Test Winter Fuel Payment and PAWHP receipt per person

[MaxGhenis]

Summary

winter_fuel_allowance and pawhp decided means-tested status for the whole household:

on_mtb = add(household, period, ["pension_credit", "income_support", "esa_income", "jsa_income"]) > 0

That pools every benefit unit. So a non-dependant adult child's income-related ESA:

• made a pensioner parent entitled to the 2024-25 Winter Fuel Payment and PAWHP;
• exempted the parent from the Winter Fuel Payment income test from 2025-26;
• gave a Scottish household the relevant-benefit rate.

The law tests receipt person by person, and pays each person. This PR rewrites both payments that way.

It builds on #2027 (merged as bbb9576e8). It uses #2027's is_on_income_related_esa, is_on_income_based_jsa and is_on_income_support, which name the one member of a couple an award is paid to.

The law

Fetched verbatim from legislation.gov.uk (/data.xml) on 2026-10-02.

Qualifying week	England and Wales	Scotland	Northern Ireland
2022, 2023	SI 2000/729 (Great Britain)	SI 2000/729	NISR 2000/91
2024	SI 2024/869	SSI 2024/351 as made	NISR 2024/160
2025	SI 2025/969	SSI 2024/351 as amended by SSI 2025/282 (amounts SSI 2025/100)	NISR 2025/142
2026	SI 2025/969	amounts SSI 2026/170	NISR 2025/142

• Who is on a relevant benefit. The instruments use two tests:
  • SI 2000/729 (reg 2(1)(ii), 3(1)(a)(i)) and SI 2025/969 (regs 3 and 4(2)(a)) ask whether a relevant benefit "has been, or falls to be, paid to" the person. Income Support, income-based JSA, income-related ESA and Pension Credit are paid to one member of a couple.
  • SI 2024/869 reg 2(2)(b) asks whether "the person" is entitled to one, and reg 2(5) extends that to where "the other member of the couple ... is entitled". SSI 2024/351 does the same for PAWHP: reg 7(2) as made, reg 10(8) as substituted by SSI 2025/282, and reg 2A from April 2026.
• The relevant benefits. SI 2025/969 reg 1(3): Income Support, income-based JSA, Pension Credit, income-related ESA and Universal Credit. SI 2024/869 reg 2(2)(b) adds child tax credit or working tax credit of not less than £26 for 2024-25, and SSI 2024/351 as made does the same. SI 2000/729 reg 2(1)(ii) lists only Pension Credit, income-based JSA and income-related ESA. The old code omitted Universal Credit and tax credits.
• One payment per couple on a relevant benefit. SI 2000/729 reg 3(1)(a)(i); SI 2024/869 reg 4(1)(a)(i); SI 2025/969 reg 4(2)(a); SSI 2024/351 reg 9(d). The amount is the higher one if either member is 80 (SI 2024/869 reg 3(b); SI 2025/969 reg 3(3); SSI 2024/351 reg 10(4)(a)(ii)).
• Shared amounts for everyone else. A person not on a relevant benefit who lives with another entitled person gets £100 under 80, £200 at 80+ living with an under-80, and £150 at 80+ living with another 80+ (SI 2000/729 reg 2(1)(ii), 2(2)(b); SI 2025/969 reg 3(2), (5), (6), with (5) subject to (6)). For PAWHP from 2025 the amounts are £101.70, £203.40 and £152.55, then £105.55, £211.15 and £158.35 from April 2026 (SSI 2024/351 reg 10(5), (6) as substituted).
• Age. SI 2000/729 reg 2(1)(b) requires "the qualifying age for state pension credit". SI 2024/869 reg 2(1)(a), SI 2025/969 reg 2 and SSI 2024/351 require pensionable age.
• Winter fuel payment charge. ITEPA 2003 s.681I, inserted by FA 2026 Sch 10 for 2025-26 on, charges each person with total income over £35,000 the amount of their payment, "but P is not liable for the charge if P is entitled to a relevant benefit" (s.681I(4)). It covers SI 2025/969, SSI 2024/351 and the NI regulations.

