Debt and return pursuit: PAYE: e-payment default: e-payment compliance - multiple monthly payments
A proportion of employers send in several payments for the same month. There is a problem if the employer makes one payment on time and the others before the 28th (date of the default run). For example if the full amount due for a particular month was £25000, the payment pattern may not incur an automatic default if
- £10000 was paid on the 17th
- £7500 paid on the 23rd and
- £7500 paid on the 26th.
Because of the “up to date rules” applied by BROCS an employer can pay less than the full amount, but the IDMS work item will still be treated as paid in full, closed, but no default notice issued.
Review list and criteria for entry
From April 2005 BROCS monthly lists were introduced to identify large employers who make several payments for the same month. This list, which is issued to coincide with the default notice run, will report large employers who have made additional monthly payments for the month between the 23rd and the date the list is generated.
Dealing with the review list
Criteria for review
You should review the list but restrict your activities to those employers that are making
- small payments on time
- large balancing payments after the payment date.
A large balancing payment is one that is 50% or more of the expected monthly payment.
Actioning the list
For those items identified for review
- telephone the employer and ask to speak to the Finance Director and
- the reason given for the default.
- whether “reasonable excuse” applies.
If you are satisfied with
- the reason for default and
- this is the first occasion that you have educated this employer,
- warn that future payments that are made late or not in full will incur default
- educate, or re-educate where necessary, the employer of their companies responsibility around electronic payment
- request that all areas of their business responsible for facilitating PAYE/NIC payments to HMRC (payroll and finance directors, company directors) be made aware of the companies responsibility in respect of electronic payment.
Where an employer has been warned before and reasonable excuse does not apply
- advise they are in default and you will be issuing default notice(s).
- amend the Default Notice Count on BROCS using BROCS function AME
- issue default notice(s) manually
- note IDMS Action History.