Apply Housing Benefit and national Council Tax Reduction non-dependant deductions as legislated

[MaxGhenis]

Fixes #2004. Also fixes the non-dependant half of #1934; its pensioner-gate half stays open.

Summary

Housing Benefit and the national Council Tax Reduction schemes now make non-dependant deductions the way the regulations set them. Law was read on legislation.gov.uk at the 7 April 2025 point in time, plus each year's version for the CTR scales.

Housing Benefit (SI 2006/213 reg 74; SI 2006/214 reg 55 is the same for these rules):

Rule	Before	Now
Banding, reg 74(2)	right=True, so £192.00 a week fell in the band below and £0 paid nothing	Bands include their lower edge ("not less than"). An in-work non-dependant with no income pays the reg 74(1)(b) amount
Remunerative work, reg 74(1)-(2), reg 6(1) and (6)	Everyone banded on their own income	Only a non-dependant working 16+ hours, and not on IS, JSA(IB) or ESA(IR), is banded. Anyone else pays the (1)(b) amount (£20.40 a week in 2026-27)
Couples, reg 74(3)-(4)	Each member charged, on their own income	One deduction for the couple, the higher, banded on the couple's joint income. Any other adult in the family (for example a young person on approved training) is a separate non-dependant on their own income
Non-dependant exemptions, reg 74(7), (8), (10)	None	Full-time students; State Pension Credit recipients; under-25s on Income Support, income-based JSA, or Universal Credit calculated on no earned income
Claimant exemption, reg 74(6)	None	No deduction for anyone if the claimant or partner is blind or receives AA, the DLA care component, the PIP daily living component or AFIP

Council Tax Reduction: the England pensioner (SI 2012/2885 Sch 1 para 8), Welsh (WSI 2013/3029 Sch 1 para 3 and Sch 6 para 5) and Scottish (SSI 2012/319 reg 48; SSI 2012/303 reg 67, then SSI 2021/249 reg 90) schemes.

• Scales. These used the Housing Benefit scale. Each scheme now has its own weekly scale for 2013-14 to 2026-27, with the amending instrument cited for every year.
  • 2026-27: England £5.20 to £15.95 on £279/£485/£605; Wales £6.70 to £20.05 on the same bands; Scotland £5.55 to £16.55 on £286/£497/£614. The HB scale was £20.40 to £131.45.
  • Pensioner and working-age scales are identical in Wales and in Scotland in every year.
  • From 2027-28 the scales are uprated by gov.benefit_uprating_cpi, as Set DWP benefit rates to the announced amounts, not CPI projections #1925 does for the HB scale.
• Banding and couples. As for HB. In addition, Wales's working-age scheme deducts for both members of a couple with a Universal Credit award (Sch 6 para 5(3), "other than where there is an award of universal credit"). I read that award as the non-dependant couple's.
• Exemptions, at any age (para 8(7)-(8) and equivalents):
  • full-time students;
  • non-dependants on IS, income-based JSA, income-related ESA or State Pension Credit;
  • an adult for whom someone else is entitled to child benefit (LGFA 1992 Sch 1 para 3, via para 8(8)(b) and equivalents);
  • from the year each scheme added it, Universal Credit calculated on no earned income: England 2015-16 (SI 2014/3312), Wales 2015-16 (WSI 2015/44), Scotland 2016-17 (SSI 2016/81).
• Applicant exemption (para 8(6)): council_tax_reduction_household_has_non_dep_exemption existed but only the local schemes used it. It now applies to the national schemes too.
• English working-age local schemes (Merton, Kingston, Newham, Westminster, Oxford) keep their own variables. They share council_tax_reduction_individual_non_dep_deduction_eligible, so the national exemptions are applied inside council_tax_reduction_individual_non_dep_deduction, not there.