What changed

Receipt, per person. New person variables:

• is_on_pension_credit. Pension Credit is the claimant's entitlement and is paid to the claimant (SPCA 2002 ss.1 and 5). The claimant must have attained the qualifying age (s.1(2)(b)). So of the claimant and partner, the model puts on it a member who has attained that age: the one who reports the award, else the benefit-unit head, else the elder. Where neither has, the same order applies to both, as in Count only the claimant's and partner's legacy awards in means tests and passports #2027's readers. Anyone else is on it only through their own report.
• is_on_universal_credit and tax_credit_award. Both are claimed jointly (WRA 2012 s.2(1)(b); TCA 2002 s.3(3)(a)), so for the claimant and the partner they read the couple's award. Universal Credit is also awarded jointly (WRA 2012 s.1(2)(b)) and paid into an account the joint claimants nominate (Universal Credit etc. (Claims and Payments) Regulations 2013 reg 47(4)). Reg 47(6) pays it wholly to one member only by special arrangement. The exception is a partner who cannot be a joint claimant (uc_is_ineligible_partner): the other member then claims as a single person (Universal Credit Regulations 2013 reg 3(3)), so the award is not that partner's. Anyone else is on one only through their own report.
• is_on_winter_fuel_payment_relevant_benefit and is_on_pawhp_relevant_benefit. They read three new dated parameters for each scheme, under gov.dwp.winter_fuel_payment.eligibility and gov.social_security_scotland.pawhp.eligibility:
  • relevant_benefits, the list.
  • minimum_tax_credit_award: £26 for the 2024 week and infinite otherwise. The winter threshold therefore stays at £26 even if the tax credit payment minimum is reformed.
  • partner_receipt_counts: whether a member of a couple is on a relevant benefit when the other member is. It is false for the Winter Fuel Payment under the 2000 and 2025 regulations ("paid to"). It is true for the 2024 week (SI 2024/869 reg 2(5)) and for PAWHP throughout.

Payments, per person; household totals kept. I kept winter_fuel_allowance and pawhp as the Household variables every reader uses: household benefits, HBAI, gov_spending, the cost-of-living pensioner payment and disable_simulated_benefits. Each now adds up new person-level payments, winter_fuel_payment and pension_age_winter_heating_payment, with winter_fuel_payment_eligible and pawhp_eligible. Shared logic is in policyengine_uk/utils/winter_heating.py.

I did not keep the old £200/£300-per-household structure, because the law requires per-person payments. Every instrument entitles and pays a person, and sets the amount from that person's own receipt, age, partner's age and who they live with. A household rule matches the law only when one benefit unit holds every pension-age member. Otherwise it is wrong:

• two pensioners in separate benefit units each on Pension Credit get two payments (SI 2024/869 reg 4 excludes only a partner);
• a Pension Credit recipient living with a pensioner who is not on it gets £200, and the other gets £100 (SI 2025/969 reg 3(1)-(2)), £300 in all;
• in Scotland from 2025, a household rule plus a correct receipt test would pay a pensioner living with a non-dependant on ESA less than the law does.

A relevant-benefit couple gets one payment whichever test applies: the couple's receipt decides who is excluded. The payment goes to the member the benefit is paid to. SI 2025/969 reg 4(2)(a) excludes the partner of the pension-age person paid, and the explanatory memorandum (para 5.8) names the lead claimant, or the partner when only the partner has reached pensionable age. Where a benefit is paid to both members (a joint award), the model takes the claimant to be the member who reports the award, failing that the benefit-unit head, failing that the elder. A report of an award the model does not pay does not count.

This matters beyond the couple. A Pension Credit claimant aged 70 with a partner aged 85 gets £300, and their 82-year-old lodger gets £200 (reg 3(5)). Paying the 85-year-old instead would give the lodger £150 (reg 3(6)).

