Give the UC LCWRA and carer elements, the work allowance and the benefit cap exceptions on the claimants' circumstances only

[MaxGhenis]

Stacked on #1978 (uc-claimant-only-income, which adds is_uc_assessed_claimant), itself on #1973 and #1949. Review the four commits on top of 2a8129139.

What was wrong

Universal Credit gave an award three amounts on any benefit-unit member's circumstances where the law reads only the claimant's (a single claimant, or each of two joint claimants: WRA 2012 s. 40):

• LCWRA element (uc_LCWRA_element) summed uc_limited_capability_for_WRA over every member. A disabled 10-year-old gave a lone parent the LCWRA element (£5,118.08 a year in 2026, after the rebalancing modifier) on top of the disabled child addition. Reg 27(1) includes it "in respect of the fact that a claimant has limited capability for work and work-related activity".
• Carer element (uc_carer_element) was defined_for = "benunit_has_carer", and num_carers counts every member. A 17-year-old at school caring 40 hours a week, or reporting Carer's Allowance, gave the parent the carer element (£2,512.08). Reg 29(1) includes it "where a claimant has regular and substantial caring responsibilities for a severely disabled person".
• Work allowance (is_uc_work_allowance_eligible) used benunit.any(uc_limited_capability_for_WRA). Reg 22(1)(b)(i) has no work allowance "where a single claimant does not have, or neither of joint claimants has, responsibility for a child or qualifying young person or limited capability for work".

Reading the same regulations turned up three more defects, fixed here too:

• Joint claimants who both have limited capability got two LCWRA elements. Reg 27(4)(a): "the award is only to include one LCWRA element". The rebalancing modifier already sets one amount per award for 2026 to 2029, so this changes 2025 and 2030 on.
• The carer element was one flat amount per benefit unit. Reg 29(2) gives one to each joint claimant who is a carer (unless they care for the same person), and reg 29(4) gives a carer who has limited capability only the LCWRA element, unless the other joint claimant's LCWRA element is the one included.
• The benefit cap exceptions summed every member for every exempting benefit. Reg 83(1) names "the claimant" or "a claimant" alone for ESA with the support component, industrial injuries benefit, attendance allowance and armed forces compensation payments ((a) to (e)). It adds "a child or qualifying young person for whom a claimant is responsible" only for disability living allowance (f), and "a qualifying young person" for PIP and Carer's Allowance ((g), (i), (ia)). HB Regs 2006 reg 75F(1) draws the same lines with "the claimant or the claimant's partner".

Changes (one commit each)

1. c2f0a209a uc_LCWRA_element, uc_carer_element and is_uc_work_allowance_eligible read is_uc_assessed_claimant. The cap's LCWRA exception now tests "the LCWRA element is included in the award" (reg 83(1)(a)) as uc_LCWRA_element > 0, so it follows the element.
2. 87b68c7a7 One LCWRA element per award (reg 27(4)).
3. 84bb07808 One carer element for each claimant who is a carer (reg 29(2)), none for a carer with limited capability unless the other joint claimant's LCWRA element is the one included (reg 29(4)). The model does not record who is cared for, so it takes two carers to care for different people, as it already does when it pays each of them Carer's Allowance.
4. 672e1e555 Benefit cap: ESA, industrial injuries benefit, attendance allowance and AFCS exempt the award only when a claimant receives them. DLA stays claimant-or-child, PIP and Carer's Allowance or Carer Support Payment claimant-or-qualifying-young-person.
5. 0ef77e453 The disability_basic_income contrib reform (off by default) pays for "receiving" the LCWRA element, so it now needs a claimant with limited capability, not any member with the flag.

Not changed: num_carers, benunit_has_carer and is_carer_for_benefits. uc_carer_element no longer reads the shared variables, so their other readers are untouched:

• carer_minimum_guarantee_addition and income_support_eligible are restricted to the claimant or partner by Replace generic child and adult flags with each programme's legal definitions #1896 (the PC addition) and its stack.
• uc_non_dep_deduction_exempt is about the non-dependant's own caring, which is right.
• carer_premium still counts every member, against IS Regs 1987 Sch 2 para 14ZA ("the claimant or his partner is, or both of them are, entitled to a carer's allowance"). Fixing it needs Replace generic child and adult flags with each programme's legal definitions #1896's is_claimant_or_partner, so it is a separate follow-up.

uc_limited_capability_for_WRA is still is_disabled_for_benefits by default (DLA or PIP receipt in the data). This PR changes whose flag counts, not the proxy.

