InsightsDirector Pay

HMRC Starter Checklist: Onboard a New Employee Without a P45

By Noman Abassi27 May 20266 min read
New employee completing an HMRC starter checklist form on their first day

When a new employee starts without a P45, you ask them to complete an HMRC starter checklist so you can set the correct tax code and run payroll properly. The checklist captures their employment circumstances, chiefly whether this is their only job, and points you to one of three statements (A, B or C) that determines the code. You keep the completed form; you do not send it to HMRC.

That is the whole job in a sentence. The detail below covers when you need it, how each statement works, and the tax codes that follow.

What Is the HMRC Starter Checklist?

The starter checklist is the form a new employee fills in when they cannot give you a P45. It replaced the old P46 and gives you everything Real Time Information (RTI) payroll needs to report a new starter to HMRC on or before their first payday.

You need it whenever a new joiner:

  • has lost their P45, or never received one;
  • left their previous job before 6 April 2026 (the P45 is stale);
  • is starting their first ever job;
  • has a second job or a pension running alongside this one.

Your new starter completes it; you transfer the details into your payroll software. Keep the record for the current tax year plus the next three, it is part of your statutory payroll documentation.

The Three Starter Checklist Statements: A, B and C

Coins and a small plant, financial growth

The heart of the form is a single choice. The employee ticks the statement that matches their situation, and that drives the tax code you operate from their first pay.

StatementWhen the employee picks itTax code (2026/27)Basis
AThis is their first job since 6 April, and they have had no other income (no JSA, ESA, state or other pension)1257LCumulative
BThis is now their only job, but they have had another job, or taxable benefit, earlier this tax year1257L W1/M1Non-cumulative (emergency)
CThey have another job or receive a pension as well as this oneBRAll pay taxed at basic rate

The 1257L code reflects the standard tax-free personal allowance of £12,570 for 2026/27. On a cumulative basis (Statement A) the allowance is spread evenly across the year. On a Week 1 / Month 1 basis (Statement B) each pay period is taxed in isolation, so the employee may slightly over- or under-pay until HMRC issues a settled code.

BR (Statement C) applies the basic 20% rate to every pound, on the assumption the personal allowance is already used up by the other job or pension.

What If the Employee Ticks Nothing, or You Have No Checklist at All?

If you have neither a P45 nor a completed checklist by the first payday, default to tax code 0T on a Week 1 / Month 1 basis. That gives no personal allowance and can over-tax the employee, so chase the checklist promptly and correct the code once you have it. A late P45 received afterwards should be actioned in your next Full Payment Submission.

Where Do You Get the Starter Checklist Form?

The form is free from HMRC. You can complete it online and print the result, or download the PDF and have the employee fill it in by hand. The authoritative version, updated for 2026/27, lives on the official guidance page: Starter checklist if you're starting a new job (GOV.UK).

This form does not go to HMRC. The data reaches them automatically through your RTI submission. Posting the paper form in is a common, and unnecessary, mistake.

How the Checklist Feeds Your Payroll Reporting

Once you have the statement and the employee's details (name, date of birth, address, National Insurance number, start date and student loan position), you enter them into your payroll software before the first FPS. The software then reports the new starter to HMRC in real time.

Two fields catch people out:

  • Student loan and postgraduate loan plans. The checklist asks which plan type applies. Get this wrong and deductions start on the wrong threshold, or not at all.
  • The "starter declaration" letter. Your software stores the A/B/C choice as a single letter. Mis-keying B as A is the usual cause of an unexpected under-payment that surfaces months later.

If running this in-house feels fiddly, our bookkeeping and payroll services handle new-starter onboarding, RTI submissions and tax-code corrections, so the first payslip is right first time.

Common Starter Checklist Mistakes to Avoid

  • Using last year's P45. If the employee left their old job before 6 April 2026, ignore the P45 and use the checklist instead.
  • Letting the emergency code drift. A Statement B starter on 1257L W1/M1 should move to a cumulative code once HMRC catches up, check for the P6 coding notice.
  • Forgetting the second-job case. A genuine second job needs Statement C (BR), not Statement A, however small the earnings.
  • Binning the form. Keep it for the current year plus three. HMRC can ask to see it during a compliance check.

Frequently Asked Questions

Do I send the starter checklist to HMRC?

No. The completed checklist stays in your records. The new-starter information reaches HMRC automatically through your Real Time Information payroll submission, so you only need to keep the form on file, for the current tax year and the following three.

What tax code do I use if a new employee has no P45 and no checklist?

Operate tax code 0T on a Week 1 / Month 1 basis until you receive the checklist or a P45. This applies no personal allowance and may over-tax the employee, so collect the checklist quickly and correct the code as soon as you can.

Is the starter checklist the same as a P46?

Effectively, yes. The starter checklist replaced the old P46 form. It serves the same purpose, telling the employer how to tax a new starter who has no P45, but is now completed by the employee and kept on file rather than posted to HMRC.

Which statement should an employee pick if it is their only job this year?

Statement A, if they have had no other income since 6 April. If they had another job or a taxable benefit earlier in the same tax year, Statement B is correct, which puts them on an emergency (Week 1 / Month 1) code until HMRC settles their position.

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Get Your Onboarding Right From Day One

A mis-set tax code on a first payslip means an awkward conversation and a correction later, easily avoided with two minutes of attention to the right statement. If you would rather hand payroll, RTI and new-starter onboarding to someone who does it every week, get in touch with Zmartly and we will keep your team paid correctly from their first day.

Free · 30 minutes · No obligation

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Thirty minutes with an ACCA-qualified accountant. Most owners uncover £1,000-£3,000 in annual savings on the first call. If we are not the right fit, you walk away with a free tax review on the house.

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