Keeping Payroll Merry: Early December Pay Dates and RTI Reporting

The festive season is just round the corner!  HMRC is reminding employers of an important payroll rule if you plan to pay staff earlier than usual in December, you must follow the correct Real Time Information (RTI) reporting rules.

What You Need to Do

If you’re spreading a little Christmas cheer by paying employees early, remember the key point is you must report their normal or contractual pay day on your Full Payment Submission (FPS), NOT the actual early pay date.

Example:

If you pay staff on 19^th December 2025, but their usual pay day is 31^st December 2025, you should report 31^st December as the pay date.  The FPS must be submitted on or before 31^st December 2025, even if you pay early.

Why This Matters

Reporting the correct contractual date helps protect employees’ eligibility for income-based benefits such as Universal Credit.  An early payment could impact the employees’ current and future entitlements.

Further Guidance

HMRC has published helpful guidance for employers:

October 2025 issue of the Employer Bulletin – GOV.UK– reminders about the permanent RTI easement during Christmas.

Final Reminder

Paying early in December is fine but always submit your RTI using the normal pay day, not the early one.  This small step protects employees who receive Universal Credit and keeps payroll compliant with HMRC guidance.

The information in this blog provides only an overview of HMRC guidance and legislation in force at the date of publication and no action should be taken without consulting the detailed HMRC guidance and legislation or seeking professional advice.  Therefore no responsibility for loss occasioned by any person acting or refraining from action as a result of the material contained in this blog can be accepted by the firm.