PAYE in 2026: what every employer should understand right now
Running payroll sounds straightforward until something goes wrong or the rules change. April 2026 brought a cluster of updates that affect how employers manage PAYE — from wage rates to umbrella company liability. Here is our take on what matters and what to watch.
PAYE — Pay As You Earn — is the system HMRC uses to collect Income Tax and National Insurance from employees in real time, rather than waiting for an annual return. If you employ anyone, even just yourself through your own limited company, PAYE is your responsibility. Get it right and it ticks along quietly in the background. Get it wrong and the penalties, interest, and HMRC correspondence stack up quickly.
The 2026 tax year has brought more change to PAYE than most. New wage rates, adjusted employer reliefs, revised rules around expenses, and a significant shift in liability for businesses using umbrella companies all came into force on or around 6 April 2026. In our experience, most employers are aware that something changed — but far fewer have checked whether their payroll setup reflects those changes correctly.
This post walks through the key things that matter right now, and where the common mistakes tend to happen.
How PAYE actually works — a quick recap
At its core, PAYE requires employers to calculate the correct amount of Income Tax and National Insurance for each employee every pay period, deduct it from their gross pay, and send that money to HMRC. The critical part is the reporting side: each time you pay an employee, you must submit a Full Payment Submission (FPS) to HMRC on or before payday. Not after — on or before.
That real-time reporting obligation is what HMRC calls RTI, or Real Time Information. It was introduced back in 2013 and by now most payroll software handles it automatically. But automatic does not mean infallible. One of the most common issues we see is an FPS that records the wrong payment date — the date the report was sent rather than the actual date the employee was paid. HMRC uses the payment date on the FPS to work out your liability, so a mismatch creates an incorrect bill and a reconciliation headache.
Alongside the FPS, there is the Employer Payment Summary (EPS). You use this to tell HMRC if you are claiming statutory payments, taking the Employment Allowance, or have no employees to pay in a given period. If you skip it when you should have sent it, your PAYE account will show an inflated balance that HMRC expects you to pay.
If your bill looks wrong after submission, you have until the 12th of the following tax month to contact HMRC before it becomes harder to resolve informally.
What changed in April 2026
April 2026 was a busy month for payroll. The key changes employers need to have already acted on are:
- National Minimum Wage and National Living Wage: Both rates increased on 1 April 2026. If your payroll was not updated before the first pay run after that date, you may have underpaid affected employees — which is an HMRC compliance issue, not just an HR one.
- Small Employers’ Relief: The compensation rate for statutory payments (such as Statutory Maternity Pay) recovered through payroll increased from 8.5% to 9%. Small employers who qualify should ensure they are claiming the correct rate on their EPS.
- Homeworking expenses: Tax relief for non-reimbursed homeworking expenses was removed from 6 April 2026. This affects employees who had previously claimed the flat-rate deduction on their own tax return. However, if your business formally reimburses employees for homeworking equipment, eye tests, or flu vaccinations, new exemptions mean those reimbursements can now be made free of tax and National Insurance — provided they are properly structured.
- NI refund automation: HMRC is moving to automated processing for National Insurance refund claims involving multiple employees, with refunds going directly to the employer’s PAYE online account rather than by bank transfer. Worth knowing if you manage payroll for a larger team.
None of these changes are obscure. But in the busyness of running a business, it is easy for April to pass without double-checking that your payroll software and processes have kept pace.
A mismatch between the payment date on your FPS and the date you actually paid your staff is one of the most common causes of an unexpected PAYE bill — and one of the easiest to avoid.
Umbrella companies and where liability now sits
If your business uses temporary workers sourced through recruitment agencies, and those workers are paid via umbrella companies, the rules shifted significantly from 6 April 2026. This is worth understanding even if you are not directly running payroll for those workers.
Under the new rules, recruitment agencies are now responsible for accounting for PAYE and Class 1 National Insurance on payments made to workers supplied through umbrella companies. Where there is no agency in the chain — meaning you engage umbrella workers directly — the responsibility falls to you as the end client.
