P38a deadline

I can't find any reference to this on HMRC's guidance... Is there a deadline after which a penalty will be imposed for submitting a P38a?

When you submit a P35 you make a declaration to say that you have included P14s or a P38a for everyone in your employment (or words to that effect), so I had felt that if you forget to submit the P38a then, technically, the P35 was not complete and therefore a penalty will arise.

But, I then found this on HMRC's internal guidance for the procedure to follow if a P38a has not been received:


No mention of a penalty there... what do we think?
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