Late reporting reasons on a Full Payment Submission

A Full Payment Submission is due on or before payday. The late reporting reason field lets an employer tell HMRC why a payment was reported afterwards, using one of seven codes: A, B, C, D, F, G or H. A code only prevents an automatic late filing penalty if the situation genuinely fits it and the FPS is sent within the extended window HMRC allows for that code; otherwise HMRC can still issue a warning and a penalty.

Where does the on or before rule come from?

Regulation 67B of the Income Tax (Pay As You Earn) Regulations 2003 requires a Real Time Information employer to deliver the FPS information on or before making a relevant payment to an employee. Regulation 67C relaxes this for notional payments, such as shares or vouchers: if the employer cannot report on or before the payment, it must report as soon as reasonably practicable and no later than 14 days after the end of the tax month in which the payment is made.

Penalties for late in year returns are in Schedule 55 to the Finance Act 2009. Paragraph 6C imposes no more than one penalty per tax month, excludes failures in an initial period for new employers and excludes the first failure in each tax year. Paragraph 6D allows a further 5% penalty where a return is more than 3 months late. The amounts and appeal process are covered in PAYE late filing and late payment penalties; this page is about the codes.

What are the late reporting reason codes?

HMRC’s RTI data item guide for 2026 to 2027 lists the codes as below, and says a reason should not be given where none of them applies. There is no code E in the current list. The timing column is HMRC’s guidance on payroll information to report.

Code	HMRC description	Typical situation	Report by
A	Notional payment: payment to expat by third party or overseas employer	An overseas employer paying an expatriate employee, or pay delivered through a third party	The 19th of the tax month after the payment
B	Notional payment: employment related security	Shares given at less than market value	Usually the 19th of the tax month of giving the shares; contact HMRC for complex cases
C	Notional payment: other	Other non cash payments, such as vouchers or credit tokens	The 19th of the tax month after the payment
D	Payment subject to Class 1 National Insurance but P11D for tax	An expense or benefit where National Insurance, but not Income Tax, goes through payroll	Within 14 days of the end of the tax month
F	No requirement to keep a deductions working sheet, or impractical to report work done on the day	A new employee without a P45 who is paid less than £96 a week or has worked for less than a week; pay that depends on work done on the day, such as harvest workers paid by amount picked	Within 7 days of paying the employee
G	Reasonable excuse	See below	As soon as possible
H	Correction to earlier submission	Correcting an FPS already sent	The next regular FPS or an additional FPS; by the 19th of the tax month after the original for the correction to show in that month’s bill

When does HMRC accept code G?

G is the general reasonable excuse code, but HMRC’s guidance gives it specific uses:

• Payday on a non banking day. If the usual payday falls on a weekend or bank holiday and you report on the next banking day, enter the regular payment date and code G.
• No employer PAYE reference yet. Report as soon as possible after the reference arrives, using code G.
• Foreign tax paid for the employee. Where calculating PAYE and National Insurance on tax paid abroad on the employee’s behalf takes longer than usual, report as soon as possible and within one month of the usual reporting date, using code G.

HMRC’s employer guide CWG2 for 2026 to 2027 gives a worked case: pay due on Wednesday 5 May 2026 but paid on Thursday 6 May is treated as paid on 5 May, so either the FPS goes in by 5 May or it goes in on 6 May with code G, because a 6 May submission showing a 5 May payment date would otherwise look late.

Outside those cases, G is not a blanket cover for a missed deadline. Whether a reason amounts to a reasonable excuse is judged in the usual way; see HMRC reasonable excuse.

How is code H used?

H is for corrections, not new pay. GOV.UK describes several uses:

• Wrong pay or deductions. An additional FPS showing the difference in the this pay period fields, corrected year to date figures, the same payment date and pay frequency as the original, and code H.
• Wrong payment date. An additional FPS with the correct date and code H, sent by the 19th of the tax month after the original so HMRC applies it to the right month.
• A leaver not reported. HMRC’s data item guide says to report the actual leaving date with nothing in this pay period, the last reported year to date figures, code H and the same payroll ID.
• More than one payment after leaving. GfC22 says to use code H on each payment after leaving beyond the first, with pay in period of 0.00 and adjusted year to date figures, so HMRC can match it to the original.

Does entering a code stop the penalty?

Only if it is the right code and you are within its window. HMRC’s PAYE manual at PAYE5055 says that if the payment date falls outside the late reporting reason period, a late filing notice is issued and a penalty is due. GOV.UK’s guidance is to put the reason on each late FPS; if you do not, or HMRC disagrees with the reason, you may get an online penalty warning message and a penalty.

Separately from the codes, HMRC’s guidance says it will not charge a penalty where all payments on a late FPS are within 3 days of payday, though employers who regularly file within that 3 day margin may be contacted or considered for a penalty. It also will not charge a new employer whose first FPS is within 30 days of paying an employee, or for the first failure in a tax year (except for annual schemes). If a penalty is charged anyway, the appeal grounds HMRC lists include missed correction or easement, which is the natural route where a valid code was used but the penalty still arrived; see appealing a late filing penalty.

How might the codes apply in practice?

Illustration only. A monthly payroll sends its FPS on the 24th for a payday on the 25th. In one month:

• A new starter’s first pay is missed and paid by bank transfer on the 28th. HMRC’s guidance lists an ad hoc payment outside the regular payroll, such as a new starter you are told about after sending the FPS, as one that can go in the next regular FPS or an additional FPS.
• The payroll team then finds that last month’s overtime for two staff was understated. They pay the difference on the 28th and, on or before that day, send an additional FPS with code H.
• The company also gives staff shopping vouchers on the 15th, which were not on the FPS of the 24th. They are reported on a later FPS with code C, by the 19th of the following tax month.

Every other FPS that month goes in on time, so no code is entered on it.

What mistakes come up most often?

• Entering a code on every FPS as a precaution. HMRC’s guidance is that no reason should be given where none applies.
• Using G for routine lateness, such as payroll being run after staff were paid.
• Using H for a genuinely new payment, or a new payment code for what is actually a correction.
• Putting the date the FPS was sent in the payment date field, which makes on time reports look late.
• Assuming a code fixes a report sent after the window for that code has passed.
• Relying on the 3 day margin every month.

The wider reporting rules are in Real Time Information: FPS and EPS explained, and the effect of late and corrected reports on your balance in reconciling your PAYE account with HMRC.

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Related Accountapedia entries

• MTD late submission penalty points
• Payment practices reporting
• HMRC Late Payment Interest Explained
• Appealing a VAT late submission penalty point
• MTD late submission penalty points for agent clients

Sources

• legislation.gov.uk: SI 2003/2682, regulation 67B
• legislation.gov.uk: SI 2003/2682, regulation 67C
• legislation.gov.uk: Act 2009 c. 10, schedule 55
• legislation.gov.uk: Act 2009 c. 10, schedule 55
• GOV.UK: Real time information internet submissions 2026 to 2027 technical spec
• GOV.UK: What payroll information to report to hmrc
• GOV.UK: Fps after payday
• GOV.UK: 2026 to 2027 employer further guide to paye and national insurance con
• GOV.UK: Correcting pay or deductions
• GOV.UK: Correcting your fps or eps

Reviewed by Christine Anderson, Broker, Solar Protect. Last reviewed 24 October 2026. Part of Accountapedia, the Solar Protect guide to UK tax and accounting. This page is general information, not personalised advice.