For care agency finance leads in London & the UK

Your Care Agency PAYE Demand: Which Figures Can You Dispute?

An employer PAYE demand that looks terrifying is often an HMRC estimate for a month you simply did not file, not a settled bill. Here is how to tell the disputable part from the part you owe.

Last updated: 13 October 2026
โ˜… 4.8 Google rating
100+ verified reviews
Mon to Sat 10am to 7pm
Qualified accountants

You can dispute a care agency PAYE demand wherever it rests on an HMRC estimate rather than your own figures. The most common disputable item is a specified charge, HMRC's guess for a month you did not file, which is replaced the moment you send the missing Full Payment Submission or Employer Payment Summary. You can also challenge payments allocated to the wrong period, a missing Employment Allowance claim worth up to 10,500 pounds, and statutory pay you never reclaimed. What you cannot argue away is tax you deducted from carers and have not yet paid over.

K By Kris Nick, Account ManagerReviewed and signed off by a senior qualified accountant on the LOYALS team
12 min read

The short answer: a demand is often an estimate, not a settled bill

When a brown envelope lands and your care agency's PAYE account suddenly shows thousands more owing than you expected, the instinct is to assume HMRC has caught a mistake and to find the cash. Hold on. A large part of what employers see on these demands is not a figure HMRC has worked out from your payroll at all. It is a figure HMRC has estimated because, for at least one month, your payroll numbers never reached it.

That matters because an estimate can be disputed by replacing it with the truth. If you did not send a Full Payment Submission for a month, HMRC may raise what it calls a specified charge, an estimate of what it thinks you owe. Send that month's missing submission and the estimate falls away. The parts of the demand built from figures you actually reported are a different matter, and we will be honest about which those are.

This guide is written by LOYALS, a King's Cross firm of accountants and business consultants that runs payroll and PAYE for care agencies across London, so the framing is the decision a finance lead with fifteen or more carers actually faces when the demand arrives, not a tour of the legislation. If you want the cornerstone on how we support providers, our care agency accountants page sets out the wider picture.

Which part of a PAYE demand can you dispute?A care agency facing a PAYE demand first checks whether it is a specified estimated charge. If the month's FPS or EPS was never sent, sending it replaces the estimate with the real figure.Which part of a PAYE demand can you dispute?Start with the kind of charge, 2026 to 2027Is it an estimated charge?NoYesAgreed liabilityCheck paymentsand creditsMonth's FPS or EPS sent?NoYesSend it nowFiling replacesthe estimateReconcileHMRC movesor clears it
How a care agency in the UK works out which part of an HMRC PAYE demand to dispute. Illustration, not client data.

What a specified charge is, and why care agencies trigger them

A specified charge is HMRC's own estimate of what it thinks you owe for a tax month when you have not sent an FPS, or have not sent an EPS to say you paid no one. HMRC is clear that it bases the estimate on your previous PAYE payment and filing history, which is the sting in the tail for a care agency: your busiest month, with a full rota and holiday cover, can be used to estimate a quiet one, so the guess comes out high.

Care agencies trigger these more than most employers, and not through carelessness. Payroll in domiciliary care runs fortnightly or four weekly around travel time, zero hours contracts and a stream of starters and leavers, and the month where every carer's National Insurance is covered by Employment Allowance is exactly the month an office manager forgets to send the nil EPS. HMRC sees no submission, assumes a normal month, and estimates accordingly. The operator level point most guides miss is this: the demand is usually not telling you that you underpaid, it is telling you that one month never arrived.

There is a genuine cost on top of the estimate, though. HMRC charges late filing penalties by headcount, and for an agency with fifteen to forty nine people on the payroll that is 200 pounds a month, rising to 300 pounds at fifty and 400 pounds at two hundred and fifty. Penalty notices come quarterly, and interest is avoided if you pay within 30 days of the notice. A first failure in the tax year is normally let off. None of that changes the main event, which is that the estimated tax itself can be removed.

The demand and the payroll you filedAn illustrative care agency PAYE demand of 17,600 pounds against 11,200 pounds of payroll actually reported on the FPS, leaving 6,400 pounds in dispute.The demand and the payroll you filedIllustrative care agency quarterAmount, thousands of pounds01020ยฃ17.6kHMRC demandยฃ11.2kFiled FPS totalWhat HMRC shows against your records
A care agency PAYE demand against the payroll actually filed, UK illustration. Illustration, not client data.
Want to sense-check what a month of carer wages should really cost in tax and National Insurance before you compare it to the demand? Our free take home pay calculator breaks a wage down into PAYE and NI in seconds. No signup needed.

