What is a Full Payment Submission?
A Full Payment Submission (FPS) is the central Real Time Information (RTI) filing that every UK employer must send to HMRC each time they pay employees. It replaced the old annual end-of-year return (P35) when RTI was introduced in April 2013.
The FPS tells HMRC:
- Which employees were paid and how much
- What Income Tax and National Insurance was deducted
- Any student loan deductions made
- Running year-to-date totals for each employee
- Any new starters or leavers in the period
HMRC uses FPS data to reconcile against what you pay over each month and to update individual employees' tax records in real time.
When Must You Submit an FPS?
The FPS must be submitted on or before the date you pay your employees. This is the fundamental RTI rule. There is a minor exception: if you pay more frequently than weekly, HMRC allows a single FPS covering all payments made in a 7-day period, sent by the last payment date of that period.
A late FPS — one filed after payday — will trigger an automatic penalty notice. HMRC's in-year penalty regime applies to FPS submissions filed more than three days late (with a one-month grace period for first-time offenders in a new tax year).
For bureau operators, the practical rule is: never approve a pay run until the payroll software is ready to submit the FPS immediately.
What Information Goes in an FPS?
Employer information
- PAYE reference — your employer PAYE reference (format: 123/AB456)
- Accounts Office reference — 13-character reference for HMRC payments
- Tax year and tax period — the period the payment relates to
Per-employee data
- Full name, date of birth, address, and National Insurance number
- Works number or payroll ID
- Tax code and basis (cumulative or week 1/month 1)
- NI category letter (A, B, C, H, J, M, Z — see NI rates guide)
- Gross pay this period and year to date
- Tax deducted this period and year to date
- Employee and employer NI contributions (broken down into the NI bands: LEL to PT, PT to UEL, above UEL)
- Student loan deductions (Plan 1, Plan 2, Plan 4, Postgraduate loan)
- Statutory payments (SSP, SMP, SPP, SAP, ShPP, SPBP)
- Starter/leaver indicator and relevant dates
Step-by-Step: Submitting an FPS
- Run payroll — calculate gross pay, apply tax codes, compute Income Tax and NI for each employee.
- Review the payslips — check for anomalies before approving. Unusual tax codes, unexpected pay changes, or NI category mismatches are worth investigating before the submission leaves your system.
- Approve the pay run — once satisfied, approve. This locks the payroll figures.
- Submit the FPS — your payroll software packages the approved data into the HMRC XML schema and transmits it to the Government Gateway over TLS. The submission receives a correlation ID.
- Check the response — HMRC acknowledges receipt and returns a status. Wait for ACKNOWLEDGED before treating the submission as complete.
FPS Response Statuses Explained
| Status | Meaning | What to do |
|---|---|---|
| PENDING | Submission sent, awaiting HMRC acknowledgement | Wait — usually resolves within minutes |
| ACKNOWLEDGED | HMRC accepted the submission | Nothing — submission is complete |
| REJECTED | HMRC rejected the submission with error codes | Fix the errors and resubmit (see below) |
Common FPS Rejection Reasons and Fixes
1089 — NINO not found or incorrect
The National Insurance number in the submission doesn't match HMRC's records. Check the employee's NI number against their payslip or HMRC letter. If the employee doesn't yet have an NI number, use the temporary reference TN followed by date of birth and gender (e.g. TN 01 01 1990 M) until the real number is issued.
1090 — Tax code invalid
The tax code submitted is not a valid HMRC format. Common causes: a tax code that was manually keyed incorrectly, or an emergency code that wasn't updated after HMRC issued a P6. Correct the tax code and resubmit.
1098 — NI contribution discrepancy
The NI contributions in the FPS don't reconcile with the NI category and gross pay figures. Usually caused by a rounding error in manual payroll — most payroll software handles this automatically.
Authentication failure
The Government Gateway credentials (username and password associated with the PAYE scheme) are incorrect or expired. Re-enter the credentials in your payroll software's HMRC connection settings and resubmit.
Late FPS: Penalties and What to Do
HMRC issues automatic in-year late filing penalties under the Pay As You Earn (Late Filing Penalty) regime. Penalty amounts depend on the number of employees in the scheme:
- 1–9 employees: £100 per month of default
- 10–49 employees: £200 per month
- 50–249 employees: £300 per month
- 250+ employees: £400 per month
If you receive a late filing penalty but believe you had a reasonable excuse (system outage, HMRC Gateway failure), you can appeal via HMRC Online Services or by writing to HMRC's Penalty Appeals team. Include the submission correlation ID as evidence that the attempt was made.
If you simply forgot to submit, file as soon as possible. HMRC will still issue a penalty, but the amount is typically lower than if you continue not to file.
FPS for New Starters and Leavers
You don't need a separate submission for new starters or leavers — they're included in the regular FPS for that pay period.
- New starter: Include the Starter Declaration (A, B, or C from the Starter Checklist) on their first FPS payment. This replaces the old P46 process.
- Leaver: Set the leaver indicator and date of leaving on their final FPS. The employee's P45 is generated from this data.