Under the "paid to" test, the partner of an income-related ESA claimant who is under pensionable age is not on a relevant benefit, because the award is the claimant's alone. So under SI 2025/969 the partner is paid at their own rate: £200 alone, £100 beside another entitled person (reg 3(2)). Under SI 2024/869 they are entitled through the couple. Universal Credit falls to be paid to both joint claimants, so the pension-age member of a Universal Credit couple keeps the full £200 beside a lodger.

Everyone in a household is taken to live together; residential care, long hospital stays and custody are not modelled.

Age. winter_fuel_payment_eligible applies the dated test from main (fcfcd4189), person by person. It uses the qualifying age for State Pension Credit up to the 2023 week and pensionable age from 2024, both for the person's own entitlement and in the household income test. pawhp_eligible uses pensionable age.

Residence. SI 2000/729 covered Great Britain up to the 2023 qualifying week. From 2024 the Winter Fuel Payment covers England and Wales (SI 2024/869 reg 1(2); SI 2025/969 reg 1(2)) and PAWHP Scotland. The old code excluded Scotland from the Winter Fuel Payment in every year and paid "PAWHP" in 2022-23. New parameters: gov.dwp.winter_fuel_payment.eligibility.countries and gov.social_security_scotland.pawhp.active. Northern Ireland pays under mirror regulations, and the existing parameters stand in for them as before.

PAWHP amounts. From the 2025 week there is no relevant-benefit condition (SSI 2025/282 reg 5 omits reg 7), and the legislated amounts apply. The removed pawhp.amount.base paid £100 per household not on a relevant benefit; the regulations have no such amount. The higher and lower amounts were CPI projections (£206.80 / £310.20 for 2025); they are now the legislated £203.40 / £305.10 (SSI 2025/100) and £211.15 / £316.70 (SSI 2026/170). CPI uprating continues beyond 2026.

Citations. The PAWHP parameters cited SSI 2024/250, which is the Town and Country Planning (Amendment of Local Development Plan) (Scotland) Regulations 2024. They now cite SSI 2024/351 and its amending instruments.

Registry. programs.yaml gains a PAWHP entry, and the Winter Fuel Payment entry's variable: winter_fuel_payment now exists.

Kept as is. The Winter Fuel Payment income test (taxable_income_test) still stands in for the s.681I charge. It applies to a household with any member of pensionable age under £35,000, in England and Wales only. The relevant-benefit exemption it gives is now per person: a non-dependant's award no longer exempts the pensioner. A per-person charge is #2066.

Parameter dates follow the files' convention: PE-UK reads parameters at 30 April, so regime changes for a September qualifying week are dated 1 January of that year, with a comment giving the instrument's in-force date.

Invariants (property-tested)

policyengine_uk/tests/test_winter_heating_payment_properties.py:

1. Differential. For households of up to three benefit units, in any country and in 2023-2026, every person's payment equals a reference implementation. The reference is written person by person from the regulations, with its own benefit lists, amounts and the two receipt tests, not read from the model's parameters.
2. Non-dependants. Adding a person under pensionable age, in their own benefit unit or as a member who is neither claimant nor partner, never changes anyone else's payment. This holds whatever relevant benefit the added person has.
3. One benefit unit. From 2025, a household in England, Wales or Scotland of a single person or a couple (one benefit unit's claimant and partner, with no one else), with incomes under the £35,000 limit, receives the full amount for that unit (higher if anyone is 80+), on a relevant benefit or not. The shared amounts are designed to add up to it. The one intended exception is PAWHP from April 2026: two shared amounts of £105.55 make £211.10, 5p below £211.15.