Reconcile the demand against the payroll you filed

Before you dispute anything you need one page that puts HMRC's figure next to yours, month by month. This is the reconciliation we build for every care client who brings us a demand, and you can build a simple version yourself. Take the demand, split it into the tax months it covers, and against each month write three of your own numbers: what your payroll software says was due on the FPS, what you actually paid to HMRC and when, and any reductions you were entitled to that month, such as Employment Allowance or reclaimed statutory pay.

The gaps tell you everything. A month where HMRC's figure is far above your FPS total, or where there is no FPS at all, is a specified charge to clear. A month where your FPS and the demand agree but you have a bank payment that is not showing is an allocation problem, not a tax problem. A month where the employer National Insurance looks too high is usually a dropped Employment Allowance claim. Work from your payroll records, not from the running balance in your HMRC account, because that balance already has the estimates baked into it.

HMRC runs a service to get help to correct an employer PAYE bill that is worth knowing about. You give it your PAYE reference, your Accounts Office reference, your tax reference and the FPS amounts from your payroll software, and it says explicitly to give the figures as they appear on your payroll software, not from your HMRC business tax account. You submit a separate request for each tax year, and HMRC says it will come back to you by email within 40 working days with the FPS information it holds and a help card. That is useful when you cannot see where the difference is, but it is slower than simply sending the missing month yourself once your reconciliation has found it.

What makes up the demandThe illustrative 17,600 pound demand is built from 11,200 pounds of agreed PAYE, a 6,200 pound specified charge estimate for one unfiled month, and a 200 pound late filing penalty. Only the first figure is supported by the filed FPS.What makes up the demandIllustrative, one unfiled monthRunning total, thousands of pounds01020Supported by your FPSPAYE you agree is dueSpecified charge estimateLate filing penaltyยฃ17,600 demandedThe demandBuild-up of the PAYE demand
What a UK care agency PAYE demand is built from when one month was not filed. Illustration, not client data.
Real LOYALS client outcome We run the finance function for a London domiciliary care provider with around 45 carers: fortnightly payroll including travel time, council and NHS integrated care board invoicing twice a week, remittance reconciliation, credit control and the monthly lender pack. The discipline that keeps that engagement clean, an FPS on or before every payday and an EPS by the 19th of the following month even when there is nothing to pay, is the same discipline that stops a specified charge appearing in the first place. The demands we dispute are nearly always from the months before a provider had that rhythm.

Which figures you can actually dispute

Four items on a care agency demand are genuinely disputable, and it is worth knowing each one by name before you phone HMRC.

Four figures to reconcile firstThe four figures to reconcile on a care agency PAYE demand are a specified charge for an unfiled month, a misallocated payment, unclaimed Employment Allowance of up to 10,500 pounds, and statutory pay reclaimable at 92 percent.Four figures to reconcile firstBefore you pay a care agency PAYE demandSpecifiedEstimatedunfiled monthAllocationPaid, wrongbill or periodAllowanceUp to ยฃ10,500unclaimedStatutory pay92% reclaimmissedIllustration: where a care agency PAYE demand most often goes wrong.
The four figures to reconcile on a care agency PAYE demand in the UK. Illustration, not client data.

The specified charge for an unfiled month

This is the big one and it is the easiest to clear. Sending the missing FPS or EPS for that exact month replaces the estimate with the amount actually due and, HMRC says, supports an appeal against any late filing penalty attached to it. One warning that catches people out: if you send updated year to date figures in a later month's FPS rather than the missing month's own submission, the specified charges stay in place. It has to be the right month's filing.

A payment that is sitting against the wrong bill

Employer PAYE payments carry your 13 character Accounts Office reference, and an early or late payment needs four extra digits on the end that tell HMRC the tax year and the month the money is for. HMRC's guidance on payment reference numbers warns that if you use the wrong reference your payment may be delayed or used to pay a different tax bill you owe. So a month can show as unpaid even though the money left your account weeks ago. Do not pay it twice. Ask the HMRC employer helpline to move the payment to the correct period, with your bank reference and the date ready.

An Employment Allowance claim that dropped off

Employment Allowance can reduce your employer National Insurance by up to 10,500 pounds a year for 2026 to 2027, but it is not automatic. You have to claim it again every tax year by setting the Employment Allowance indicator to yes on an Employer Payment Summary. A new payroll run, a software switch midway through the year or a change of office staff is all it takes for that claim to disappear, after which HMRC's figures show more employer National Insurance owing than you really owe. Reinstating the claim on an EPS for the year brings the demand down by the allowance you were due.

