RTI reporting of early payments 

Employers may choose to pay regular earnings earlier than usual in December to allow employees access to funds prior to Christmas or due to closures over the festive period.  

The payment date to be reported in the full payment submission (FPS) should be the normal or contractual payment date. This will ensure that the payment is treated as having been paid on the usual payment date for national insurance purposes and that employees’ entitlement to income-based benefits is not impacted by the early payroll run.  

In its October employer bulletin, HMRC has reminded employers of the permanent easement of the usual requirement to submit the FPS on or before the actual payment date for early Christmas payroll runs. The employer can instead submit the FPS on or before the normal or contractual payment date. 

The bulletin gives an example of an actual payment date of 20 December 2024 when the normal or contractual payment date would be 31 December 2024. The payment date on the FPS should be reported as 31 December 2024 and the FPS should be submitted to HMRC on or before that date.   

Auto-enrolment for temporary festive workers  

Some employers may employ additional staff on a temporary basis in order to manage demand over the Christmas period. In its December employer bulletin, HMRC reminds employers of their obligation to consider whether such workers qualify for automatic enrolment into their workplace pension scheme, despite irregular working hours or inconsistent earnings.  

Staff should be automatically enrolled provided they are aged between 22 and state pension and earning over £192 a week or £833 a month. Employers should assess such temporary workers each time they are paid to ensure they do not omit any staff who should be automatically enrolled.