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Pension Credit income still omits IIDB, SDA, the AFCS guaranteed income payment and other countable income #1954

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@MaxGhenis

Found while fixing Pension Credit income for carers (#1952), which added carers_allowance and carer_support_payment.

gov.dwp.pension_credit.guarantee_credit.income still omits income that SPCA 2002 s.15(1) and SPC Regs 2002 reg 15 count. Items below were checked against legislation.gov.uk on 2026-09-30. Counts are Enhanced FRS 2026, weighted, State Pension age people.

Not in the income list (countable in law):

  • iidb. Industrial injuries disablement benefit counts, except the reg 15(1)(c) and (e) increases for constant attendance and exceptionally severe disablement. About 66k people, £5.9m of it in benefit units receiving Pension Credit.
  • afcs. The Armed Forces Compensation Scheme guaranteed income payment counts less £10 a week (reg 15(5)(aa); Sch IV para 1(cc)). About 20k people in Pension Credit units, £83m. First check what afcs holds: FRS code 8 may bundle war pensions, which also count less £10 a week (s.15(1)(g); Sch IV paras 1-2).
  • sda, incapacity_benefit, maternity_allowance: not excepted by reg 15(1).
  • maintenance_income, if it is spousal maintenance (reg 15(5)(d)).
  • Sublet income: reg 15(5)(i) with the £20 disregard in Sch IV para 9. property_income is counted gross; check it against reg 15(5)(i) and Sch IV para 18.
  • SSP, SMP, SPP and SAP are earnings under reg 17A(2)(h)-(j), but pension_credit_earnings does not include them.

Other gaps:

  • savings_credit/excluded_income.yaml lacks working tax credit, incapacity benefit, SDA, maternity allowance and maintenance (reg 9(a), (b), (d), (e), (f)).
  • gov.dwp.pension_credit.income.savings_credit_excluded_sources is an unused duplicate.
  • pension_credit_income applies no Sch VI earnings disregards.
  • It deducts all benefit-unit income tax and NI, but reg 17(10) disregards tax only on income taken into account.
  • uk-data maps bsp_reported from FRS codes 6 and 9. If those carry widow's benefits rather than bereavement support payment, excluding them under reg 15(1)(n) is wrong.

Suggested tests: the Hypothesis differential property in test_pension_credit_carer_income_properties.py (#1952), comparing Pension Credit income with HB (SPC) reg 29 income for the same household, extended to these sources.

🤖 Generated with Claude Code

Activity

  1. MaxGhenis commented on Oct 1, 2026

    @MaxGhenis
    CollaboratorAuthor

    The Schedule VI earnings disregard bullet is now #2019 (paras 1, 3, 4(1), 4A and 5; paras 2-2B and 4(2)-(4) not modelled, as stated there). It moves no FRS Pension Credit reporter's entitlement on the #510 build; the reporter gap is imputed capital (#2018). The other items in this issue are untouched.

  2. MaxGhenis commented on Oct 2, 2026

    @MaxGhenis
    CollaboratorAuthor

    One more Pension Credit item from the review of #2019, existing behaviour:

    (Correction: an earlier version of this comment also listed the lone-parent and couple-rate definitions. On main after #1896, a single pensioner with an 18-year-old in upper-secondary education is SINGLE and a lone parent, so that item is already fixed.)

  3. MaxGhenis commented on Oct 2, 2026

    @MaxGhenis
    CollaboratorAuthor

    Pension-age Housing Benefit has the same tax deduction issue. housing_benefit_applicable_income deducts all benefit-unit income tax and NI, but HB (SPC) Regs 2006 reg 33(12) (https://www.legislation.gov.uk/uksi/2006/214/regulation/33) disregards tax only "in the case of any income taken into account", the same wording as SPC Regs reg 17(10). The invariant 3 property in test_pension_credit_carer_income_properties.py adds income tax back for both measures; when this is fixed, tighten it to assert the measures themselves are unchanged (see #2049).

  4. MaxGhenis commented on Oct 11, 2026

    @MaxGhenis
    CollaboratorAuthor

    A reproduction for the pension-age Housing Benefit part of this issue (the tax deduction, HB (SPC) Regs 2006 reg. 33(12)), from round 2 of the PolicyBench UK engine audit.

    Household (policyengine-uk 2.126.7, 2026): single woman aged 72, council tenant in Cornwall, rent £4,886, State Pension £12,548, private pension £7,760, savings interest £6,559, savings £1,250.

    Engine Tax on counted income only
    Counted income (the two pensions) £20,308.00 £20,308.00
    Tax deducted £1,659.40 (all income tax) £1,547.60 (tax on the pensions)
    housing_benefit_applicable_income £18,648.60 £18,760.40
    housing_benefit_applicable_amount £13,312.00 £13,312.00
    Housing Benefit (65% taper) £1,417.21 £1,344.54

    The savings interest is left out of the income, but the £111.80 of tax on it is deducted. That £111.80 is itself too low because of #1799: the savings starting rate is given although taxable non-savings income exceeds £5,000. So fixing #1799 alone would raise the wrong deduction here.

    The same household's pension-age Council Tax Reduction has the same deduction; that part is #2090, with the figures in this comment.

    (Edited: this comment first described the Council Tax Reduction case, which #2090 already covers.)

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