New variables:

• housing_benefit_non_dep_deduction_exempt (Person)
• housing_benefit_non_dep_deductions_claimant_exempt (BenUnit)
• council_tax_reduction_non_dep_deduction_exempt (Person)

New parameters:

• HB remunerative_work_hours (16)
• HB income_related_benefit_age_limit (25)
• per CTR scheme, non_dep_deduction/{amount, remunerative_work_hours, exempt_universal_credit_without_earned_income}

HB age_threshold (18) now starts in 2006, when the 2006 Regulations were made, not 2019.

Inputs and choices

• Full-time student: current_education != NOT_IN_EDUCATION or in_HE, the helper the local schemes already use. In the Enhanced FRS, current_education comes from FTED/EDUCFT ("in full-time education"), so it is the full-time flag. Note the age-based default: with no input, an 18- or 19-year-old is in tertiary education and so exempt.

• Claimant or partner: the benefit unit's head, or any member who is not an SSCBA s.142 child or qualifying young person (is_child_or_qualifying_young_person_for_child_benefit, already on main). That is how HB Regs 2006 regs 2(1) and 19 and the English and Welsh CTR regulations (reg 2(1)) define a family's members other than the claimant and partner. It is used for:

  • the claimant exemption (HB, and council_tax_reduction_household_has_non_dep_exemption, which the English local schemes also read);
  • joint income, which counts only the couple;
  • the one-deduction-per-couple rule, which covers only the couple, while any other member is deducted separately;
  • benefit-receipt exemptions, which count only for the claimant or partner of the award.

• Gross income: for a claimant or partner of the non-dependant's family, the couple's taxable income (total_income, floored at zero) plus the family's UC, CTC, WTC and child benefit. For anyone else in the family, their own taxable income.

  • UC is taken after the benefit cap (UC reg 81). The cap is applied to the capped benefits other than Housing Benefit, which a non-dependant family does not receive. universal_credit itself depends on HB through the cap, so using it would be circular.
  • The disability benefits disregarded by reg 74(9) are untaxed and not added.
  • Other untaxed income the regulations count, such as maintenance, is not added.

• On a benefit: the IS, JSA(IB), ESA(IR) and SPC exemptions, and HB reg 6(6), apply only to the person the award is payable to (HB reg 2(3)-(3A), "payable to him"). That is the member who reports the award, or the benefit unit's head where none does. UC counts for both joint claimants (reg 2(3B), entitlement).

• HB reg 6(6): a claimant or partner of an IS, JSA(IB) or ESA(IR) award is treated as not in remunerative work, so pays the lowest amount whatever their hours.

• UC entitlement: universal_credit_pre_benefit_cap > 0, because universal_credit depends on Housing Benefit through the benefit cap and would be circular.

• "Earned income" in the UC limb (UC regs 52-62):

  • employment income plus statutory sick and maternity pay, less relievable pension contributions (reg 55(4)-(5));
  • self-employed earnings, with a loss counting as nil (reg 57(2)) and the minimum income floor where the UC model applies it (reg 62);
  • other paid work.

  Testing the person's own earnings rather than a joint award's is an interpretation. The limb reads "the award is calculated on the basis that the non-dependant does not have any earned income", and a joint award is calculated on combined earnings (UC reg 22(1)(b)). I found no DWP guidance that settles it. The local-scheme work on Charge non-dependant deductions for non-dependants within the claimant's benefit unit #2017 keeps the couple reading for the five English local schemes.

Not modelled (no input)

• Pension-age HB's 26-week deferral of a deduction increase (SI 2006/214 reg 59(10)-(13)), and the CTR applicant exemption's protection while AA, DLA or PIP is suspended in hospital (para 8(6)).
• HB: a working full-time student's summer vacation (reg 74(7)(d)), and under-25s on assessment-phase income-related ESA (no ESA group input).
• Wales: ESA(IR) recipients in the work-related activity group, who are not exempt. They are treated as exempt.
• CTR: persons disregarded for council tax discounts (LGFA 1992 Sch 1) other than students and, under para 3, adults for whom someone else is entitled to child benefit, which is modelled. is_apprentice has no £195 earnings cap, so it isn't used.
• All schemes: youth training allowances, a normal home elsewhere, long hospital stays, prison, armed forces operations, and joint-occupier apportionment (reg 74(5), para 8(5)). Apportionment is Give sharers, boarders and lodgers their own rent, tenure and LHA category #2006.
• Scottish disability assistance (ADP, PADP, CDP, Scottish adult DLA) for the claimant exemption, which has no separate input.
• Before 2015 the model reads parameters at 1 January, not in fiscal years. That is unchanged.