The policy change is a direct response to years of non-compliant umbrella schemes leaving temporary workers with large, unexpected tax bills. HMRC’s stated intention is to close the gap between what those workers should be paying and what was actually being deducted. The practical effect is that more businesses in the supply chain now carry PAYE liability for people they may not formally think of as their employees.
If you use agency workers or have contractors operating through umbrella arrangements, it is worth reviewing those relationships now rather than waiting for HMRC to raise a query. For contractors themselves, the interaction between umbrella company rules and IR35 is increasingly relevant — the two frameworks overlap more than many people realise.
What to do when your PAYE bill looks wrong
It happens more often than employers expect: the bill in your PAYE online account does not match what you thought you owed. Before assuming HMRC has made an error, it is worth working through a short checklist.
First, check whether your most recent FPS and EPS were submitted on time and contain the correct payment date — not the submission date. A one-day difference can cause HMRC’s systems to treat a payment as late or attribute it to the wrong period.
Second, check whether any employees have recently started or left. Incorrect reporting of starters or leavers is a common cause of duplicate records in HMRC’s system, which inflates the bill. HMRC’s guidance notes that these duplicates are often corrected automatically, but not always promptly.
Third, if the bill is still wrong after checking those two areas, contact HMRC directly. If you raise it before the 12th of the following tax month, there is usually a straightforward route to correction. After that point, it becomes a formal amendment process.
If your business is facing cashflow pressure and genuinely cannot pay a PAYE liability on time, a Time to Pay arrangement with HMRC is worth exploring. These allow payment in instalments over an agreed period — sometimes extended to 12 or 15 months depending on the employer’s circumstances. They are not guaranteed, but HMRC will generally engage if you contact them proactively rather than waiting for enforcement action.
Our take
PAYE is one of those areas where small errors compound. A wrong date on an FPS, a missed EPS, a wage rate that was not updated in time — none of these feel significant in isolation, but together they create reconciliation problems, HMRC correspondence, and occasionally penalties. The April 2026 changes have added more moving parts than usual, particularly around umbrella company liability and the homeworking expense rules.
Our view is that payroll is not somewhere to cut corners or leave on autopilot without periodic sense-checks. If your PAYE bill has surprised you recently, or you are not fully clear on how the 2026 changes affect your payroll setup, that is exactly the kind of thing we help clients get on top of. Initial conversations are free and without pressure — get in touch if you would like a second pair of eyes on your payroll.
Common questions about PAYE
What is the deadline for submitting a Full Payment Submission?
You must submit your FPS on or before the date you pay your employees. Submitting late — even by one day — can trigger automatic penalties. Most payroll software will handle this automatically, but it is worth confirming the payment date recorded on each submission matches your actual pay date.
Can I claim Employment Allowance to reduce my PAYE bill?
Most employers with a Class 1 National Insurance liability below £100,000 in the previous tax year can claim Employment Allowance, which reduces their NI bill by up to £10,500 per year. You claim it through your payroll software via the EPS. If you have not claimed it and believe you qualify, it can be backdated within the same tax year.
What happens if I cannot afford to pay my PAYE on time?
Contact HMRC before the payment is late and ask about a Time to Pay arrangement. HMRC can agree a payment plan spread over several months — sometimes longer in genuine hardship cases. Acting proactively is key; HMRC is far more receptive before enforcement action begins than after.
Are the new umbrella company PAYE rules relevant to my business?
If you engage temporary workers through a recruitment agency that uses umbrella companies, yes — you should check who in the chain now holds PAYE liability. From 6 April 2026, that responsibility generally sits with the agency, but if you engage umbrella workers directly without an agency in the chain, the liability falls to you as the end client.
Do the April 2026 homeworking expense changes affect my payroll?
The flat-rate deduction employees could previously claim themselves has been removed. However, if your business formally reimburses employees for qualifying expenses — such as homeworking equipment, eye tests, or flu vaccinations — new exemptions from April 2026 mean those reimbursements can be processed through payroll without attracting tax or National Insurance, provided they are set up correctly.