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No One Got Paid This Month: Do I Need an FPS or EPS?

A practical UK payroll guide for small employers on when to send an FPS, when to send an EPS, and how no-pay months affect PAYE reporting.

No one got paid this month. Maybe the company is seasonal. Maybe payroll was paused. Maybe it is a director-only company and the next salary is not due yet.

This is one of those payroll moments where small employers make avoidable mistakes because they focus on pay periods and forget HMRC works to tax-month reporting rules.

The short version is simple:

if you paid employees, you usually send an FPS;
if you did not pay any employees in a tax month, HMRC says you send an EPS instead of an FPS;
if you will not pay staff for 3 months or more, HMRC also expects the irregular payment pattern indicator to be used on the last FPS before the break.

This guide is general payroll guidance for UK employers. It is not tax or legal advice. If your payroll has already gone quiet for months and HMRC has started estimating what you owe, treat the cleanup as a live compliance issue rather than a normal admin task.

Quick answer

Use this rule of thumb:

Paid employees in the tax month? Send an FPS on or before payday.
Paid no employees in the tax month? Send an EPS instead of an FPS.
Not paying someone for 3 months or more but keeping them on payroll? Use the irregular payment pattern indicator on the last FPS before the gap.

The phrase that matters is tax month, not "calendar month" and not "one week when nobody worked".

Tax month versus pay period

HMRC payroll reporting often goes wrong because employers blur these together.

A tax month runs from the 6th of one month to the 5th of the next.

That matters because:

you can miss a weekly payroll run without automatically needing an EPS;
you only need a no-payment EPS if no employees were paid at all during the whole tax month;
your payroll software timetable and your HMRC reporting obligations are related, but not identical.

What an FPS is for

HMRC says an FPS is used to report employee pay, deductions, and other payroll information on or before payday.

In most normal runs, the FPS is your standard submission. If wages were paid, start from the assumption that an FPS is required.

What an EPS is for

HMRC says an EPS is used in situations where you need to report something that is not covered by the FPS for that tax month, including when no employees were paid.

For the no-pay scenario, the key HMRC rule is:

if you have not paid any employees in a tax month, send an EPS instead of an FPS.

HMRC also says the EPS should be sent by the 19th of the following tax month.

Step by step: deciding what to send

1. Ask whether any employee was paid in the tax month

Do not start with the pay cycle. Start with the tax month.

If anyone was paid between the 6th and the 5th:

you will usually have an FPS obligation connected to that payday;
you would not usually send a "no payment" EPS for that tax month.

If no one was paid in that whole window:

send an EPS instead of an FPS.

2. Check whether staff are still on payroll

A no-pay month does not automatically mean employees have left. HMRC says that if you temporarily stop employing staff for less than a whole tax year, your PAYE scheme continues to run.

That is especially relevant for:

seasonal businesses;
director-only payrolls with infrequent payments;
casual or zero-hours workers who may not be paid every month.

3. Use the irregular payment indicator when the gap is long

HMRC says that if you will not pay staff for 3 months or more, you should put "Yes" in the irregular payment pattern indicator on the last FPS before you stop paying them.

That helps stop HMRC assuming the person has left simply because they were not paid for a while.

4. Send the EPS on time

If no employees were paid in the tax month, do not leave the EPS until the next routine payday. HMRC says the EPS should be sent by the 19th of the following tax month.

5. Keep evidence of why the month was blank

That can be as simple as an internal note:

director not paid this month;
seasonal closure;
no hours worked by casual staff;
payroll paused during transition.

That note helps if HMRC later raises a question or if someone else inherits the payroll file.

Worked examples

Example 1: one missed weekly run

A café runs weekly payroll. No one worked in one particular week, but staff were paid in the same tax month on earlier and later payroll dates.

That is not automatically a no-payment EPS month. Employees were still paid in the tax month.

Example 2: director-only company with no June salary

A sole-director company usually pays the director monthly but skips June entirely.

If no employees are paid in the whole June tax month, the company should send an EPS instead of an FPS for that month.

Example 3: seasonal payroll gap

A business will not pay a casual worker for over 3 months but expects to use them again later in the year.

On the last FPS before the gap, the employer should use the irregular payment pattern indicator and then handle no-pay reporting correctly during the quiet period.

Common mistakes

Using calendar months instead of tax months: HMRC payroll timing does not run on normal month-end logic.
Sending nothing because no one was paid: no pay can still create a reporting obligation.
Forgetting the irregular payment indicator: this matters for long gaps and casual patterns.
Issuing P45s too quickly: a temporary gap in pay does not necessarily mean the employee has left.
Assuming director-only payroll is exempt from upkeep: infrequent pay is exactly where these reporting errors happen.

When this starts to cost time and money

No-pay-month reporting errors often cause:

HMRC estimated charges;
confusion over whether employees are still active;
messy payroll reconciliations later;
unnecessary panic when someone notices a silent PAYE scheme.

That is why the boring monthly review matters, even when the answer is "nobody was paid".

Make quiet payroll months visible

A no-pay month should still produce a decision, a submission where required, and a record. That is what keeps a quiet PAYE scheme from turning into a messy one.

Workmax helps employers keep payroll calendars, pay-run status, employee records, RTI submissions, and audit notes in one workflow, so quiet months do not disappear into inboxes and memory.

If your payroll pattern is irregular, keep this guide beside the 2026/27 UK payroll calendar, the new employer compliance checklist, and your standard month-end review.

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