Mutation checks:

• The property suite was run against four deliberate bugs, and caught every one: a person counted as living with themselves; two payments per relevant-benefit couple; Universal Credit dropped from the 2024 list; the old household-pooled receipt test.
• Paying the elder member of a couple rather than the claimant is caught by the differential property and 3 YAML cases.
• Five mutants of the two receipt tests each fail between one and three YAML cases. They are: the couple test for the 2025 regulations; the couple test for the 2000 regulations; the "paid to" test for the 2024 week; the "paid to" test for PAWHP; and the exclusion read from the payee alone.
• Pension Credit read for both members of a couple rather than the payee passed every YAML case until round 4; it now fails 3. Dropping the qualifying-age limit on the Pension Credit payee fails 2.
• The two round-5 regressions below (an unpaid report, and a Universal Credit single claim) fail on 4f2758c5d and pass on c12f8200a.

Tests

• YAML, each case worked by hand from the regulations:
  • tests/policy/baseline/gov/dwp/winter_fuel_payment/relevant_benefit_receipt.yaml: 33 cases, 2023-2025. They include:
    • a pensioner with a non-dependant on income-related ESA, in a separate benefit unit and as a non-partner member;
    • £25 and £26 tax credit awards, on the couple's award and reported by a pensioner who is neither claimant nor partner;
    • the claimant-and-lodger case above;
    • the partner of an income-related ESA or income-based JSA claimant under pensionable age, under each instrument;
    • a Universal Credit couple with a lodger;
    • who Pension Credit is paid to, including a couple whose member under the qualifying age reports the award or heads the benefit unit;
    • a report of an award that is not paid, and a Universal Credit single claim.
  • tests/policy/baseline/gov/social_security_scotland/pawhp.yaml: 23 cases, 2024-2026.
  • tests/policy/reforms/parametric/winter_fuel_allowance/minimum_tax_credit_award.yaml: 3 reform cases (a minimum of 0 still needs a positive award).
• One existing case moved: winter_fuel_allowance.yaml asserted no Winter Fuel Payment in Scotland in 2023. SI 2000/729 paid it there that winter, so the case now uses 2024. Main's four dated age-test cases in that file pass unchanged.
• On main (e89b8abcf), 35 of the 56 cases give a household total that differs from the law:

