Specified charges in insolvency — insolvency practitioner bulletin 13 (2024)
Published 23 July 2025
© Crown copyright 2025
This publication is licensed under the terms of the Open Government Licence v3.0 except where otherwise stated. To view this licence, visit nationalarchives.gov.uk/doc/open-government-licence/version/3 or write to the Information Policy Team, The National Archives, Kew, London TW9 4DU, or email: psi@nationalarchives.gov.uk.
Where we have identified any third party copyright information you will need to obtain permission from the copyright holders concerned.
This publication is available at https://www.gov.uk/government/publications/insolvency-practitioner-bulletin-13-2024-specified-charges-in-insolvency/specified-charges-in-insolvency-insolvency-practitioner-bulletin-13-2024
Background
When an employer or contractor has not submitted their PAYE Real Time Information (RTI) or Construction Industry Scheme (CIS) return for a pay period, HMRC systems raise an estimated charge.
This is called a specified charge, and it estimates the tax and National Insurance contribution which we consider might have been included in the RTI or CIS return, had it been sent.
The correct amount due will replace our estimate on the customer record as and when the return is submitted for that period.
New process for insolvency cases
Insolvency practitioners have not previously had a suitable mechanism to allow them to file pre-appointment RTI or CIS returns easily. However, HMRC is introducing such a mechanism now.
Insolvency practitioners are not obliged to file returns for pre-appointment periods. They should use their professional judgement whether to accept the specified charge or to replace it by filing the relevant return.
Insolvency practitioners appointed in formal insolvencies of employers or contractors will soon start to receive a notice that will advise of this option to file pre-appointment returns.
Further questions
If you have any questions about this insolvency bulletin, direct them to R3 or your representative group who will take them forward with HMRC.