Furlough scheme ends – what next for employers?

The latest statistics (produced 9 September) suggest that approximately 11.6 million people have been put on furlough, with a staggering £68 billion paid to employers to support them in paying wages to employees during the pandemic.

What should employers be doing now?

Now that the scheme is coming to an end, employers should be aware of their obligations for the end of the scheme and their ongoing requirements.

1. Submit any final claims – on or before 14 October 2021
2. Correct any previous claims – on or before 28 October 2021
3. Identify and disclose to HMRC any grant overclaims – within 90 days on the overclaims arising

What would HMRC expect employers to do?

As a minimum, HMRC would expect all employers to self-review all of their grant claims made under CJRS and correct any errors made. As HMRC will be able to review all claims for the next 5 years, and have recently made investments in a new Task Force to investigate claims, employers should ensure that:

• Any self-review is properly documented;
• All background documentation and calculations are kept, along with the claims made for the required statutory period;
• Grant claims made were based on Government guidance and Treasury Directions in place at the time of the claims; and
• They can demonstrate they have taken reasonable care with their grant claims.

Are there any other issues to consider?

In addition, it is expected that an employer will be faced with a number of queries about their claims from a number of different sources:

• HMRC;
• Investors and financial due diligence advisers;
• Auditors;
• Customers and suppliers; and
• Senior Accounting Officer requirements

How can UNW help?

As an alternative to a self-review, UNW can carry out a full “mock HMRC” review of an employer’s CJRS claims to stress test whether any errors have been made and to ensure that should any queries be made of grant claims in the future they are fully prepared to respond. UNW can help to carry out a full review of submitted claims and ensure that the underlying data is robust, that the positions taken by the employer can be sustained and any judgements taken at the time of each claim can be substantiated with full records.

If you would like more information about this, or any other employment tax related matters, please do not hesitate to get in touch with Lee Muter, Employment Taxes Partner, at leemuter@unw.co.uk or Paul Tucker, Employment Taxes Senior Manager, at paultucker@unw.co.uk.