Late P45 after first pay: HMRC code or starter checklist?
Separate a late P45 from a late starter checklist after first pay. Check HMRC code instructions, payroll history and the next FPS without another start date.
Direct answer
Which record controls when starter documents arrive after first pay?
First check whether HMRC has already sent a tax code: its late-document guidance says to use that code. Without a code from HMRC, a late P45 is used to work out the code and update payroll details. A late starter checklist has a different route: update the declaration but keep the code used in the first FPS until HMRC sends a new one. Do not treat the two documents as interchangeable.
Independent payroll checklist, not tax advice. The source currently displays 2025 tax-year cutoffs; this page does not relabel them as 2026–27 rules. Confirm year-specific pay/tax fields and student-loan corrections with current HMRC guidance or your payroll provider.
Choose the document branch before editing payroll
What arrived?
First check
Audit note
HMRC code notice
Its applicable instruction
Notice and payroll action date
Late P45, no HMRC code
P45 route and relevant tax year
Fields reviewed in payroll software
Late starter checklist, no HMRC code
Declaration update; retain first-FPS code
Answers changed and reason
Example audit note: “First pay processed using the starter declaration. A starter checklist arrived later; no new HMRC code received. Declaration reviewed; existing FPS code retained pending HMRC instruction.” A P45 arriving in the same folder is a separate event to assess, not a reason to silently replace this note.
Checklist controls
Save the code and declaration actually used for the first payment.
Identify whether the new document is a P45, a starter checklist or an HMRC code notice.
Record which branch applies and which payroll fields changed, using the applicable tax year.
Review the next payslip and FPS without entering another start date.
What declaration and tax code were used for first pay.
Shows what has already gone to payroll and HMRC.
New document
Whether the late P45 or checklist changes the employee information.
Prevents overwriting records blindly.
Payroll update
How the payroll software expects the late data to be entered.
Avoids duplicate starter events.
FPS trail
Which FPS has already been submitted and what follows next.
Keeps submissions consistent.
Audit note
Why the record changed and which document triggered it.
Useful for later payroll review.
Timing
First pay changes the context.
After first pay, you are updating a record, not starting from a blank page.
Evidence
Keep the late document.
The P45 or checklist should sit with the payroll change note.
Boundary
Payroll software differs.
Follow HMRC rules and your software workflow for the actual update.
Late P45 workflow
Record what was used for the first pay run.
Compare the late P45 or checklist with existing starter data.
Update payroll records through the correct software route.
Keep an audit note with document date and payroll action.
Check the next payslip and FPS path after the update.
Frequently asked questions
Should the next FPS contain another start date?
No. HMRC says not to enter another start date on the next FPS, including where a start date was not reported before. Follow the late-document route and retain the audit trail.
Source checked 2026-09-18. Independent payroll checklist, not tax advice. The source currently displays 2025 tax-year cutoffs; this page does not relabel them as 2026–27 rules. Confirm year-specific pay/tax fields and student-loan corrections with current HMRC guidance or your payroll provider.