Law

From legislation.gov.uk CLML (/data.xml), current revised text, fetched 2026-10-01.

UC Regs 2013 regs 22(1), 27, 29(1), (2), (4), 30(1), 83(1); HB Regs 2006 reg 75F(1); WRA 2012 ss. 12(1)-(2), 40

WRA 2012 s. 12:

(1) The calculation of an award of universal credit is to include amounts in respect of such particular needs or circumstances of a claimant as may be prescribed.
(2) The needs or circumstances prescribed under subsection (1) may include— ... (b) the fact that a claimant has limited capability for work and work-related activity; (c) the fact that a claimant has regular and substantial caring responsibilities for a severely disabled person.

WRA 2012 s. 40:

“claimant” means a single claimant or each of joint claimants;
“joint claimants” means members of a couple who jointly make a claim or in relation to whom an award of universal credit is made;

Reg 22(1)(b):

the following amount of the claimant’s earned income (or, in the case of joint claimants, their combined earned income) in respect of the assessment period— (i) in a case where no work allowance is specified in the table below (that is where a single claimant does not have, or neither of joint claimants has, responsibility for a child or qualifying young person or limited capability for work), 55% of that earned income; or (ii) in any other case, 55% of the amount by which that earned income exceeds the work allowance specified in the table.

Reg 27:

(1) An award of universal credit is to include an amount in respect of the fact that a claimant has limited capability for work and work-related activity (“the LCWRA element”).
...
(4) In the case of joint claimants, where each of them has limited capability for work and work-related activity, (a) the award is only to include one LCWRA element , and (b) where the LCWRA element for each of them is a different amount, the LCWRA element to be included is the higher amount.

Reg 29:

(1) An award of universal credit is to include an amount (“the carer element”) specified in the table in regulation 36 where a claimant has regular and substantial caring responsibilities for a severely disabled person, but subject to paragraphs (2) to (6) and section 70 of the Contributions and Benefits Act ...
(2) In the case of joint claimants, an award is to include the carer element for both joint claimants if they both qualify for it, but only if they are not caring for the same severely disabled person.
...
(4) Where an amount would, apart from this paragraph, be included in an award in relation to a claimant by virtue of paragraphs (1) to (3), and the claimant has limited capability for work and work-related activity (and, in the case of joint claimants, the LCWRA element has not been included in respect of the other claimant), only the LCWRA element may be included in respect of the claimant.

Reg 30(1)-(2):

(1) ... a person has regular and substantial caring responsibilities for a severely disabled person if— (a) they satisfy the conditions for entitlement to a carer’s allowance or would do so but for the fact that— (i) their earnings have exceeded the limit prescribed for the purposes of that allowance; or (ii) they are— (aa) resident, or treated as resident, in Scotland; or (bb) resident outside of Great Britain and have a genuine and sufficient link to Scotland; or (b) they are entitled to carer support payment.
(2) Paragraph (1)(a) applies whether or not the person has made a claim for a carer's allowance.

Reg 83(1):

The benefit cap does not apply in relation to any assessment period where— (a) the LCWRA element is included in the award of universal credit or the claimant is receiving an employment and support allowance that includes the support component; (b) a claimant is receiving industrial injuries benefit; (c) a claimant is receiving attendance allowance; (ca) a claimant is receiving pension age disability payment; (d) a claimant is receiving a war pension; (e) a claimant is receiving a payment under article 15(1)(c) or article 29(1)(a) of the Armed Forces and Reserve Forces (Compensation Scheme) Order 2011; (f) a claimant, or a child or qualifying young person for whom a claimant is responsible, is receiving disability living allowance; (fa) a claimant, or qualifying young person for whom a claimant is responsible, is receiving Scottish adult disability living allowance; (g) a claimant, or a qualifying young person for whom a claimant is responsible, is receiving personal independence payment; (h) [entitled but not receiving, in hospital or a care home] ... (ha) a claimant, or a child or qualifying young person for whom a claimant is responsible, is receiving child disability payment; (hb) a claimant, or qualifying young person for whom a claimant is responsible, is receiving adult disability payment; (i) a claimant, or a qualifying young person for whom a claimant is responsible, is entitled to carer’s allowance; (ia) a claimant, or a qualifying young person for whom a claimant is responsible, is entitled to carer support payment; (j) the carer element is included in the award of universal credit; (k) a claimant is entitled to guardian’s allowance under section 77 of the Contributions and Benefits Act.

