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HMRC internal manual

PAYE Manual

HM Revenue & Customs
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Employer records: set up employer record: pseudo employer records

You may receive a request to set up a ‘Pseudo’ employer record. This will arise from either

  • An Employer Compliance section
  • LBO(EC) Large Business Office (Employer Compliance)


  • National Minimum Wage Unit

A Pseudo employer record is required

  • In order that ECR (Employer Compliance Review) which is the employer compliance part of ECS (Employer Compliance System) can be used to register a review or inspection of an employer where no Employer Business Service (EBS) employer record already existed. A record must be set up on EBS so that the details can be passed from that record to ECS
  • To handle penalties raised from 01/04/2009 on employers who are not paying their employees the National minimum wage (NMW). The penalty charge will be raised in Strategic Accounting Framework Environment (SAFE) and a BROCS record is required to deal with the accounting

When you receive a request you will be asked to take the following action

Day 1

* Set up an EBS employer record (see [PAYE20135]( for more details)

Day 2

* Check Function VIEW BROCS (Format 1) to ensure that the record has been set up on BROCS

If the record has been set up on BROCS, cancel the EBS employer record (see PAYE21015 for more details).

Day 3

* Check Function VIEW BROCS (Format 9) to ensure the cancellation has taken place

Once the cancellation has been confirmed you should advise the Employer Compliance section, LBO (EC) or NMW unit accordingly. You may be asked to reopen the record if, after a compliance review, it transpires that a PAYE scheme is appropriate, otherwise no further action will be necessary.