Case	Year	Base (main e89b8abcf)	This branch = law
WFP: 2024 a non-dependant's income-related ESA does not entitle the pensioner	2024	£200.00 ✗	£0.00
WFP: 2024 a non-dependant who is neither claimant nor partner does not pass their ESA to the pensioner	2024	£200.00 ✗	£0.00
WFP: 2024 a pensioner on Pension Credit living with a non-dependant gets £200	2024	£200.00	£200.00
WFP: 2024 a Pension Credit couple gets one payment of £300 when one partner is 80	2024	£300.00	£300.00
WFP: 2024 two pensioners in separate benefit units each on Pension Credit get a payment each	2024	£200.00 ✗	£400.00
WFP: 2024 a pensioner in a mixed-age couple on Universal Credit gets £200	2024	£0.00 ✗	£200.00
WFP: 2024 a pensioner with a tax credit award of at least £26 gets £200	2024	£0.00 ✗	£200.00
WFP: 2024 a tax credit award of £25 is below the £26 minimum	2024	£0.00	£0.00
WFP: 2024 a tax credit award of exactly £26 qualifies	2024	£0.00 ✗	£200.00
WFP: 2024 a pensioner who is neither claimant nor partner reporting a tax credit award of £25	2024	£0.00	£0.00
WFP: 2024 a pensioner who is neither claimant nor partner reporting a tax credit award of £26	2024	£0.00 ✗	£200.00
WFP: 2025 a non-dependant's income-related ESA does not exempt the pensioner from the income test	2025	£200.00 ✗	£0.00
WFP: 2025 a pensioner under the income limit living with a non-dependant on ESA gets £200	2025	£200.00	£200.00
WFP: 2025 a pensioner on Pension Credit and one who is not, in separate benefit units	2025	£200.00 ✗	£300.00
WFP: 2025 an 85-year-old not on Pension Credit living with a 70-year-old who is	2025	£300.00 ✗	£400.00
WFP: 2025 a couple aged 70 and 82 not on a relevant benefit gets £300 between them	2025	£300.00	£300.00
WFP: 2025 a couple both over 80 not on a relevant benefit gets £150 each	2025	£300.00	£300.00
WFP: 2025 an over-80 living with entitled people both over and under 80 gets £150	2025	£300.00 ✗	£400.00
WFP: 2025 a Pension Credit couple gets one payment	2025	£200.00	£200.00
WFP: 2025 the couple's payment goes to the Pension Credit claimant, which sets a lodger's shared amount	2025	£300.00 ✗	£500.00
WFP: 2025 without a reported award, the couple's payment goes to the benefit-unit head	2025	£300.00 ✗	£500.00
WFP: 2023 Scotland's pensioners get the Winter Fuel Payment, not PAWHP	2023	£200.00	£200.00
WFP: 2023 a pensioner on Pension Credit and one who is not, in separate benefit units	2023	£200.00 ✗	£300.00
WFP: 2023 Universal Credit is not a relevant benefit under the 2000 regulations	2023	£200.00	£200.00
WFP: 2025 the partner of an income-related ESA claimant under pensionable age is paid at their own rate	2025	£200.00	£200.00
WFP: 2025 Universal Credit falls to be paid to both joint claimants, so the partner keeps the full amount beside a lodger	2025	£200.00 ✗	£300.00
WFP: 2024 the partner of an income-related ESA claimant under pensionable age is entitled through the couple	2024	£200.00	£200.00
WFP: 2023 the partner of an income-based JSA claimant under qualifying age is paid at their own rate	2023	£200.00	£200.00
WFP: 2025 Pension Credit is paid only to the member of a couple who claims it	2025	£200.00	£200.00
WFP: 2025 Pension Credit reported by a partner under the qualifying age is paid to the member over it	2025	£200.00 ✗	£300.00
WFP: 2025 with no report, Pension Credit is paid to the member over the qualifying age even when the other heads the benefit unit	2025	£200.00 ✗	£300.00
WFP: 2025 a report of an award that is not paid does not move the couple's payment from the Pension Credit payee	2025	£300.00	£300.00
WFP: 2025 Universal Credit claimed as a single person is not paid to the partner who cannot be a joint claimant	2025	£200.00	£200.00
PAWHP: 2024 a non-dependant's income-related ESA does not entitle the pensioner	2024	£200.00 ✗	£0.00
PAWHP: 2024 a pensioner on Pension Credit gets £200	2024	£200.00	£200.00
PAWHP: 2024 a Pension Credit couple gets one payment of £300 when one partner is 80	2024	£300.00	£300.00
PAWHP: 2024 a pensioner in a mixed-age couple on Universal Credit gets £200	2024	£0.00 ✗	£200.00
PAWHP: 2024 a pensioner with a tax credit award of at least £26 gets £200	2024	£0.00 ✗	£200.00
PAWHP: 2024 a tax credit award of £25 is below the £26 minimum	2024	£0.00	£0.00
PAWHP: 2024 a tax credit award of exactly £26 qualifies	2024	£0.00 ✗	£200.00
PAWHP: 2024 a pensioner who is neither claimant nor partner reporting a tax credit award of £25	2024	£0.00	£0.00
PAWHP: 2024 a pensioner who is neither claimant nor partner reporting a tax credit award of £26	2024	£0.00 ✗	£200.00
PAWHP: 2025 a single pensioner not on a relevant benefit gets £203.40	2025	£100.00 ✗	£203.40
PAWHP: 2025 a pensioner living with a non-dependant on ESA gets the single amount	2025	£206.80 ✗	£203.40
PAWHP: 2025 a couple under 80 not on a relevant benefit gets £101.70 each	2025	£100.00 ✗	£203.40
PAWHP: 2025 a couple aged 70 and 82 not on a relevant benefit	2025	£100.00 ✗	£305.10
PAWHP: 2025 a couple both over 80 not on a relevant benefit gets £152.55 each	2025	£100.00 ✗	£305.10
PAWHP: 2025 an 82-year-old on Pension Credit gets £305.10	2025	£310.20 ✗	£305.10
PAWHP: 2025 a pensioner on Pension Credit and one who is not, in separate benefit units	2025	£206.80 ✗	£305.10
PAWHP: 2025 the couple's payment goes to the Pension Credit claimant, which sets a lodger's shared amount	2025	£310.20 ✗	£508.50
PAWHP: 2026 a couple under 80 not on a relevant benefit gets £105.55 each	2026	£102.30 ✗	£211.10
PAWHP: 2026 a single pensioner not on a relevant benefit gets £211.15	2026	£102.30 ✗	£211.15
PAWHP: 2026 a Pension Credit couple with a partner over 80 gets one payment of £316.70	2026	£317.33 ✗	£316.70
PAWHP: 2025 the partner of an income-related ESA claimant under pensionable age is treated as entitled	2025	£206.80 ✗	£305.10
PAWHP: 2024 the partner of an income-related ESA claimant under pensionable age is entitled through the couple	2024	£200.00	£200.00
PAWHP: The Winter Fuel Payment is not paid in Scotland from 2024	2025	£100.00 ✗	£203.40

