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HMRC internal manual

Compliance Operational Guidance

Supporting Guidance: employer compliance: guidance by subject: open year inaccuracies: new schemes (previously pseudo schemes)

Where you are undertaking a compliance check

  • for a new scheme which has been set up by RIS

then every year for which returns are due (up to and including 2012-13) but still outstanding

  • is an open year.

From 6 April 2013, every tax period where a Full Payment Submission (FPS) is due but still outstanding

  • is an open tax period.

Where an inaccuracy is discovered you should

  • instruct the employer to register for RTI (if this has not already been done)
  • explain to the employer how to prepare the necessary current year records; completed FPS which must include details of

    • all employees
    • year to date details of all payments and deductions, see COG904220 
  • recover the PAYE, NIC and interest for earlier years where P35s/P14s have not been submitted, via Class 6 settlement
  • instruct the employer to submit an Earlier Year Update (EYU) for RTI years (see COG904240) and
  • consider penalties in accordance with COG914045 and COG914050 (for post April 2009 see CH80000).


If the scheme was opened and closed immediately to facilitate RIS you should

  • arrange for the scheme to be reopened.