Securing Compliance with Real Time Information – Late Filing and Late Payment Penalties – LITRG response

Published on 12 September 2012

LITRG welcomes the opportunity to respond to the consultation document 'Securing compliance with Real Time Information - late filing and late payment penalties'.

The issue of RTI penalties being a raiser of revenue is a major concern and not an unjustified worry.

RTI penalties must be proportionate and their framework simple. The regime must give employers time to get used to the obligations of RTI and this is likely to take a minimum of two years during which we would recommend a ‘light touch’ approach to the application of penalties.

Employers who are allowed to file on paper under statute must be given special consideration and we require more information on how HMRC propose to operate manual penalties for these employers.

We are concerned that there are genuinely digitally excluded employers, who, despite help from the ‘Assisted Digital package’, might still fail to get online. There clearly is no point in penalising people for failure to do the impossible and any such action by HMRC will result in reputational damage.

To see the full LITRG response please use the link below
The LITRG response 
The consultation document


Contact: Joanne Walker (please use form at

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