Statutory pay you never reclaimed

Maternity, paternity, adoption and the other statutory payments are largely recoverable. Employers can usually reclaim 92 percent, and a smaller care agency often qualifies for Small Employers' Relief, which lifts the recovery to 109 percent where your Class 1 National Insurance was 45,000 pounds or less in the last complete tax year. You claim it through the EPS. In a workforce that is mostly women, care agencies leave real money on the table here, and an unclaimed reclaim makes the PAYE account look worse than the business actually is.

Staring at a demand and not sure which bucket each figure falls into? Send me the total, the months it covers and whether you think a month went unfiled, and I will tell you honestly how much of it looks disputable before you call HMRC. Message Kris on WhatsApp.

Which parts you usually cannot dispute

Being straight about this saves you time and credibility with HMRC. Where your own FPS shows tax and National Insurance deducted from carers' wages, that money is due and disputing it will not work, because the figure came from you. The same goes for employee deductions you withheld but have not yet paid over: the cash belongs to HMRC and a dispute only delays the inevitable. A late filing penalty that relates to a month you genuinely filed late also tends to stand, unless you have a reasonable excuse or it was your first slip in the year.

Our position, after doing this for care agencies for years, is simple: do not pay a demand that includes a specified charge until you have filed the missing month, because you would be paying an estimate you can erase. The one time we tell a client to pay first is when the disputed amount is small against the risk, for example where HMRC is close to enforcement or has mentioned a security, and protecting the carers' payroll and the agency's bank matters more than holding out on a few hundred pounds. That judgement, how big the disputed figure is against how close HMRC is to acting, is the whole decision.

How to respond, and what to send HMRC

Once your reconciliation is done, the response writes itself. For each disputed month, send the actual filing HMRC is missing rather than a letter describing it.

  1. File the missing month. Send the FPS for a month where carers were paid, or an EPS marked no payment for the period where they were not. This is what replaces the specified charge with the real figure.
  2. Reinstate reductions. If Employment Allowance or statutory pay recovery was missed, put them on an EPS for the year so the employer National Insurance falls to what you actually owe.
  3. Move misallocated payments. Call the employer helpline and ask for any payment sitting against the wrong month or the wrong tax to be reallocated, with your bank reference to hand.
  4. Appeal penalties with the right reference. Where a penalty should not stand, appeal online through the PAYE for employers service and quote the unique ID shown on the penalty notice.
  5. Keep the evidence together. Hold the submission receipts and your reconciliation in one place, because if HMRC queries it you want the whole story on one page.

If your payroll software cannot refile a closed month, or you simply cannot see where the gap is, that is the point to bring in help. Our payroll and PAYE service picks up exactly this: we rebuild the position, file what is missing and deal with HMRC so you are not spending a Saturday on hold.

What this means for you

Treat the demand as a question, not a verdict. Pull the months apart, file the ones that never reached HMRC, move any payment sitting in the wrong place, and put back the Employment Allowance and statutory recovery you were entitled to. In most cases the number that frightened you on the envelope is not the number you owe. Hold your nerve, file first, and pay the corrected figure.

If you would rather not spend an evening reconstructing payroll months, ask our payroll and PAYE team to check the disputed payroll balance and prepare the response for you. LOYALS is a King's Cross firm of accountants and business consultants that runs payroll, PAYE and the wider finance function for care agencies across London, and we would rather clear an estimate than watch a provider pay one.

Useful? Share this with another care provider.

Here is how the three common ways of handling a care agency PAYE demand actually compare:

What you need Pay it / DIY Generic accountant LOYALS specialist
Separates the estimate from what you really owe โœ— You pay the guess โ— If asked โœ“ Built into the review
Refiles the exact missing month, not a catch-up โœ— โ— โœ“ Done properly
Finds dropped Employment Allowance and statutory pay โœ— โ— Extra fee โœ“ Checked every year
Understands domiciliary and live-in care payroll โœ— โœ— Rarely โœ“ Daily
Open Mon to Sat when a demand lands โœ— โœ— Mon to Fri 9 to 5 โœ“ 10am to 7pm Mon to Sat
Fixed monthly fee, no surprise invoices โœ“ โ— Hourly billing common โœ“ Fixed monthly

This is why care providers move from paying demands blind, or from a generic accountant, to a specialist who clears the estimate and keeps the payroll clean afterwards.

