For HMRC to demand that RTI submission are made in real-time on the day employees are paid is a draconian system which gives absolutely no allowance for processing difficulties such as a delay in accountants and payroll bureaus receiving information from clients or for small businesses whose processing staff might not be available during the time a report is due.  The stresses that this places business owners, accountants and payroll bureaus is disproportionate to the benefits gained.  If the RTI filing deadline was relaxed to the 19th of the following month for ALL reports this would be in line with acceptable PAYE filing obligations in this country and would still provide HMRC with up to date information on a month by month basis.  This would also enable businesses to comply without any need for further extension to the delay in introduction of the currently dreaded penalties scheme.