HB Regs 2006 reg 75F(1), the same split for Housing Benefit:

(a) the claimant or the claimant’s partner is receiving an employment and support allowance under Part 1 of the Welfare Reform Act which includes a support component; (b) the claimant or the claimant’s partner is receiving an industrial injuries benefit ...; (c) the claimant or the claimant’s partner is receiving an attendance allowance; ... (e) the claimant, the claimant’s partner or a child or young person for whom the claimant or the claimant’s partner is responsible, is receiving a disability living allowance; ... (ea) the claimant, the claimant’s partner or a young person for whom the claimant or the claimant’s partner is responsible, is receiving a personal independence payment, adult disability payment or an armed forces independence payment ...; ... (h) the claimant, the claimant’s partner, or a young person for whom the claimant or the claimant’s partner is responsible, is entitled to a carer’s allowance under section 70 of the Act;

Reg 36 table (2026-27, a month): LCWRA element £217.26 (or £429.80 for a pre-2026 claimant, a severe conditions criteria claimant or a terminally ill claimant), carer element £209.34, disabled child addition lower rate £164.79. For 2025-26: LCWRA £423.27, carer £201.68. Reg 22 table, 2026-27: £710 higher and £427 lower work allowance.

DWP's Advice for Decision Making chapter F6, para F6037, tabulates which of the two elements an award includes for each combination. It is guidance, not law, and it matches regs 27(4) and 29(2), (4); the property tests check the model against it.

Tests

YAML (expected values hand-computed from the reg 36 and reg 22 tables):

• uc_carer_element.yaml: 18 cases, replacing two that set benunit_has_carer directly, which the element no longer reads. They cover reg 29(1) (a 17-year-old QYP who is a carer, by hours or by reported Carer's Allowance → 0), reg 30(2) (no claim needed), a third flagged claimant, reg 29(2) (two carers → 2 × 209.34 × 12 = £5,024.16) and every reg 29(4) combination.
• uc_LCWRA_element.yaml: 9 new cases. A disabled child → 0, with the disabled child addition of £1,977.48; a disabled QYP; a disabled parent of a disabled child → £2,607.12 + £1,977.48; reg 27(4), both claimants → one element (£5,079.24 in 2025-26, £2,607.12 in 2026-27); a third flagged claimant.
• is_uc_work_allowance_eligible.yaml and uc_work_allowance.yaml: limited capability of a single claimant or one joint claimant gives the work allowance (£8,520 / £5,124); a non-qualifying 17-year-old's, a third flagged claimant's or a looked-after child's does not.
• New gov/dwp/benefit_cap/benefit_cap_exempt_whose_circumstances.yaml: 14 cases covering reg 83(1)(a), (b), (e), (f), (g), (i), (j). A dependant's IIB, ESA or AFCS → not exempt; the claimant's or partner's → exempt; a child's DLA, a QYP's PIP and a QYP's Carer's Allowance entitlement → exempt; a disabled child without DLA → not exempt.

Hypothesis (policyengine_uk/tests/test_uc_claimant_elements_properties.py). The populations are single claimants and couples (25-64) with up to four dependants aged 0-19, in or out of education, each randomly disabled, with LCWRA, caring 0/20/35/60 hours, reporting Carer's Allowance, and receiving ESA, IIB or AFCS. Rent varies, across England, Wales and Scotland, for 2025 and 2026. Invariants:

1. A dependant's disability or caring never changes uc_LCWRA_element, uc_carer_element, is_uc_work_allowance_eligible or uc_work_allowance. Each dependant's four circumstances are cleared and the outputs must be identical.
2. Differential against DWP's F6037 table, all 16 two-claimant combinations of carer/LCWRA. The number of each element matches the table; the carer amount equals 12 × £201.68 / £209.34 per element, and the 2025-26 LCWRA amount equals 12 × £423.27, written from reg 36, not read from the model. The work allowance is present exactly when a claimant has limited capability or a dependant is a child or QYP.
3. Bounds: at most one LCWRA element, at most one carer element per claimant, and LCWRA plus carer elements ≤ claimants.
4. Monotonicity: giving the claimants limited capability never lowers LCWRA + carer elements or the work allowance.
5. Member order does not change the elements.
6. Benefit cap: a dependant's ESA, IIB or AFCS never changes is_benefit_cap_exempt, benefit_cap_reduction or universal_credit for capped families; a child's DLA always exempts, without an LCWRA element, and the same families without it are not exempt.

