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HM Revenue & Customs has published further guidance on PAYE Real Time Information and verifying National Insurance Numbers (NINos) at Real Time Information and National Insurance Number Verification Requests (NVRs) and pointed out that NVRs can be operated only AFTER the first Full Payment Submission under RTI.

HMRC appears also to have received numerous telephone calls from employees whose employers are insisting on a NINo before they can be paid under RTI. It then goes on to say that its guidance on the matter is "clear", and basically that NINos are NOT in fact mandatory - but that when they are given, they must be correct.

Clear? Really? How about "Getting Your Payroll Right The First Time - Why Employee information Matters" - National Insurance Number:

"Please always enter the correct National Insurance Number." This instruction could easily be interpreted to mean that a NINo must always be given.

Having read the Full Payment Submission Checklist and seen NINos listed under the title "Information Employers Must Complete", employers might also be forgiven for thinking that they must be completed. Although not marked with an asterisk so not in fact mandatory, the guidance does for good measure add, "an employee is required by law to give you a National Insurance number". 

To be fair, it is perhaps to be expected that there will be some confusion, given the scale of the changes. (Do we mean fair to employers, or fair to HMRC?!)