The New Starter Checklist Explained for Employers

The starter checklist replaced the old P46 form, and it is the document an employer reaches for whenever a new hire arrives without a P45 ^[16]. Get the checklist wrong and the employee is likely to be put on an emergency tax code, taxed on each pay period in isolation as though that figure were repeated across the whole year ^[21].

Onboarding a worker into PAYE is a small process with real consequences. The information an employer gathers in the first week decides the tax code, the starter declaration and whether student loan deductions begin, and every one of those choices flows into the first Real Time Information submission HMRC receives about that person ^[15].

This guide explains what the starter checklist is, when it is used instead of a P45, how the three starter declarations work, what happens when the wrong one is picked, and how the collected information reaches HMRC on the first Full Payment Submission. It is written for employers setting up their own payroll and for the accountants who onboard staff on their behalf.

Key takeaways

• The starter checklist replaced the P46 and is used when a new employee has no usable P45.
• It sets two things: the starter declaration (A, B or C) and the starting tax code.
• Declaration A gives the standard cumulative code, B gives a week 1 or month 1 basis, and C gives the basic rate code with no personal allowance.
• When the employer cannot establish the right statement, declaration B is the prudent default.
• The completed checklist goes to the employer, never to HMRC, and its details are reported on the first Full Payment Submission.
• If the plan is unknown, student loan deductions start on Plan 5, the plan with the lowest threshold.

What the starter checklist is

The starter checklist is the HMRC form a new employee completes so the employer can work out the correct tax code for the first payday when there is no P45 to rely on ^[16]. It gathers the employee's personal details, their employment situation since the start of the tax year, and their student loan position ^[15].

One point is often misunderstood. The employee completes the checklist and hands it to the employer, and the form is not sent to HMRC ^[16]. The employer keeps it in the payroll records and uses the answers to configure the worker in payroll software. HMRC only sees the resulting figures when they appear on the first submission ^[19].

When to use the checklist instead of a P45

An employer should always ask a new starter for a P45 first, because it carries the year-to-date pay and tax that keeps the employee's code accurate ^[14]. The starter checklist steps in when no P45 is available, or when the P45 is too old to use for the current tax year ^[16].

The table below shows which route applies.

An employer that wants the wider onboarding picture, including the P45 mechanics, can read how the HMRC PAYE Online service delivers the codes and notices that follow a new starter.

The one-off payment exception

There is a narrow case where the full checklist is not needed. When an employer pays a worker once and knows there will be no further payments, the worker is taxed on code 0T on a non-cumulative basis, the pay frequency is reported as irregular, and no start or leaving date is entered ^[15]. The employer gives the person a payslip or a letter confirming the payment rather than a P45 ^[14]. This keeps a genuine single payment out of the normal starter process, but the exception is easy to misapply, so an employer should use it only when it is certain no second payment will follow.

An employer should also keep the collected information for the current tax year and the three years after it, because HMRC can ask to see how a code was determined ^[14]. Good record-keeping at onboarding is what lets an employer answer a query months later without reconstructing the decision from memory.

The three starter declarations

The heart of the checklist is the starter declaration. The employee picks the statement that describes their situation, and that choice maps to a tax code and a calculation basis ^[16]. There are three declarations, and the difference between them is significant for take-home pay in the first months.

Why the declaration matters

Declaration A is the most generous to the employee because it applies the full personal allowance cumulatively, so tax is smoothed across the year ^[11]. Declaration C is the most restrictive: everything the employee earns in the job is taxed at 20% with no allowance at all, which is correct for a genuine second job but painful if it is applied by mistake ^[16].

Declaration B sits in the middle. It applies the standard code but on a non-cumulative week 1 or month 1 basis, so each pay period is taxed in isolation rather than against the running total for the year ^[21]. When an employer genuinely cannot tell which statement fits, declaration B is the safe default, because it avoids the harshness of C while HMRC settles the correct position ^[15].

What happens when the declaration is wrong

Picking the wrong declaration is one of the most common causes of a new employee landing on an emergency tax code and either overpaying or underpaying in the early months ^[21]. An emergency code taxes the worker on what they are paid in that single week or month, as if that amount were repeated every period of the year, which distorts the first payslips ^[21].

Emergency tax codes at a glance

The standard code 1257L only becomes an emergency code when it carries a week 1, month 1 or X marker after it ^[22]. The table below sets out the codes an employer will meet when onboarding.

Under Real Time Information, an incorrect emergency code is usually corrected within a few weeks once HMRC receives the first submissions and issues a revised code through the employer's online account ^[22]. The employer applies the new code from its effective date, and any overpaid tax is refunded through the payroll. Running payroll on an HMRC-recognised payroll platform means the revised code is imported and applied automatically rather than keyed by hand.