Intended violations: none. Before this PR, invariants 1, 2 (reg 29(2), (4) rows, and reg 27(4) in 2025), 3 and 6 fail. The household probes below show the counterexamples, minimised to one family each.

Household probes

Synthetic households, Simulation, council rent £18,000, North East. 2026 amounts include the UC rebalancing modifier, which sets an existing claimant's LCWRA element to the protected amount (£5,118.08). Base is the #1978 head 2a8129139, branch 672e1e555.

Household	Year	LCWRA element	Carer element	Work allowance	Cap exempt	UC
Lone parent 40, disabled child 10	2026	5,118.08 → 0	0	yes	yes → no	34,416.91 → 20,613.40
Lone parent, QYP 17 caring 40 h	2026	0	2,512.08 → 0	yes	yes (reg 83(1)(i))	29,833.44 → 27,321.36
Single 40, non-QYP 17-year-old with LCWRA	2026	5,118.08 → 0	0	yes → no	yes → no	28,216.88 → 22,020.00
Couple + 22-year-old with LCWRA, all three flagged claimants	2026	5,118.08 → 0	0	yes → no	yes → no	31,121.71 → 22,020.00
Couple, both LCWRA	2025	10,158.48 → 5,079.24	0	yes	yes	35,695.68 → 30,616.44
Couple, both caring 40 h	2026	0	2,512.08 → 5,024.16	no	yes	19,524.92 → 22,037.00
Single carer with LCWRA	2026	5,118.08	2,512.08 → 0	yes	yes	26,233.55 → 23,721.47
Couple: carer with LCWRA, partner with LCWRA	2026	5,118.08	2,512.08 (kept)	yes	yes	unchanged
Couple: carer with LCWRA, partner neither	2026	5,118.08	2,512.08 → 0	yes	yes	29,138.40 → 26,626.31
Capped family (lone parent, 4 children, QYP 17), QYP on IIB	2026	0	0	yes	yes → no	41,910.48 → 16,890.20
Same, QYP on contributory ESA	2026	0	0	yes	yes → no	41,910.48 → 16,890.20
Same, child on DLA	2026	0	0	yes	yes (reg 83(1)(f))	unchanged
Same, QYP on PIP	2026	0	0	yes	yes (reg 83(1)(g))	unchanged
Same, claimant on IIB	2026	0	0	yes	yes (reg 83(1)(b))	unchanged

Enhanced FRS impact

Real Microsimulation runs on a private copy of the 2024-25 Enhanced FRS used for the #1978 runs (sha256 e433e532…). There is one run per commit: the base 2a8129139 (the #1978 head) and each of the four commits. Every figure below comes from those six runs (no scaling). Aggregates only.

	2025	2026	2027	2028	2029	2030
UC, base (£bn)	79.41	83.72	85.60	87.19	88.23	85.13
UC, this PR (£bn)	76.14	81.32	83.15	84.69	85.78	83.19
Change (£bn)	-3.27	-2.40	-2.45	-2.50	-2.46	-1.94
1. elements and work allowance for claimants only (regs 27(1), 29(1), 22(1)(b))	-2.817	-2.063	-2.102	-2.145	-2.093	-1.504
2. one LCWRA element for joint claimants (reg 27(4))	-0.128	+0.000	+0.000	+0.000	+0.000	-0.062
3. carer element per carer claimant; none with LCWRA (reg 29(2), (4))	-0.323	-0.337	-0.346	-0.354	-0.363	-0.371
4. benefit cap: claimant-only ESA, IIB, AA, AFCS (reg 83(1)(a)-(e))	+0.000	+0.000	+0.000	+0.000	+0.000	+0.000
Benefit units losing (k)	648	576	578	580	582	626
Benefit units gaining (k)	0	0	0	0	0	0
Benefit units leaving UC (k)	17.7	16.3	16.3	16.1	16.1	13.6
Mean loss per losing unit (£/yr)	5,045	4,164	4,233	4,305	4,222	3,093
Household net income (£bn)	-3.27	-2.40	-2.45	-2.50	-2.46	-1.94

2026	base	this PR
UC awards with an LCWRA element (k)	2,199	1,757
LCWRA element in UC awards (£bn)	10.48	8.38
UC awards with a carer element (k)	678	543
Carer element in UC awards (£bn)	1.70	1.36
UC caseload (k)	6,517	6,500
Benefit cap reduction (£bn)	1.422	1.422
Poverty AHC, all	18.46%	18.67%
Poverty AHC, children	23.15%	23.65%
Poverty AHC, working-age adults	18.94%	19.09%
Poverty BHC, children	16.00%	16.55%

2026 split by household origin: FRS-origin -2.083bn, SPI-synthetic -0.316bn.

