HMRC Starter Checklist: P46 Form Replacement Guide

The HMRC Starter Checklist (P46 form) is a form used by UK employers to determine your correct tax code when you start a new job.

Tax paperwork isn't the most exciting part of the onboarding process, but getting it wrong can lead to an emergency tax code, overpayments, and a frustrating conversation with HMRC further down the line.

The Starter Checklist is the form that prevents all of that, and yet many employees hand it over without understanding what it does or why each question matters.

This guide breaks down everything you need to know about what the Starter Checklist replaced, how to fill it in correctly, what happens when you don't, and how your employer uses the information you provide.

Key points

• The P46 has been replaced by the Starter Checklist 📃
  Since HMRC introduced Real Time Information (RTI) in 2013, new employees without a P45 now complete a Starter Checklist instead. Employers use it to send your tax details directly to HMRC through payroll.
• Choosing the wrong statement can affect your tax ⚠️
  The A, B, and C statements determine which tax code you receive. Selecting the wrong one can lead to overpaying tax, underpaying tax, or being put on an emergency tax code until HMRC corrects it.
• Second jobs are taxed differently 💷
  If you already have another job or receive a pension, you won't get a second tax-free Personal Allowance. HMRC may apply a BR or D0 tax code so the extra income is taxed correctly from the start.
• Student loan details matter more than people think 🎓
  Your employer needs the correct student loan plan to deduct repayments properly. Using the wrong plan, or forgetting to declare one entirely, can lead to unexpected repayment issues later.
• ANNA helps you stay organised beyond payroll paperwork 🚀
  If you’re a freelancer, have a side hustle, or manage multiple income streams alongside a new job, ANNA can help simplify the admin. You can track expenses, sort taxes automatically, send invoices, and even get your 2025/26 Self Assessment prepared and filed for free when you sign up.

What was the P46, and why was it replaced?

The P46 was a paper form that employees completed when starting a new job without a P45. A P45 is a document in the UK that an employer gives you when you leave a job, showing how much tax you've paid on your earnings so far in the tax year.

HMRC scrapped the P46 when the Real Time Information (RTI) system launched in 2013, replacing it with the Starter Checklist.

The key difference is that the old P46 was submitted directly to HMRC, whereas the Starter Checklist stays with your employer, who passes the data to HMRC through RTI as part of normal payroll reporting.

When you need to complete the Starter Checklist

Here are some common situations in which people need to fill out a Starter Checklist:

Even if you have a P45, your new employer may still ask you to complete the checklist. The P45 doesn't capture information on student or postgraduate loans, which your employer needs in order to deduct the correct repayments from your salary through PAYE.

What if I have a second job?

For a second job, the Starter Checklist tells HMRC that you already have another source of income that is using your tax-free Personal Allowance.

Without that information, your new employer may assume you are entitled to a full Personal Allowance, which would be incorrect.

Instead, HMRC will usually assign a BR (Basic Rate) or D0 (Higher Rate) tax code to your second job. This means all income from that job is taxed from the first pound, preventing you from 'double claiming' the tax-free allowance.

If you don't declare that you already have another job, your second employer may temporarily apply the wrong tax code, and you could underpay tax for the year. HMRC will later adjust this, which often results in a tax bill or reduced tax code to recover the shortfall.

The breakdown of the HMRC Starter Checklist (P46 form)

The HMRC Starter Checklist is divided into several sections that collect the key information your employer needs to set up your tax correctly.

Here's a clear breakdown:

Your personal details

This section covers your name, address, date of birth, National Insurance number, and start date. Your NI number is how HMRC links the submission to your tax record. If you don't have one yet, you can still start work, but you should apply for one through GOV.UK as soon as possible.

The statement section

This is the part of the form that determines your tax code, and it's where most mistakes happen. You should pick the option that best describes your employment history since the start of the current tax year, which is 6 April.

You must select one statement of the three:

A and B result in the same tax code, but they tell HMRC different things about your year. The distinction helps HMRC calculate whether you've already used any of your Personal Allowance.

The wrong statement won't create a legal issue, but it can mean overpaying or underpaying tax in your first few months.

💡Did you know?

The 1257L tax code represents the standard Personal Allowance of £12,570, or the amount you can earn before income tax applies. The 'L' suffix indicates entitlement to the basic Personal Allowance.

Student loan repayments

If you have an outstanding student loan, you need to declare it and specify your loan repayment plan. This matters because repayment thresholds (the point at which deductions kick in) vary significantly across plans, as does the deduction rate.

Your employer can't apply the right deductions without knowing which plan you're on.
Here are the options:

If you're not sure which plan applies to you, log in to the Student Loans Company portal or check your original loan offer letter. Don't guess, since using the wrong plan means deducting either too much or too little each month.

Postgraduate loan

If you have a postgraduate loan, it runs on its own repayment schedule. The threshold is lower (£21,000), the deduction rate is different (6% vs 9% for undergraduate loans), and the two can run at the same time if you have both.

If you have a postgraduate loan, tick this box as well as (or instead of) the student loan box, depending on your situation. Your employer needs both pieces of information to deduct the right amounts.

What happens after you submit the Starter Checklist?

Your employer enters the information into payroll and applies the relevant tax code before your first payslip. HMRC receives this via the RTI submission and may issue a revised tax code if their records show additional income from earlier in the tax year.

Check your first few payslips for 'W1' or 'M1' next to your tax code. This indicates a non-cumulative emergency basis that is temporary and should resolve once HMRC processes the submission and updates your code.

Common mistakes and how to avoid them

Most errors on the Starter Checklist happen due to rushing. The form looks simple, but a few specific mistakes tend to cause problems, usually because they don't surface until weeks later.

Here are the most common mistakes to avoid:

• Leaving the statement blank: If you don't select A, B, or C, your employer has no basis for applying a specific tax code and will default to an emergency one. You'll likely overpay tax from your first payslip, and getting it corrected means chasing both your employer and HMRC.
• Choosing statement C instead of B: This is the most common mix-up. Statement C applies when you have another job or pension running at the same time, not when you had a job earlier in the year.
• Not declaring a student loan: Without a declaration, your employer won't deduct repayments through payroll. That doesn't mean you're off the hook – HMRC will identify the gap, usually at the end of the tax year, and may collect the unpaid amount in a way that doesn't fit into your monthly budget.
• Having a typo in your NI number: Your National Insurance number is how HMRC ties the submission to your actual tax record. An incorrect number means the data sits unmatched, which can delay your tax code being properly set up. Check it against your NI card, a previous P60, or your HMRC personal tax account before you hand the form over.

Employers' obligations

Employers must collect the Starter Checklist on or before a new starter's first payday.

Here are HMRC's requirements for employers:

• Provide access to the checklist before the first pay run
• Apply the tax code that corresponds to the statement selected
• Retain the completed form for the remainder of the current tax year and the following three tax years
• Include the information in the employee's first Full Payment Submission via RTI

You don't need to send the form to HMRC. If the checklist isn't ready before the first payday, apply 1257L W1/M1 for Statements A or B, or 0T for Statement C, and collect the form as soon as possible afterwards.

Where to find the latest Starter Checklist version

The current Starter Checklist is on GOV.UK. HMRC updates it periodically, so make sure you always download a fresh copy. Employers can offer either a printed or digital version; both are acceptable.

If an employee's circumstances change after submission (for example, if they take on a second job), they'll need to complete a new checklist.

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