the current guidance around reissuing a P45 that’s been provided digitally? A: The rule against issuing duplicate P45s was established before digital systems and real time information. It was intended to ensure that employees couldn’t claim their tax-free personal allowance more than once from different employers, and to prevent the generation of subsequent P45s for payments made post-termination.
Although the specific reasoning isn’t officially documented, current guidance still states that no duplicates are permitted: https://ow.ly/yEJq50YmkeM. Recouping training costs and national minimum wage (NMW) implications Q: If an employee leaves our business and is required to repay training costs, do we need to consider NMW rules before taking a deduction from their final pay? A: If the training was in connection with the employment, was a requirement of that employment or was enforced by the company, the deduction for training costs would reduce pay for the purposes of NMW. However, if the training was completed voluntarily for the individual’s own personal development, wasn’t connected or required as part of the employment and the company paid the deductions to a third-party (such as a training provider), the deduction for training costs wouldn’t reduce pay for the purposes of NMW. Meet the team
Further information can be found under the training costs paragraph of ‘Deductions or payments for the employer’s own use and benefit’, here: https://ow.ly/ JZNa50Ymkra, and examples can be accessed here: https://ow.ly/oEL550YmkuV.
Real living wage rate uplift timelines Q: We’re an accredited living wage employer. If we don’t action the new real living wage rates until 1 May 2026, do they need to be backdated to when the announcement of the new rates was made? When do the new real living wage rates need to be implemented by accredited living wage employers?
Can we issue duplicate P45s when they’ve been provided digitally?
Chevonne Wild MCIPPdip Payroll Advisory Team Leader
Marie Bennett MCIPPdip Payroll Advisory Officer
Monica Blajut MCIPPdip Payroll Advisory Officer
Leanne Sinclair MCIPPdip Payroll Advisory Officer
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