What Is RTI and When Must You Submit FPS and EPS to HMRC?

## The short answer

Real Time Information (RTI) is the UK system that requires employers to report payroll details to HMRC every time they pay employees, rather than once a year. The two core submissions are the Full Payment Submission (FPS), which must reach HMRC **on or before** the date you pay your staff, and the Employer Payment Summary (EPS), used to tell HMRC about adjustments such as statutory pay you are reclaiming or a period with no payments. Miss the FPS deadline without a valid reason and you risk a late-filing penalty.

If you only remember one rule: send the FPS on or before payday, every payday, without exception.

## What the FPS actually reports

The Full Payment Submission is the workhorse of RTI. Each one tells HMRC, for every employee paid in that run:

- Gross pay and the pay frequency

- Income tax deducted under PAYE

- Employee and employer National Insurance contributions

- Pension contributions and student loan deductions

- Starter and leaver information, plus year-to-date totals

Because the FPS carries year-to-date figures, each submission effectively restates the running position. That is why an error in one period can usually be corrected in the next FPS rather than requiring a separate amendment.

## When the EPS is needed

The Employer Payment Summary is not sent every period. You use it when there is something the FPS cannot communicate, including:

- Recovering statutory payments such as maternity, paternity, adoption or shared parental pay

- Claiming the Employment Allowance against employer National Insurance

- Reporting Construction Industry Scheme deductions suffered

- Telling HMRC that you paid no employees at all in a tax month (a "nil" EPS)

The EPS generally needs to reach HMRC by the 19th of the month following the tax month it relates to, so that your liability is reduced before the payment becomes due.

## Understanding the tax month and payment dates

UK payroll runs on tax months that begin on the 6th and end on the 5th. Your PAYE liability for a tax month is normally payable to HMRC by the 22nd if you pay electronically (the 19th for postal payments). The EPS deadline of the 19th sits deliberately ahead of that so adjustments land before the bill is calculated.

This calendar trips up many new employers because it does not align with calendar months. A payday on, say, the 28th falls into a different tax month than a payday on the 2nd, and getting that wrong shifts figures into the wrong reporting period.

## Late filing: what triggers a penalty

HMRC operates a late-filing penalty regime for RTI. The key points to keep in mind:

- Penalties are based on the number of employees, charged per PAYE scheme per month an FPS is late

- There is usually no penalty for the first default in a tax year

- HMRC allows a short period of grace after payday before treating an FPS as late

- A valid "late reporting reason" code can prevent a penalty where the late submission is justified

The practical defence is simple: build payroll so the FPS is generated and sent as part of the same process that produces payslips, not as a separate manual afterthought.

## Common mistakes that cause RTI problems

- **Sending the FPS after payday.** Even a day late counts. Schedule it earlier in the run.

- **Forgetting the nil EPS.** If you pay nobody in a month, HMRC still expects to hear from you, or it may estimate a liability.

- **Duplicate employee records.** Re-onboarding a returning employee with a new payroll ID can create a duplicate, inflating reported pay and NI.

- **Wrong starter declarations.** The starter checklist statement drives the tax code; the wrong choice causes over- or under-deduction.

- **Mismatched year-to-date figures** after switching software mid-year, which HMRC reads as inconsistent reporting.

## How software should help

Good payroll software removes the timing risk by tying RTI submissions to the pay run itself, validating data before it leaves your system, and surfacing the EPS only in the periods it is actually required. neart.ai builds enterprise-grade products in the HR and payroll space, and the design principle that matters here is the same one HMRC enforces: reporting should be an automatic by-product of paying people correctly, not a manual task that depends on someone remembering a date.

When evaluating any system, check that it: confirms successful HMRC acceptance (not just submission), stores the response for your records, handles corrections through the next FPS cleanly, and prompts for the EPS when statutory recovery or Employment Allowance applies.

## Practical takeaway

Treat the FPS as a hard, recurring deadline locked to every payday, and the EPS as a monthly check: do I have statutory pay to recover, an allowance to claim, or a nil month to declare? Automate both inside your pay run, confirm HMRC has accepted each submission, and keep the acceptance records. Get the rhythm right and RTI becomes routine rather than a recurring source of penalties.