Guide
Prepare for an HMRC PAYE compliance check
What to expect and how to prepare when HMRC reviews your PAYE records.
Prepare for a PAYE compliance check by gathering payroll records for the last 3 years. Cooperate fully with HMRC officers and be ready to explain any discrepancies. You may face penalties up to 100% of unpaid tax if errors are found.
- Keep PAYE records for minimum 3 years after tax year ends
- You typically get 7-14 days notice before a check
- Common checks: employee status, expenses, benefits, tax codes
- Penalties can reach 100% of unpaid tax plus interest
- You have 30 days to appeal any penalty notice
- Gather payroll records, RTI submissions, P45/P60 forms
- Check your own records for errors before HMRC visits
- Nominate one staff member to liaise with HMRC
- Accountant or tax adviser can represent you
- Take notes during the check of all questions asked
HMRC carries out compliance checks to ensure employers are operating PAYE correctly. This guide explains what triggers a check, what to expect, and how to prepare.
Why HMRC might check your PAYE
- Random selection: Routine checks on a sample of employers
- Risk indicators: Late submissions, frequent corrections, sector patterns
- Third-party information: Tips or information from other sources
- Discrepancies: Differences between RTI and other returns
- New employer: First-year employers sometimes checked
- Notice period
- Usually 7-14 days written notice before visit
- Record retention required
- Minimum 3 years after end of tax year
- Penalties for non-compliance
- Up to 100% of unpaid tax, plus interest
- Appeal rights
- 30 days to appeal any penalty notice
Records HMRC may ask for
- Payroll records: Employee details, pay, deductions, tax codes
- RTI submissions: FPS and EPS submissions for reviewed periods
- P45s and P60s: Employee forms issued
- Starter checklists: Forms completed by new employees
- Payment records: Evidence of payments to HMRC
- Employment contracts: To verify employment status
- Expense claims: Receipts and approval records
- Benefits records: P11D working papers
Common areas of scrutiny
- Employment status: Are "self-employed" workers actually employees?
- Expenses: Are reimbursements genuinely business expenses?
- Benefits in kind: Are all taxable benefits reported on P11D?
- Tax codes: Are correct codes being applied?
- NI categories: Are correct categories used (especially for directors)?
- Statutory payments: Are eligibility checks being done properly?
Preparing for a compliance check
- Gather records early: Do not wait until the visit day
- Review your submissions: Check RTI submissions for the review period
- Identify any errors: Better to disclose voluntarily than be found out
- Prepare workspace: HMRC officer needs desk and privacy
- Nominate a contact: One person to liaise with the officer
- Consider representation: Accountant or tax adviser can attend
During the check
- Be cooperative: Obstruction can lead to penalties
- Answer honestly: Do not guess - say if you need to check
- Take notes: Record questions asked and answers given
- Request time: You can ask for time to find documents
- Ask questions: Clarify anything you do not understand
After the check
HMRC will write to you with their findings:
- No issues: Letter confirming compliance
- Minor issues: Advice on improving processes
- Underpaid tax: Assessment for additional tax plus interest
- Penalties: Separate penalty notice if errors were careless or deliberate