A number of important deadlines crystallised last month in the context of the various COVID-19 support schemes.

• Claims under the job retention scheme for periods up to 31 October 2020 must be made by 30 November 2020;
• Applications for the second self-employed income support scheme grant closed on 19 October 2020; and
• Businesses began to be required to notify HMRC if they overclaimed a coronavirus job retention scheme (“CJRS”) or self-employed income support scheme (“SEISS”) grant.

This must be done within 90 days of Royal Assent to Finance Act 2020 or 90 days of receipt of the grant, whichever is the later. Tuesday 20 October 2020 was 90 days from Royal Assent to Finance Act 2020. This means the deadline for notifying overclaimed CJRS/SEISS grants fell on this date where these were received before 22 July 2020.

For CJRS grants where the employer ceased to be entitled to retain the payment, the notification deadline is the later of 90 days after ceasing to be entitled to the grant or the two dates mentioned above.

Failure to notify HMRC of an overpaid grant may result in the imposition of interest and a penalty as well as repaying the excess CJRS grant. Amounts still due to HMRC will then be recovered through a special income tax charge on the employer.

Employers can let HMRC know about overclaims as part of their next online claim. If an employer claimed too much but does not plan to submit further claims, you can let HMRC know and make a repayment online through a new online card payment service.