• Runs on c12f8200a:
  • policyengine-core test on tests/policy/baseline/gov, tests/policy/integration and tests/policy/reforms/parametric/winter_fuel_allowance: 1,608 passed.
  • pytest test_winter_heating_payment_properties.py: 3 passed. (test_legacy_award_readers_properties.py: 11 passed on 4f2758c5d; c12f8200a does not touch the legacy readers.)
  • CI's Test job (make test: every YAML test and the whole policyengine_uk/tests pytest suite) passed on c12f8200a.
  • ruff format --check policyengine_uk: clean.

Enhanced FRS impact

Real Microsimulation runs, both trees clean, one run at a time. The base is main at e89b8abcf, the commit merged into this branch, which includes #2027. The branch is a2a1b0355. Each run used its own fresh private copy of a dataset; the H5 inputs and per-record arrays stay private.

The branch was run again at 4f2758c5d (the round-4 fixes) and at c12f8200a (the round-5 fixes), each on fresh copies. In both, every per-record array matches the a2a1b0355 run in every year, so the figures below are unchanged.

• 2024-2030: the Enhanced FRS 2024-25 (sha256 e433e532…).
• 2023: the Enhanced FRS 2024-25 has no 2023 inputs, so 2023 uses the Enhanced FRS 2023-24 from policyengine-uk-data's storage (sha256 4c2b5e41…).

All figures are weighted totals in £m.

Year	Winter Fuel Payment, base → branch	PAWHP, base → branch	Winter payments	Cost-of-living payment	Household net income	gov_spending
2023	1,656.8 → 1,831.6	173.8 → 0.0	+1.0	+223.2	+398.0	+224.2
2024	438.3 → 441.4	34.4 → 34.7	+3.3	0	+3.0	+3.3
2025	1,700.7 → 1,701.4	106.1 → 201.1	+95.7	0	+0.7	+95.7
2026	1,689.5 → 1,690.2	108.4 → 208.2	+100.5	0	+0.7	+100.5
2027	1,643.5 → 1,644.3	109.9 → 211.2	+102.2	0	+0.9	+102.2
2028	1,618.8 → 1,619.5	112.1 → 215.5	+104.1	0	+0.8	+104.1
2029	1,614.9 → 1,615.7	114.8 → 220.7	+106.7	0	+0.7	+106.7
2030	1,603.7 → 1,604.4	117.6 → 226.2	+109.3	0	+0.7	+109.3

Where it comes from (groups of fewer than 10 survey records are not reported):