How to read it:

• Step 1 is all children's DLA. Every non-claimant member with the limited-capability flag in benefit units on UC receives DLA or PIP, because the flag defaults to is_disabled_for_benefits, which the data set from DLA or PIP receipt. In 2026 these are 466k weighted children under 16 and 82k young people aged 16 to 19. So those awards lose the LCWRA element but keep the disabled child addition. They also stay exempt from the cap through the child's DLA or the QYP's PIP (reg 83(1)(f), (g)): no benefit unit on UC changes cap status.
• Step 2 moves only 2025 and 2030, because the rebalancing modifier already sets one LCWRA amount per award for 2026-29.
• Step 3: 134k awards (2026) where a claimant who is a carer also has limited capability lose the carer element. Nobody gains: no benefit unit on UC in the data has two claimants who are both carers without limited capability, so reg 29(2) adds nothing on this dataset.
• Step 4 changes the component exemption flags of 26k (health and disability) and 67k (other) benefit units. Overall exemption changes for 0.9k, none of them on UC, so no award moves.
• policyengine-uk-data calibrates the weights to OBR UC spending and caseloads (targets/build_loss_matrix.py, storage/tax_benefit.csv). A dataset rebuilt on this model would reweight towards those totals; the figures here are on the current weights.

Overlaps

• Replace generic child and adult flags with each programme's legal definitions #1896 (remove-is-child-flags) rewrites the has_children lines of is_uc_work_allowance_eligible, next to the has_LCWRA line this PR changes, so whichever merges second gets a textual conflict. Resolution: keep Replace generic child and adult flags with each programme's legal definitions #1896's has_children and this PR's has_LCWRA. Replace generic child and adult flags with each programme's legal definitions #1896 makes is_uc_claimant is_claimant_or_partner, which is_uc_assessed_claimant reads unchanged. Replace generic child and adult flags with each programme's legal definitions #1896 does not touch the element or benefit cap files.
• Fix benefit cap exemption defects (#1818) #1820 (benefit cap exemption defects) deletes the unused earnings code in is_benefit_cap_exempt_health_disability and _other and adds armed_forces_independence_payment. Resolution: keep Fix benefit cap exemption defects (#1818) #1820's deletions and put AFIP in the claimant-or-QYP list, with PIP, as HB reg 75F(1)(ea) groups it.
• Apply the benefit cap to mixed-age couples on Universal Credit, and keep them off pensioner Council Tax Reduction #1944 (mixed-age benefit cap) rewrites is_benefit_cap_exempt_other. Resolution: keep Apply the benefit cap to mixed-age couples on Universal Credit, and keep them off pensioner Council Tax Reduction #1944's pension_age_housing_benefit and this PR's claimant-only AFCS and ESA lines.
• Follow-ups not in this PR:
  • carer_premium counts every member (IS Regs Sch 2 para 14ZA: "the claimant or his partner"); it needs Replace generic child and adult flags with each programme's legal definitions #1896's is_claimant_or_partner.
  • is_severely_disabled_for_benefits treats any AFCS payment as severe disability, which gives a child the higher disabled child addition.

Axiom

axiom: pending. A Subfleet lane is checking uk/regulations/uksi/2013/376/22, /27 and /29. They take per-claimant inputs, so they look encoded-correct, but they need companion cases for reg 27(4), 29(2), 29(4) and the reg 22 LCW-only work allowance. The lane is also checking the UC ProgramSpec, which sums the carer element over adult_of_benefit_unit, and reg 83, which has no module (TheAxiomFoundation/rulespec-uk#389). This line will be replaced with the final route.

Verification

• policyengine-core test policyengine_uk/tests/policy: 1,394 passed (at 672e1e555). The contrib test file, re-run after 0ef77e453, passed 9 of 9.
• Property tests and the full pytest suite: results to follow in a comment.
• CI does not run on this branch, because its base is not main.

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