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Employer NI ignores the under-21 and apprentice zero rates and the Employment Allowance #1918

Description

@MaxGhenis

ni_class_1_employer applies the full employer rate (15% from 2025-26) above the secondary threshold to every earner aged 16 or over. The model does not implement:

  • SSCBA 1992 s.9A. 0% secondary rate for earners under 21, up to the upper secondary threshold (SI 2001/1004 reg 10(e); £967 a week in 2026-27).
  • s.9B. 0% for relevant apprentices under 25, up to the apprentice upper secondary threshold (reg 10(f)). is_apprentice exists, but NI does not use it.
  • The Employment Allowance (NICA 2014 s.1): £10,500 per eligible employer in 2026-27, set against the employer's total secondary Class 1. It is employer-level, so the right representation in a person-level model needs a design decision.
  • The elective veterans and freeport/investment zone reliefs (NICA 2022 ss.1 and 6–7), for completeness.

So ni_employer is overstated for under-21s and young apprentices, and gross of the Employment Allowance.

policyengine-uk-data calibrates weights to OBR "Class 1 Employer NICs" using this model's ni_employer (targets/sources/obr.py, obr/ni_employer). Any fix interacts with calibration.

Found while fixing #1894 (PR #1895). There, the property test checks the statutory s.9 amount only from age 21, because of this gap.

Activity

  1. MaxGhenis commented on Sep 30, 2026

    @MaxGhenis
    CollaboratorAuthor

    Thresholds for whoever models the under-21 and apprentice zero rates here. I checked these against the primary sources on 2026-09-30.

    • 2026-27 (law): the UST and AUST are £967 a week (SI 2001/1004 reg 10(e)-(f)), or £4,189 a month and £50,270 a year (reg 11(3B)-(3C)). For a period that is a multiple of a week, reg 11(3B)(c)/(3C)(c) gives £50,270 / 52 per week, the same convention the model uses for the UEL.
    • 2027-28 to 2030-31 (announced, not yet legislated): the Budget 2025 policy paper says "the UST and AUST thresholds will remain aligned to the National Insurance contributions UEL at £967 per week up until the 2030 to 2031 tax year" (HMRC). Budget 2025 para 4.111 covers "other employer NICs relief thresholds aligned with the UEL".
    • The veterans' UST is enacted only through 2027-28 (NICA 2022 s.6(4)(e)-(f) and s.8(2), as amended by SI 2026/231 reg 6).
    • The freeport and investment zone UST is £481 a week for 2026-27 (HMRC rates page); I found no announced value for later years.

    #1959 freezes the UEL itself through 2030-31. Tying new UST and AUST parameters to it would keep them aligned.

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