Review

• Round 1 (independent Subfleet review of 59c7082, Opus 5.5 after a rate-limited first attempt) asked for changes.

  • It found five P1s:
    1. is_adult as claimant or partner;
    2. a dependent child's income counted as the couple's;
    3. HB reg 6(6);
    4. self-employed losses cancelling wages in the UC test;
    5. UC, tax credits and child benefit missing from gross income.
  • It also found two omissions to disclose.
  • All are fixed in this head, each with a test that fails on 59c7082 (non_dependant_deduction_review_cases.yaml and new cases in household_benefits_individual_non_dep_deduction.yaml). The response is in the PR thread.

• What round 1 confirmed: 288 CTR fixture and parameter comparisons and the 11 HB 2026-27 values; no leak into the five English local schemes; no dependency cycle in 48 household-years; the full HB, UC and local-authority YAML suites passing.

• Round 2 (Subfleet review of 6257277) asked for changes. Fixed in e92b5d1, each with a test that fails on 6257277 (the "Round 2" section of non_dependant_deduction_review_cases.yaml):

  • UC earned income per regs 55 and 62: SMP, pension contributions and the minimum income floor;
  • benefit awards counted only for the person they are payable to;
  • UC after the benefit cap in gross income;
  • the LGFA Sch 1 para 3 disregard.

• Explicit young partners (round 2's identity finding): fixed by adopting Replace generic child and adult flags with each programme's legal definitions #1896's is_claimant_or_partner, which caps the set at the head and one partner, when Replace generic child and adult flags with each programme's legal definitions #1896 lands. Replace generic child and adult flags with each programme's legal definitions #1896's owner asked for this.

• The round 1 and round 2 responses are in the PR thread.

Invariants

These hold for every input:

1. An exempt non-dependant's deduction is zero, for HB and for CTR.
2. An eligible, non-exempt non-dependant pays between the scale's lowest and highest amounts. The national CTR deduction is zero in English working-age households.
3. A non-dependant working under 16 hours pays the lowest amount, whatever their income.
4. A claimant or applicant exemption zeroes the family's deductions.
5. A family's deductions are the sum over the other families in the household of their higher member's amount (both members for a Welsh working-age UC couple), recomputed independently.
6. Monotonicity: raising a non-dependant's income never lowers any deduction.
7. Exhaustively, in every year 2015-2030 (2019-2030 for HB), uprated years included: an income at a band's lower edge pays that band's amount, and the next lower representable income pays the band below's.
8. Differential: every CTR parameter value equals the enacted sums in tests/fixtures/council_tax_reduction_non_dependant_deductions.yaml.
9. Differential: the exemption flags equal a reading of the provisions computed straight from the inputs.

Tests

• YAML (all with hand-worked expectations from the law):

  • HB: band edges in and out of remunerative work, couples, a dependent child's income, each exemption and its age boundary, each claimant exemption (and that a child's DLA doesn't count), and aggregation.
  • The Set DWP benefit rates to the announced amounts, not CPI projections #1925 review's counterexample, end to end: a 40-year-old claimant with £6,000 rent and a zero-income 20-year-old full-time student gets HB £6,000 (Set DWP benefit rates to the announced amounts, not CPI projections #1925 alone would have given £4,978.20).
  • CTR: each scheme's band edges (2026-27, plus 2025-26 spot checks), not in remunerative work, every exemption at age 40, the UC-limb start dates, couples including the Welsh UC rule, the applicant exemption, English working-age households, and National council tax reduction: non-dependant deductions use Housing Benefit amounts and skip exemptions; pensioner gate ignores benefit exclusions #1934's example end to end. That example is a guarantee credit pensioner whose son earns £30,000 working 37.5 hours: the deduction is £691.60 a year, not the HB scale's £6,232.20, and CTR is £1,308.40.
  • Two existing tests change:
    • the pension-credit CTR case now uses England's £5.20 (it was the HB scale's £20.40);
    • an HB eligibility case now sets current_education and would_claim_uc: false (an income-free 18-year-old is otherwise entitled to UC without earned income, and so exempt).

