HMRC will accept old style P45 Part 3 forms for starting dates up to 18 May 2009 if they have a leaving date in the previous employment of before 6 April 2009. All P45s issued to employees from 6 April 2009 must be on the new version form. In addition, if a P45 Part 1 is filed online on or after 6 April 2009 for an employee who left before that date, the P45 issued to the employee must be on the new form.
The new form will still have the same Parts 1, 1A, 2 and 3, but will exist in four different formats:
- a four-part P45, printed in colour by HMRC, for use where Part 1 is not filed online
- a substitute four-part P45, printed in colour by the employer, with prior design approval from HMRC
- a three-part P45(Online) comprising Parts 1A, 2 and 3, pre-printed in black and white by HMRC, for use on a non-impact printer where Part 1 is filed online
- a substitute three-part P45(Online), printed in black and white by the employer, without the need for prior HMRC approval as long as it is "an accurate reproduction that matches the content, layout and general appearance of HMRC's P45(Online)".
The substitute P45(Online) must be printed on plain white (not coloured) paper of at least 80 gsm. The printing must be entirely in pure black, without any shading, and must include the HMRC logo. The form may not be printed first and the data printed afterwards in the boxes - both form and data must be printed at the same time. The design specification for the substitute P45(Online) gives precise details of the typeface, type size and type style that must be used and the sizes of the boxes and their positioning.
The three-part form P45(Online) may only be issued after Part 1 has been successfully filed online and validation has been confirmed by HMRC (although a different rule may apply when Part 1 is filed by EDI). It may not be amended after Part 1 has been submitted.
The information recorded on each Part of the P45(Online) is very similar to that shown on the existing P45, but with the addition of the employee's gender and some changes in the order of the boxes. We have, however, queried with HMRC the requirement on the new form to enter the leaver's "taxable pay" at items 7 and 8, i.e. the pay after deducting free pay or adding additional pay, as this conflicts with the Regulations. The existing form asks for "total pay", not "total taxable pay".
