Add the universal credit limb of the Housing Benefit passport (HB Regs Sch 4 para 12, Sch 5 para 4, Sch 6 para 5) #2132

Problem

The working-age Housing Benefit passport covers Income Support, income-based JSA and income-related ESA, but not Universal Credit. housing_benefit_applicable_income_disregard (Sch 4 para 12) sums income_support, jsa_income and esa_income. housing_benefit_applicable_income (Sch 5 para 4) and housing_benefit_assessable_capital (Sch 6 para 5) read in_receipt_of_income_support_jsa_ib_or_esa_ir (#2000). All three leave out the universal credit limb. The comments justify the omission: the model never pays Housing Benefit to a family on Universal Credit, and Universal Credit depends on Housing Benefit through the benefit cap.

Law (legislation.gov.uk /data.xml, read 2026-10-04)

• SI 2006/213 Sch 4 para 12: "Where a claimant is on universal credit, income support, an income-based jobseeker's allowance or an income-related employment and support allowance, his earnings."
• Sch 5 para 4: "Where a claimant is on universal credit, income support, an income-based jobseeker's allowance or an income-related employment and support allowance the whole of his income."
• Sch 6 para 5: "Where a claimant is on universal credit, income support, an income-based jobseeker's allowance or an income-related employment and support allowance, the whole of his capital."
• Reg 2(3B): "For the purposes of these Regulations, a person ("P") is on universal credit on any day in respect of which P is entitled to universal credit (whether it is in payment or not)."
• SI 2013/2070 reg 7(2), (7), (8) and (9) inserted the universal credit words from 28 October 2013.
• Northern Ireland: the same words are in SR 2006/405 Sch 5 para 12, Sch 6 para 4, Sch 7 para 5 and reg 2(3B), inserted by SR 2018/92 reg 4 from 8 May 2018.

Why now

In law, working-age Housing Benefit is paid alongside Universal Credit for specified or temporary accommodation (UC (Transitional Provisions) Regs 2014 reg 5(2)(a)). That rent is excluded from the UC housing costs element (UC Regs 2013 Sch 1 para 3(h) and (i)). The passport gives these families maximum Housing Benefit.

#1910 adds in_specified_or_temporary_accommodation and a route to Housing Benefit alongside Universal Credit. Once it lands, the model would means-test those families on their income and capital instead.

Circularity

The benefit cap makes post-cap universal_credit depend on Housing Benefit. Reading it would be circular. is_uc_entitled (Universal Credit before the cap and deductions, for a family that claims) does not depend on Housing Benefit, and housing_benefit_pension_age_regulations_apply already reads it. It also matches the law's "whether it is in payment or not". The law has no circularity at all: UC Regs 2013 reg 80(2A) counts Housing Benefit as nil in the UC cap, and HB Regs reg 75F(1)(g) disapplies the HB cap for a claimant receiving Universal Credit.

Axiom

TheAxiomFoundation/rulespec-uk#375 already plans the universal credit input. Its PolicyEngine modelling-difference note, which says the limb is left out, needs retiring.