HMRC P46 Form – Complete Guide to the Old P46, Modern Starter Checklist, RTI Rules, and How to Correct Missing Employee Starter Information

Understanding the P46 Form in a Modern HMRC Context

Until 2013, the P46 was one of the most important payroll forms in the UK. Employers completed a P46 whenever a new employee started without a P45, ensuring HMRC applied the correct tax code and PAYE deductions.

Since then, the P46 has been abolished and replaced by the Starter Checklist, submitted through RTI (Real Time Information) using the FPS (Full Payment Submission).

However, people still search for “P46 HMRC” because:

• They want to understand what it used to be

• Their employer or accountant still refers to it

• HMRC requests missing starter information

• Their tax code is wrong

• They started a job without a P45

• They need historic P46 data for old tax years

• Payroll teams need to correct employee starter errors

This guide explains everything you need to know about the P46 form — historic purpose, modern equivalents, how to fix missing starter information, how employees can correct tax codes, and how employers stay compliant under RTI.

Audit Consulting Group created this guide to help both employees and employers understand exactly how the P46 works today.

What Was the HMRC P46 Form?

The P46 was the official HMRC form completed when an employee started a job but did not have a P45 from their previous employer.

The P46 provided HMRC with:

• Employee’s personal details

• Employment start date

• Employment status

• Whether the employee had other jobs

• Student loan status

• The correct tax code to apply

After submitting the P46, HMRC sent the employer a new tax code where required.

Why the P46 Was Abolished

In April 2013, HMRC replaced the P46 with:

• RTI submissions

• FPS (Full Payment Submission)

• Starter Checklist

The Starter Checklist is now used to determine the correct tax code and National Insurance category when an employee joins without a P45.

What Replaced the P46 Form?

The Starter Checklist is the modern equivalent of the P46.

Employers use it to collect all employment starter information, including:

• Full name

• Address

• National Insurance number

• Date of birth

• Employment declaration (A, B, or C)

• Student loan plan

• Postgraduate loan status

• Start date

Link: https://www.gov.uk/guidance/starter-checklist-for-paye

The payroll system then includes these details in the FPS submission, which replaces the P46.

Who Needs to Complete Starter Checklist Information?

Employees must complete starter information if:

• They start a job without a recent P45

• Their previous employer cannot provide a P45

• They have multiple jobs

• They are working for the first time

• They are returning to the UK

• They started self-employment alongside employment

This information allows HMRC to determine the correct tax code.

The Old P46 vs. the Modern Starter Checklist

Understanding the Old P46 Employment Statements (A, B, C)

The P46 contained three statements to determine tax code:

A – First job since 6 April

Employee should be put on:

• 1257L (standard code)

• Or current personal allowance code

B – Has another job or pension

Employee placed on:

• BR, D0, or D1 depending on payroll system

C – This is an additional job

Employee is taxed:

• 100% of earnings at basic rate

• Or higher rate for high earners

These statements still exist today within the Starter Checklist.

What Happens Now If an Employer Does Not Receive a P45?

If no P45 is available, employer must:

1. Ask employee to complete a Starter Checklist

2. Use this information to set the correct tax code

3. Submit it via the FPS on or before first payday

4. Update HMRC automatically

Failure to do this leads to:

• Wrong tax codes

• Emergency tax

• Incorrect NI category

• HMRC compliance issues

How Employees Access P46-Equivalent Information Today

Although P46 forms are no longer used, employees may need P46-equivalent starter information for:

• Tax code corrections

• Backdated refunds

• Evidence for HMRC inquiries

• Employment history requests

• Immigration or visa documentation

• Mortgages or rental applications

Employees can find this information in:

1. HMRC Personal Tax Account

https://www.gov.uk/personal-tax-account

View:

• Employment history

• Tax codes

• PAYE records

• Starter information visible to HMRC

2. Payslips from the first employment month

Usually show:

• Tax codes

• PAYE references

• Deductions applied

3. Employer payroll records

Employers store:

• Starter forms

• FPS submissions

• Employment declarations

How Employers Access Historic P46 Information

Historic P46 information may be needed for:

• HMRC audits

• Employee disputes

• PAYE corrections

• Payroll migration

• Legal cases

• National Insurance gaps

Employers can retrieve P46-equivalent information from:

1. Payroll software archives

Most software stores:

• Starter declarations

• RTI-starter flags

• Employment history

2. The HMRC PAYE for Employers portal

https://www.gov.uk/paye-online

View:

• Tax codes

• Employment start dates

• RTI-adjusted data

3. HMRC requests

You can request a “historic starter information summary” for pre-2013 years.

Common Issues That Happen When No P45 or Starter Checklist Is Used

Employees often face:

• Emergency tax (1257L W1/M1)

• Overpaid PAYE tax

• Incorrect student loan deductions

• Wrong NI category

• Incorrect starter declaration

• HMRC underpayment letters

Employers face:

• PAYE penalties

• RTI non-compliance

• HMRC investigations

• Incorrect payroll reporting

• Employee complaints

Audit Consulting Group helps fix both employee and employer issues.

How to Fix Wrong Tax Code Caused by Missing P46 / Starter Information

Employees can correct their tax code through:

• HMRC Personal Tax Account

• The “Check your tax code” tool

• Employer payroll adjustments

• Calling HMRC (0300 200 3300)

• Submitting missing employment starter details

If starter information was wrong:

• The employer must update their payroll

• HMRC will automatically issue a corrected tax code

Correcting Missing or Incorrect Starter Information (Employers)

1. Submit a corrected FPS

Update:

• Tax code

• Start date

• Starter declaration

• Student loan info

2. Submit an FPS adjustment

For previous pay periods.

3. Submit an EYU (Earlier Year Update)

For older RTI years.

4. Provide missing information to HMRC

HMRC may request:

• Starter Checklist

• Staff ID

• NI number verification

• Right-to-work evidence

Audit Consulting Group can assist with all corrections.

Case Studies

Case Study 1 – Employee on Emergency Tax

Client: Daniel S., Manchester
Issue: No P45 → placed on wrong tax code.
Solution: Starter information corrected, tax code updated in 48 hours.
Outcome: £780 refunded.

Case Study 2 – Employer Audit

Client: Construction Firm, Liverpool
Issue: Missing starter information for 14 workers.
Solution: We reconstructed all starter data and corrected RTI.
Outcome: HMRC accepted records with no penalty.

Case Study 3 – Payroll Migration

Client: Retail Chain, Birmingham
Issue: Needed all historic starter information to move to new software.
Solution: Extracted P46-equivalent history from HMRC + old provider.

Case Study 4 – Student Loan Error

Client: Fiona R., London
Issue: Student loan plan applied incorrectly.
Solution: Updated starter info → HMRC recalculated deductions.

Frequently Asked Questions (FAQ)

Q1: Does the P46 form still exist?

No. It was discontinued in 2013.

Q2: What replaced the P46 form?

The Starter Checklist and RTI FPS submission.

Q3: What happens if an employee has no P45?

Complete a Starter Checklist to determine the correct tax code.

Q4: Can I still access historic P46 information?

Yes — through employer payroll records or HMRC’s archives.

Q5: Why am I on emergency tax?

Usually because no P45 or starter information was provided.

Q6: Do employers get fined for missing starter information?

Yes — HMRC can issue penalties for incorrect RTI reporting.

Q7: Can P46-related information affect tax refunds?

Yes. Missing starter data often leads to overpayments.

Official guidance:
https://www.gov.uk/new-employee