• 2023, Scotland. The Winter Fuel Payment (£174.1m) replaces "PAWHP" (£173.8m).
  • winter_fuel_allowance is in household benefits and HBAI income, and pawhp is only in gov_spending. So Scottish pensioners' winter payment now counts in household net income.
  • The cost-of-living pensioner payment qualifies on winter_fuel_allowance, so it now reaches them: +£223.2m.
  • UK-wide, pensioner poverty falls from 16.26% to 16.13% after housing costs and from 21.03% to 20.88% before. Overall poverty falls by 0.02 percentage points after housing costs and 0.03 before.
  • Elsewhere, +£0.7m for about 6,100 households with two or more pension-age benefit units.
• 2024.
  • +£3.5m for about 17,400 households whose pension-age member is on a relevant benefit only through Universal Credit or tax credits.
  • −£0.2m for about 1,100 households that qualified only through a non-dependant's award.
  • About 1,400 households with two or more pension-age benefit units net +£0.1m.
• 2025 on, Scotland. PAWHP rises by about £95-109m a year.
  • About 700,000-712,000 households gain: +£95.5m in 2025, rising to +£108.6m in 2030. These include households not on a relevant benefit, which go from the flat £100 to the legislated amounts.
  • About 130,000 households lose: −£0.57m in 2025 and −£0.07m to −£0.08m a year after. The legislated amounts for people on a relevant benefit are below the CPI projections they replace, for example £305.10 against £310.20 for 2025.
  • pawhp is in gov_spending but not in household income (Count the Pension Age Winter Heating Payment in household and HBAI income #2047 adds it), so these do not change household net income or poverty.
• 2025 on, England, Wales and Northern Ireland.
  • England: +£0.7m to +£0.9m a year for about 6,500-7,800 households, all gains. In 2025 and 2030 every one of them has two or more pension-age benefit units.
  • Wales and Northern Ireland move fewer than 10 records each, as do Universal Credit, tax credits and non-dependants' awards in any country.
• Poverty in 2024-2030 is unchanged to three decimal places.
• About 16,800 households (0.2% of the 8.8 million with a pension-age member) have pension-age members in two or more benefit units.

The 2022 qualifying week (Scotland's Winter Fuel Payment and the £300 pensioner cost-of-living payment) is not run: no 2022 dataset is at hand. policyengine-uk-data's OBR targets map the welfare line "Winter fuel payment" to winter_fuel_allowance, so a rebuild will calibrate to the new totals.

Interpretations

The model takes these readings where the law, or the data, leaves a choice. Each is documented in the code.

• PAWHP reg 10(6). It does not say whether (b) (£203.40) or (c) (£152.55) applies to an individual over 80 who lives with entitled individuals both under and over 80. The model applies (c), as SI 2025/969 reg 3(5) is "subject to paragraph (6)".
• PAWHP couples, 2025. For the 2025 week the couple rule (reg 10(8)) applied only within reg 10. So reg 9(d) ("one member of a couple ... who is entitled to a relevant benefit"), read literally, reaches only a member entitled in their own right. The model makes one payment per couple in 2025 too, as for 2024 (reg 7(2)) and from April 2026 (reg 2A).
• Mixed-age couples under "paid to". SI 2025/969's explanatory memorandum (para 5.8) says a couple's relevant-benefit payment "is made to the 'lead claimant' of the relevant means-tested benefit except in the case of a couple where only one partner has reached State Pension age in the qualifying week, in which case the payment is made to that partner".
  • The model follows the regulations' words. Universal Credit falls to be paid to both joint claimants (reg 47(4) and (6) above), so the pension-age partner of a lead claimant under that age gets the relevant-benefit rate.
  • Income Support, income-based JSA and income-related ESA are the claimant's own awards. So the pension-age partner of an under-age claimant is paid at their own rate. That is £200 alone, as the memorandum describes, but £100 beside another entitled person (reg 3(2)), where the memorandum implies the couple's £200.
• Who the claimant is. The FRS does not say who claims a couple's award. The model uses whoever reports it, else the benefit-unit head, else the elder; for Pension Credit, only among members who have attained the qualifying age.
• Living together. Everyone in a household is taken to share it as their mutual home.