What this typically costs at LOYALS

  • Care Payroll and Compliance (payroll, RTI, pensions and HMRC handling): from ยฃ995 a month
  • Care Finance Department (payroll, invoicing, reporting and tax together): ยฃ1,495 to ยฃ2,495 a month
  • One-off demand reconciliation and refiling as part of onboarding: quoted after a 15-minute call

All fees exclude VAT and are fixed for twelve months. Quotes are issued in writing within 24 hours after a 15-minute call, and we do not take on ongoing work below ยฃ500 a month. See full price list.

Care agencies sit in a corner of payroll that most generic accountants rarely touch, between council and integrated care board funding, fortnightly rotas and constant staff churn, which is why a demand that looks alarming is so often just a filing gap. If you want a team that already knows how domiciliary and live-in payroll behaves, our specialist care agency accountants handle the demand and the payroll that caused it together.

Frequently asked questions

Can a care agency dispute an HMRC PAYE demand?+
Yes, where the demand rests on an estimate rather than your own figures. If you did not send a Full Payment Submission for a month, HMRC may raise a specified charge based on your previous PAYE payment and filing history, and that estimate is only replaced when you send the missing FPS or EPS for that month. You can also dispute payments that HMRC has allocated to the wrong period or bill, an Employment Allowance claim that was never applied, and statutory pay you were entitled to reclaim. What you cannot argue away is tax you genuinely deducted from carers and have not yet paid.
What is a specified charge on a care agency PAYE account?+
A specified charge is HMRC's estimate of what it thinks you owe for a month when you have not sent an FPS, or have not sent an EPS to say you paid no one. HMRC bases the estimate on your previous payment and filing history, so a busy month can be used to estimate a quiet one, and the figure can be far higher than your real liability. It does not remove your duty to file. Only sending the missing FPS or EPS for that exact month replaces the estimate with the amount actually due and supports an appeal against any late filing penalty.
We paid HMRC but the care agency PAYE bill still shows the money as owing. Why?+
This is almost always a reference problem. Employer PAYE payments use your 13 character Accounts Office reference, and an early or late payment needs four extra digits on the end that tell HMRC the tax year and month the money is for. If those digits are wrong, HMRC warns the payment may be used to pay a different tax bill you owe, or sit unallocated, so the month you meant to clear still looks unpaid. The fix is not to pay again. Ask the HMRC employer helpline to move the payment to the right period, with your bank reference and date to hand.
How long does HMRC take to correct a care agency PAYE bill?+
If you use HMRC's online service to get help correcting an employer PAYE bill, it says it will contact you by email within 40 working days with the FPS information it holds and a help card to work through. You give the figures as they appear on your payroll software, not from your HMRC business tax account, and you submit a separate request for each tax year in dispute. Sending a missing FPS or EPS yourself is faster where you already know which month is wrong, because the estimate is replaced as soon as the real figures reach HMRC.
Does claiming Employment Allowance reduce a care agency PAYE demand?+
It can, if the allowance was never applied. Employment Allowance can reduce your employer National Insurance by up to 10,500 pounds a year for 2026 to 2027, but you have to claim it again every tax year by setting the Employment Allowance indicator to yes on an EPS. If a new payroll run or a change of software dropped that claim, HMRC's figures will show more employer National Insurance owing than you actually owe. Reinstating the claim on an EPS for the year brings the demand down by the allowance you were entitled to.
Should a care agency pay a disputed PAYE demand while it sorts it out?+
Usually you file first and pay the corrected figure, rather than pay an estimate you believe is wrong. The exception is cash flow risk: if the demand is small against the disruption of HMRC chasing it, or you have had a warning about enforcement, paying the undisputed part while you correct the rest protects the business and the carers who depend on being paid. The judgement turns on how large the disputed figure is and how close HMRC is to enforcement, which is exactly the call a payroll accountant makes with you.
K

Kris Nick, Account Manager

Kris is the account manager and day-to-day point of contact for LOYALS clients, working alongside our team of qualified accountants and experienced finance professionals across care, hospitality and construction. Open Mon to Sat 10am to 7pm.

Message Kris on WhatsApp

Three ways to deal with the demand

Quotes issued in writing within 24 hours, current period discounts and seasonal offers applied at engagement.

Free 15-min call

Talk through the demand and we will tell you honestly how much of it looks disputable.

Check your demandFree 15-min call

See our fees

Fixed monthly pricing for care payroll and the full care finance department, no hourly surprises.

See our feesNo commitment

Demand reconciliation

We rebuild the position, refile the missing months and deal with HMRC for you.

Request the reviewQuoted after a call