Furlough Cut-Off Date Relaxation and Reclaim Procedure Update

15 Apr 2020

1)  It has just been announced that the cut-off date for employees has been extended to 19th March, 2020 - see below. This is very welcome BUT note the requirement that an RTI payment submission must also have been made by then which will preclude most monthly paid employees who were taken on 1st March, 2020 or later. It will though help most weekly paid employees in the same position.

Employees you can claim for

You can only claim for furloughed employees that were on your PAYE payroll on or before 19 March 2020 and which were notified to HMRC on an RTI submission on or before 19 March 2020.This means an RTI submission notifying payment in respect of that employee to HMRC must have been made on or before 19 March 2020. Employees that were employed as of 28 February 2020 and on payroll (i.e. notified to HMRC on an RTI submission on or before 28 February) and were made redundant or stopped working for the employer after that and prior to 19 March 2020, can also qualify for the scheme if the employer re-employs them and puts them on furlough.

2) The procedure for making the reclaim is continuing to evolve, see below our understanding of the position as it stands. It is important to note that things may well change further several times before 20th April, 2020 even though that is only a few days away now.

The guidance below is general so it covers those who run their own payrolls also.

We will be contacting our own payroll clients where we think there might be an issue in advance. However there are bound to be glitches in the system so patience all round will be required.

If you have any specific queries please direct them to your usual director / manager contact where possible rather than the payroll team in order to prevent overload.

The JRS Portal

The Government has announced that they are ready to launch the online portal on 20th April.

The Access rules

To access the portal and to make the claim it is of paramount importance that:

  • That a PAYE payroll scheme was created and set up on or before 28th February 2020
  • A UK bank account exists
  • That the business has enrolled for PAYE online. If nobody has done this yet it is imperative to get the ball rolling. The link below will help: https://www.gov.uk/paye-online/enrol

Be warned that the activation code could take up to ten days in which to arrive and it might be sent to the business address which may possibly still be in lockdown.

Who can make the claim?

Only the business and agents authorised to act on behalf of the client for PAYE matters will be able to make the claim. That agent could be the accountant or another Third Party.

Please note that file only agents, which could include some Payroll Bureaus, will not be able to access the service due to data protection reasons.

The fear

The concern is that there will be thousands of businesses who will have furloughed, have a UK bank account and have an operational PAYE scheme set up but not online. This is could therefore delay processing through their claim.

Important steps to take

  1. Check to see if each business is set up online for PAYE and is able to make the claim either through their own access or through the appointed agent which could be the accountant or a Third Party. 
  2. If the scheme is not registered online do so as per the link above as soon as possible. Keep an eye out for the activation code (including at business premises).
  3. Who is going to make the claim?

a). If it is the business will the Third Party processing the payroll need to provide the client with each of the furloughed employees national insurance numbers, the furloughed salary, employers national insurance and employers pension contributions relevant to make the claim.

b). If it is the Third Party who has access to the portal will they want confirmation/ permission from the client before pressing the button on such a claim? Will the client want to know and agree the amount of the claim before the button is pressed?

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