Student loans at the point of hire

The checklist also captures whether the new employee is repaying a student loan or postgraduate loan, and an employer must ask about both because a worker can have one of each ^[18]. The employer starts deductions when the checklist indicates a loan, when a P45 says deductions should continue, or when HMRC sends a start notice and the employee earns above the plan threshold ^[18].

The unknown-plan rule

If the employee cannot say which plan applies, the employer should ask them to sign in to their student loan repayment account and check, and if they still cannot confirm it, the employer uses Plan 5 in the payroll software until a start notice (SL1) arrives ^[18]. Plan 5 is the default because it carries the lowest threshold, which makes the deduction the safest option from HMRC's point of view ^[20].

A postgraduate loan can run alongside a main student loan, so both may be deducted in the same period ^[20]. An employer must never stop a deduction because the employee asks, since only a stop notice (SL2 or PGL2) from HMRC authorises that ^[18]. A payroll bureau handling many clients relies on the software to apply the right plan and threshold across every scheme it manages.

Reporting the new starter to HMRC

The checklist does not go to HMRC, so the way the tax authority learns about the new employee is the first Full Payment Submission that includes them ^[19]. The employer must report the new starter on or before their first payday ^[13].

What the first submission carries

That first submission includes the details gathered from the checklist or P45, the starter declaration and tax code that were determined, and the pay and deductions from the start of employment with this employer only ^[13]. The year-to-date figures from a previous employer are never merged into this employer's totals ^[7].

Each employee also needs a payroll ID that is unique within the PAYE scheme ^[19]. The rules below prevent duplicate records at HMRC.

A late P45 or checklist

If the P45 or checklist arrives after the first payday, the employer follows the current HMRC code where one has already been issued, and otherwise updates its records from the late document ^[17]. A late P45 for the current tax year lets the employer update the total pay and tax figures for the first relevant period, while a late checklist updates the starter declaration held in the software ^[17]. The employer does not enter a new start date on a later submission, even if none was recorded at first ^[17]. Businesses managing this through a UK payroll engine have the correction handled inside the next scheduled submission rather than as a manual fix.

Check a new employee's tax code before the first payrun

An employer setting up a new starter can sanity-check the code the checklist produced with the Moonworkers tax code checker, which explains what each code and its markers mean under the 2026-27 rules before the first payslip is run ^[22].

Conclusion

The starter checklist looks like a simple form, but it quietly sets the terms of a new employee's tax for months. The declaration decides whether the worker gets the full allowance cumulatively, on an emergency basis, or not at all, and the student loan answers decide whether repayments begin and on which plan. None of it reaches HMRC directly, so the accuracy of the first Full Payment Submission rests entirely on how carefully the employer reads and applies the answers.

The employer that treats onboarding as a payroll task rather than a paperwork formality avoids the two failure modes that dog new hires: an emergency code that distorts early pay, and a duplicate record created by a reused payroll ID. Ask for the P45 first, fall back to the checklist when there is none, default to declaration B and Plan 5 when the facts are unclear, and let HMRC refine the code through the online account once the first submissions land.

Frequently asked questions

Does the new starter checklist get sent to HMRC?

No. The employee completes the starter checklist and gives it to the employer, who keeps it in the payroll records ^[16]. HMRC never receives the form itself. The tax authority learns about the new employee only when their details appear on the first Full Payment Submission the employer sends on or before the first payday ^[19].

Which starter declaration should I use if the employee is unsure?

Use declaration B. It applies the standard tax code on a week 1 or month 1 basis, which avoids the harsher basic rate code that declaration C produces while HMRC works out the correct cumulative position ^[15]. Once the first submissions reach HMRC, it will issue a revised code if one is needed, and the employer applies that from its effective date ^[22].

What tax code does a new employee with no P45 get?

It depends on the starter declaration they select. Declaration A gives the standard cumulative code, 1257L for the 2026-27 tax year, declaration B gives the same code on an emergency week 1 or month 1 basis, and declaration C gives the BR code that taxes all earnings at basic rate with no personal allowance ^[16]. An employee paid only once with no details supplied is taxed on code 0T ^[22].

When do student loan deductions start for a new hire?

Deductions begin when the checklist shows the employee has a loan, when a P45 indicates deductions should continue, or when HMRC issues a start notice and the employee earns above the plan threshold ^[18]. If the plan cannot be confirmed, the employer uses Plan 5 until a start notice arrives, because it has the lowest threshold and is the safest default ^[20].