The government have updated the guidance on Wednesday 15th April 2020 in relation to which employees and RTI data requirements.
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.
This a change from the prior guidance which may have indicated applying to all employed on by 28th February to place an employment and RTI filing obligation deadline of 19th March 2020.
To qualify and to protect against fraudulent claims, individuals originally had to be employed on February 28 2020.
Following a review of the delivery system and to ensure the scheme helps as many people as possible, new guidance published 15th April 2020 has confirmed the eligibility date has been extended to March 19 2020– the day before the scheme was announced.
Now employers can claim for furloughed employees that were employed and on their PAYE payroll on or before 19 March 2020. This means that the employee must have been notified to HMRC through an RTI submission in respect of that employee on or before 19 March 2020.
This change makes the scheme more generous while keeping the substantial fraud risks under control and is expected to benefit over 200,000 employees.
So employees employed before the former 28th February announced date but not paid until after 19th March are not covered by the CJRS in relation to government funding.
PAYadvice.UK 15/4/2020 updated 16/4/2020
So are we to understand that staff employed from say 1st Feb who are paid 1 month in arrears as they are casual will not qualify but contracted colleagues will?
Those employed by 28th February who are on an RTI submission by 19th March are covered for the grant, else there is no grant coverage.
How about submitting a late FPS with them on it, but with zero pay?
Although elements of this are welcome, it still negatively impacts employees who were in employment before the former 28th February date who missed the payroll cutoff for February and would normally have had their first pay date at the end of March. The change ignores employment dates and moves the RTI file contents. So weekly up to the wire are in, yet Monthly that fall after are out! Be interesting to understand whether submission point is independent of payment date on file.