As you are aware HMRC pay periods run from 6th of one month until the 5th of the next. HMRC regulations state that any payments made in this period must be accounted for by 19th of the month. This refers to the date of the payment and not the end of the pay period.
Since the introduction of RTI, this has highlighted a particular problem with Monthly payrolls and payment dates. For example, a payroll is actually paid for the calendar month of April on 7th May. Generally this would have been recorded as Month 1. But as the pay date is after May 5th, then according to HMRC rules this is Month 2. Historically with a paper based system and annual reporting this has not previously been a problem as long as your end of year returns balanced.
Now, with RTI and monthly reporting, this scenario will present a problem in that HMRC are accounting for your returns based on the pay date, not the pay period. HMRC have recognised this as a common error and have published a procedure to bring your pay period in line with their calendar. Full details can be found at https://www.gov.uk/aligning-payroll-to-the-correct-tax-period
If any of your payrolls fall within this criteria, (i.e. earnings in a cycle ending on or before the 5th April, but actually paid to the workers afterwards) – then you will need to file a ‘blank’ FPS to bring your periods into line. Clearly, this issue is not restricted to monthly cycles as it will affect any cycle where week 52 is paid after the 5th April.
Within CleanLink the ideal time to include this ‘blank’ period is at the start of the tax year i.e. send a blank period 1 and make your first paid period of the cycle period 2. This will ensure that your staff get their correct tax allowance over the year.