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Some very early thoughts on the new Treasury Direction. These are the points that jumped out on first reading. I will have missed many...
I will do a thorough read over the weekend and update the FAQ Paper next week.
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I will do a thorough read over the weekend and update the FAQ Paper next week.
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1/
The Direction is available here: https://assets.publishing.service.gov.uk/government/uploads/system/uploads/attachment_data/file/886959/CJRS_DIRECTION_No2___20_05_2020.pdf
The Direction is available here: https://assets.publishing.service.gov.uk/government/uploads/system/uploads/attachment_data/file/886959/CJRS_DIRECTION_No2___20_05_2020.pdf
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First point to note is the CJRS has only been extended to 30 June. A further extension will be needed to 31 July and we are still waiting for info on how it will work from Aug-Oct.
First point to note is the CJRS has only been extended to 30 June. A further extension will be needed to 31 July and we are still waiting for info on how it will work from Aug-Oct.
3/
New wording on SSP and furlough. If SSP is "due to be paid" employee cannot be furloughed until PIW has ended. Suggestion that PIW can be ended by agreement??
Not quite sure this brings the Direction in line with the guidance. What do others think?
New wording on SSP and furlough. If SSP is "due to be paid" employee cannot be furloughed until PIW has ended. Suggestion that PIW can be ended by agreement??
Not quite sure this brings the Direction in line with the guidance. What do others think?
4/
Big change on how to furlough. Looks like the agreement to furlough no longer needs to be in writing. It only needs to be *notified* in writing.
I think this brings the Direction in line with the guidance.
Big change on how to furlough. Looks like the agreement to furlough no longer needs to be in writing. It only needs to be *notified* in writing.
I think this brings the Direction in line with the guidance.
5/
Definition of "regular" pay has been changed. Mercifully the phrase "not conditional on any matter" (former para. 7.4(b)) has been removed!
Definition of "regular" pay has been changed. Mercifully the phrase "not conditional on any matter" (former para. 7.4(b)) has been removed!
6/
Sticking with pay, we now have some clarity on what non-discretionary payments count as "regular" pay that can be claimed under the Scheme.
Sticking with pay, we now have some clarity on what non-discretionary payments count as "regular" pay that can be claimed under the Scheme.
7/
The relevant date for TUPE transfers has been changed from 19 Mar to 28 Feb (in line with changes to the guidance).
So claims can be made for employee's TUPE'd after 28 Feb even if no RTI submission before 19 March.
The relevant date for TUPE transfers has been changed from 19 Mar to 28 Feb (in line with changes to the guidance).
So claims can be made for employee's TUPE'd after 28 Feb even if no RTI submission before 19 March.
8/
Those are my (very) early thoughts. Let me know if there are things I have missed!
Will return to the Directions over the weekend (and with a lot more coffee...)
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Those are my (very) early thoughts. Let me know if there are things I have missed!
Will return to the Directions over the weekend (and with a lot more coffee...)
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