International Assignments: Online filing now mandatory for employers with 50 employees or more – new penalty regime

1 February 2012 |

UK employers with 50 or more employees should submit the following
notifications online:

  • P45 (Part 1) – details of employee leaving;
  • P45 (Part 3) – new employee details;
  • P46 – details of employees starting work who do not have a P45;
  • P46  (Pen) – new pensions details (introduced on 6 April 2009);
  • P46 (Expat) – details of those seconded to work, either wholly or
    partly, in the UK whilst remaining employed by an overseas employer
    (introduced on 6 April 2009).

Failure to submit these forms online will result in penalties.  In
the first instance, HMRC will start with issuing letters to those
employers with 50 employees or more who are not filing the forms online.
However, from 6 January 2010 penalties are charged if forms are
submitted late or if employers continue to use paper forms when they are
required to file online.  Penalties will range from £100 to a maximum
of £3000, depending on the number of paper forms submitted by an
employer and the first penalties will be issued by HMRC for the quarter
ended 5 April 2010.

It is planned for the on-line filing requirements to be extended to
employers with fewer than 50 employees from 6 April 2011.


Those employers for whom online filing is compulsory should ensure
that they are already compliant.  In any event, in order to avoid
penalties, absolute compliance with online filing will be necessary
before 6 January 2010.

For further information, please contact Guy Abbiss (
or Libs Davies (
on +44 (0) 203 051 5711.

The author


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