Article:

CJRS is evolving again – are you keeping up?

27 April 2021

Many aspects of CJRS have remained the same since its introduction back in March 2020. However, there have also been many changes as the scheme has evolved and version four is live from 1 May 2021 bringing some important changes to variable pay calculations (see table below). Some of these changes are key to getting the CJRS calculations right so it is vital to understand which rules apply for which periods.

What if you made a mistake?

Given the wide variety of employment contracts and arrangements that employers use, the complexity of the CJRS rules and the pressures that the pandemic has put us all under it is no surprise that many mistakes have been made with furlough claims. But that doesn’t mean you can ignore them: employers have a legal obligation to correct over claims, including notifying HMRC of the error within 90 days (read more), and may well have a financial imperative to make sure they have claimed enough support!

Not 100% sure? BDO offers two CJRS tools to support your business with calculations and understanding your exposure to risk.

CJRS Calculator - A time saving calculator that allows our specialist employment tax team to assist you with calculations for your entire furlough population. Read more

CJRS Process Risk Review Tool – We will check your processes to help you understand your exposure to risk and ensure the detail of claims has been accurate and whether further action is required in order to be compliant with HRMC. Read more

How the CJRS rules have evolved

Topic/rule

CJRS v1

March to June 2020

CJRS v2

July to October 2020

CJRS v3

November to April 2021

CJRS v4

May to September 2021

Individual needed to be previously furloughed

No

Yes, apart from exceptional circumstances

No

 

No

 

Maximum number of individuals able to claim for

No maximum

Cannot exceed the maximum number of employees claimed for under any claim ending by 30 June 20 unless in very exceptional circumstances

No maximum

No Maximum

Flexible Furlough available

No

Yes

Yes

Yes

Employer claim information made public

No

No

From 1 December 20 onwards apart from exceptional cases

Yes apart from exceptional cases

Claims deadline

31 July 20

30 November 20

14 days after each month end, (unless this falls on a weekend then it is the next working day)

14 days after each month end, (unless this falls on a weekend then it is the next working day)

Add additional employees to the claim

31 July 20

N/A

28 days after month end (unless this falls on a weekend then it is the next working day)

28 days after month end (unless this falls on a weekend then it is the next working day)

Under-claim amendment deadline

30 November

30 November

28 days after month end (unless this falls on a weekend then it is the next working day)

28 days after month end (unless this falls on a weekend then it is the next working day)

Over-claim amendment deadline

20 October 20

90 days after receipt of grant not entitled to

90 days after receipt of grant not entitled to

90 days after receipt of grant not entitled to

Claim while employee is on statutory notice period

Yes

Yes

November 20 – Yes

December 20 onwards - No

No

Claim periods

Can start and finish in different months

Claim periods must start and finish in same month

Claim periods must start and finish in same month

Claim periods must start and finish in same month

Length of claim period

No minimum

At least 7 days unless it contains first or last day of month

At least 7 days unless it contains first or last day of month

At least 7 days unless it contains first or last day of month

Employee Eligibility
(must have been included in RTI submissions)

RTI submission made on or before 19 March 20

RTI submission made on or before 19 March 20

RTI submission made on or before 19 March 20, or

RTI submission made between 20 March 20 and 30 October 20

RTI submission made on or before 19 March 20, or

RTI submission made between 20 March 2020 and 30 October 20

RTI submission made between 20 March 2020 and 2 March 21

 

Reference date for employee’s reference salary and usual hours calculations – fixed employees

Last pay period ending on or before 19 March 20

Last pay period ending on or before 19 March 20

RTI submission made on or before 19 March 20 – last pay period ending on or before 19 March 20

 

RTI submission made between 20 March 20 and 30 October 20 - last pay period ending on or before 30 October 20

RTI submission made on or before 19 March 20 – last pay period ending on or before 19 March 20

Or 

RTI submission made between 20 March 20 and 30 October 20 - last pay period ending on or before 30 October 20

Or

RTI submission made between 20 March 20 and 2 March 21 - last pay period ending on or before 2 March 21

Usual hours calculations for variably paid employees

Higher of:

Average number of hours worked in 2019/20, and

Corresponding calendar period in 2019/20

Higher of:

Average number of hours worked in 2019/20, and

Corresponding calendar period in 2019/20

RTI submission made on or before 19 March 20, the higher of:

Average number of hours worked in 2019/20, and

Corresponding calendar period in 2019/20

RTI submission made between 20 March 20 and 30 October 2020:

Average number of hours worked from 6 April 20 to first day spent on furlough after 1 November 20

RTI submission made on or before 19 March 20, the higher of:

Average number of hours worked in 2019/20, and

Corresponding calendar period in 2019/20

RTI submission made between 20 March 20 and 30 October 20:

Average number of hours worked from 6 April 20 to first day spent on furlough after 1 November 20

RTI submission made between 20 March 20 and 2 March 21

Average number of hours worked from 6 April 20 to first day spent on furlough after 1 May 21

Reference pay calculation for variably paid employees

Higher of:

 

Average wages earned in 2019/20, and

 

Wages earned in corresponding  calendar period in 2019/20

Higher of:

 

Average wages earned in 2019/20, and

 

Wages earned in corresponding  calendar period in 2019/20

RTI submission made on or before 19 March 20, the higher of:

 

Average wages earned in 2019/20, and

 

Wages earned in corresponding  calendar period in 2019/20

 

RTI submission made between 20 March 20 and 30 October 20:

 

Average wages payable from 6 April 20 to first day spent on furlough after 1 November 20

RTI submission made on or before 19 March 20, the higher of:

Average wages earned in 2019/20, and

Wages earned in corresponding  calendar period in 2019/20

RTI submission made between 20 March 20 and 30 October 20:

*Average wages payable from 6 April 20 to first day spent on furlough after 1 November 20

*Average wages payable from 6 April 20 to first day spent on furlough after 1 May 21

* Note that where part of the period includes statutory sick pay related leave, family related statutory leave or reduced rate paid leave following such periods, these days should now be left out of the average.

Reference pay calculation for fixed paid employees

No adjustment

No adjustment

Pay frequency changed between reference period and pay period:

Wages pro-rated to new pay frequency, then multiplied by 80%

Pay frequency changed between reference period and pay period:

Wages pro-rated to new pay frequency, then multiplied by 80%

Grant claim

80% of reference salary (subject to cap of £2,500

Employers national insurance

Employer pension contributions

July

80% of reference salary (subject to cap of £2,500)

Employers national insurance

Employer pension contributions

August

80% of reference salary (subject to cap of £2,500)

September

70% of reference salary (subject to cap of £2,187.50)

(10% top up by employer)

October

60% of reference salary (subject to cap of £1,875)

(20% top up by employer)

80% reference salary

May and June 2021:

80% reference salary

July 2021:

70% of reference salary (subject to cap of £2,187.50)

(10% top up by employer)

August and September 2021

60% of reference salary (subject to cap of £1,875)

(20% top up by employer)

 

For more information on the specific rules, read our CJRS FAQs, get in touch with your usual BDO contact or [email protected].

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