Under the new PAYE Modernisation system in 2019 it is now much simpler to switch payroll software system during the year.

That is because each month is treated as its own mini end of year return. The pay run submissions now contain all the information required. Previously, the full picture was only given to Revenue in the end of year P35.

However, while the new filing system is an improvement over pre-2019 filing, it fails to reach the full potential of period reporting. Additionally, it fails to facilitate the intent of GDPR in regard to data portability.

The new RPN’s contain the current tax rates and bands for employees. However, they do not maintain a running total of earnings and deductions. This information is only provided in the RPN when people change roles. However, that facility could have been extended to all RPN’s with only a minor extension of logic in the RPN request process. Being able to request an employee’s latest tax position could facilitate the transfer of people between software or companies, and also the recovery of data if tax details were lost.

One of the principles of GDPR was the right to data portability. Data should be able to be transferred between data controllers in a machine readable format. Currently, there is no common machine readable structured format for payroll systems in Ireland. Software companies can export some information to csv/xls/xml. However, the exports are not the full range of data held within the system. PAYE modernsation was an opportunity that could have seen the establishment of a common format.

The new RPN system does improve the ability to switch systems. And perhaps we can revisit, once everything has calmed down, and make some incremental improvements.