Furlough Submission Deadlines and Delay Excuses
Following increased rates of coronavirus infections and the imposition of both the tiered restriction system and a new lockdown for England, the government has announced that the Coronavirus Job Retention Scheme, also known as furlough, is being extended to 31st March 2021.
It was originally planned to finish at the end of October and claims deadlines had been scheduled to take that into account. Now, with the extension of the scheme, a new series of claims deadlines has been announced.
However, the new and markedly shorter deadlines have caused consternation for businesses who intend to make claims under the new system as they now have just fourteen days to do so each month. It is felt by many that it will be very difficult, if not impossible to make accurate applications within that narrow time limit.
When can a claim be made?
A claim can be made before, during or after payroll is processed, as long as the claim is submitted by the relevant deadline. However, a claim cannot be submitted more than 14 days before the claim period end date.
When a business makes a claim, they do not have to wait till the end date of the claim period for a previous claim before making their next claim. They can make their claim more than 14 days in advance of the pay date (for example, if the employee being claimed for is paid in arrears).
If a claim is not finished in one session, it can be saved as a draft, but it must be completed within seven days of starting it.
Claims from 1st November 2020 must be submitted by 11.59pm 14 calendar days after the month to which the claim relates.
If this time falls on the weekend or a bank holiday then claims should be submitted on the next working day.
Deadlines for claims till March 2021
30th November 2020 is the last day employers can submit or change claims for periods ending on or before 31st October 2020.
Late claims excuses
If a business claims after the deadline, then HMRC may accept the claim if a reasonable excuse can be advanced and the claimant submitted a claim without delay after the excuse no longer applied.
A reasonable excuse may include:
The claimant’s partner or another close relative died shortly before the claim deadline.
The claimant had an unexpected stay in hospital that prevented them dealing with the claim.
The claimant had a serious or life-threatening illness, including Coronavirus-related illnesses, which prevented them from making the claim, and there was no-one else who could have done it for them.
The claimant was in self-isolation and thereby unable to make the claim, and there was no-one else who could have done it for them.
The claimant had a computer or software failure just before or while they were preparing the online claim.
There were issues with HMRC online services which prevented the claim from being submitted.
A fire, flood or theft prevented the claim being submitted.
Unforeseeable postal delays prevented the claim being submitted.
Delays related to the claimant’s disability have prevented them from submitting the claim.
An error by HMRC prevented the claim being made.
It is important to note that HMRC will not consider reasonable excuses in advance of a claim deadline.
rradar Tax Advisor Caroline Lamyman says “The new system brings in significantly shorter deadlines and this could well cause problems for both employers and payroll agents. In some cases, the deadlines may actually be too short if payments for the month are made in arrears the following month once all the relevant timesheets have been received and actioned.
“Some payrolls cross a month end and moving the deadline for claims forward could mean completing furlough submissions will be challenging – for some employers, significantly so. Many believe that a 30-day deadline is more reasonable and will allow employers to complete their claims without pressure, which could lead to mistakes being made. The proposed 14-day deadline may mean that hard-pressed employers, keen to avoid missing the cut-off will try to estimate their claim and this could lead to complications that have to be rectified retrospectively.”
Caroline Lamyman, Tax Advisor at rradar