Review

subfleet run --task review --tier standard:

• Round 1, on fe6aff256: REQUEST_CHANGES. Findings:

  • the couple's payee, which changes a third person's shared rate;
  • tax credits below £26 entered on the benefit unit;
  • a misworded comment on SSI 2025/282 reg 17;
  • the two PAWHP interpretations above.

  All fixed in 816bd338b, with regressions.

• Round 2, on 816bd338b: REQUEST_CHANGES (P3).

  • All round-1 items were verified fixed.
  • Two new findings: a minimum_tax_credit_award of 0 qualified everyone; the PAWHP £26 and own-report tax credit cases were untested.
  • Six nits.

  All fixed in 071d5170b. The reviewer's two surviving mutants now fail.

• Round 3, on 071d5170b: APPROVE, with no remaining findings.

• Since then: 4104aff94 added the two receipt tests after Count only the claimant's and partner's legacy awards in means tests and passports #2027 made its readers name the payee. Without it, an income-related ESA couple of pensionable age got two payments. a2a1b0355 merges main, and 17ce2368a folds the changelog.

• Round 4, on 17ce2368a (the change since round 3): REQUEST_CHANGES.

  • P1: is_on_pension_credit could make a partner under the qualifying age the payee, so a 75-year-old whose 60-year-old partner reported the award lost the relevant-benefit rate. Fixed in 4f2758c5d, with three YAML cases and the Hypothesis reference.
  • P3: the tests and this description said Universal Credit is "paid to both" without a reason, and did not explain why ESA differs. Now grounded in WRA 2012 s.1(2)(b) and reg 47(4) and (6), with the memorandum's divergence stated under Interpretations.
  • Nits: the poverty figures are UK-wide; the one-unit invariant's scope. Both fixed here.

• Round 5, on 4f2758c5d: REQUEST_CHANGES.

  • P1: the couple's payee followed any relevant-benefit report, even of an award not paid. A 67-year-old's unpaid ESA report took the payment from their 80-year-old partner, who is paid Pension Credit (£200 instead of £300). The payee is now the member a relevant benefit is paid to.
  • P1: a partner who cannot be a joint Universal Credit claimant was put on the award. Such a partner aged 72 beside a lodger got £200 instead of £100. They are now not on it.
  • P3: this description split a 2024 group into gainers and losers, and the losing side had fewer than 10 records. The split is removed.

  All fixed in c12f8200a, with two YAML regressions.

• Round 6, on c12f8200a: APPROVE, with no P1-P3 findings. One nit, the one-unit invariant's income and country limits, is fixed here.

Axiom

axiom: TheAxiomFoundation/rulespec-uk#420 queued

Of these provisions only SI 2025/969 reg 3 is in the corpus, encoded as amount parameters with no rule that selects a person's amount. Its composed pipeline (uk/policies/winter_fuel_payment_composed_award_pipeline.yaml) treats the payment as a benefit-unit amount. SI 2025/969 regs 1, 2 and 4, SI 2024/869, SI 2000/729, SSI 2024/351 and its amending instruments, and FA 2026 Sch 10 are not ingested. The issue holds the verbatim law, the required outputs, a pasteable review_finding and companion tests taken from this PR's YAML.

Follow-ups

• Charge the winter fuel payment back through income tax, person by person #2066: the winter fuel payment charge per person (ITEPA 2003 s.681I), on each person's own total income, "exceeds £35,000", Northern Ireland and PAWHP. The model now tests any pension-age member's income (< £35,000), in England and Wales only.
• Count the Pension Age Winter Heating Payment in household and HBAI income #2047: pawhp in household_benefits and HBAI income. Since Add the Scottish WFP #1000, Scottish pensioners' winter heating payment has been missing from household net income.

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