• test_non_dependant_deduction_properties.py: Hypothesis populations for invariants 1-6 and 9 (with explicit examples for the rare Welsh-couple and under-25 cases), the exhaustive edge check (7), and the fixture differential (8).

• Scale verification: an independent check (Subfleet, GPT-6.1 Sol) of all 294 CTR scale values against the amending instruments as made returned ALL MATCH, 42 scheme-years. It also confirmed that every instrument applies from 1 April, and that Wales's and Scotland's pensioner and working-age scales are identical. Three drafting points don't change any value:

  • the Welsh-language text of WSI 2016/50 has £195 where the English has £194 (the parameter uses the English text and says so);
  • SI 2012/3085 left "x 1/7" off two 2013-14 English band amounts;
  • SSI 2021/249 saves the 2021-22 working-age scale for 1-3 April 2022.

• Mutation testing (run on 59c7082; rerun on this head pending): 12 hand-made mutations:

  • HB: right-closed bands; exemptions dropped; couples summed; claimant exemption off; remunerative work ignored; under-25 limit off.
  • CTR: exemption off; right-closed bands; Welsh UC couples not summed; applicant exemption off; deduction falling with income; UC limb always on.

  The YAML suites kill all 12; the property tests kill 11. The UC-limb mutation survives them by design: they draw 2025-30, when every limb applies, and the 2014-16 YAML cases kill it.

• Commands:

  • policyengine-core test policyengine_uk/tests/policy/baseline/finance/benefit/family/{housing_benefit,universal_credit} policyengine_uk/tests/policy/baseline/gov/local_authorities -c policyengine_uk: 348 passed.
  • pytest test_non_dependant_deduction_properties.py test_parameter_descriptions.py test_parameter_metadata.py test_fiscal_year_parameters.py test_council_tax_reduction_pension_credit_properties.py test_carer_support_payment.py test_lha_freeze.py test_build_metadata.py: all passed.
  • ruff format / ruff check on the changed files.

  Targeted tests only. The full suite is left to CI.

Impact (Enhanced FRS 2024-25)

Real runs of main (7b9fc37) and this branch (6257277) on the same dataset. Nothing is scaled. The round-1 review fixes change no survey record's HB or CTR award: both are identical record by record to the run of 59c7082. They change only the computed deductions of families that receive neither benefit.

Change	2025-26	2026-27	2027-28	2028-29	2029-30	2030-31
Housing Benefit (£m)	+7.0	+7.5	+7.5	+8.1	+8.8	+8.9
Council Tax Reduction (£m)	+3.1	+3.1	+3.4	+3.6	+3.8	+4.1
Household net income (£m)	+10.1	+10.5	+10.9	+11.7	+12.6	+12.9
HB families gaining (k)	4.1	4.2	4.2	4.2	4.5	4.5
HB mean gain (£ a year)	2,270	2,394	2,408	2,415	2,378	2,385
HB families losing (k)	2.2	2.2	2.2	1.8	1.6	1.6
HB mean loss (£ a year)	1,075	1,136	1,136	1,155	1,162	1,162
CTR families gaining (k)	2.9	3.1	3.1	3.1	3.1	3.7
CTR mean gain (£ a year)	1,041	999	1,093	1,155	1,221	1,103
CTR caseload (k)	+2.2	+2.3	+2.3	+2.3	+2.4	+2.9
People in poverty, BHC (k)	+0.0	+0.0	+0.9	+0.9	+0.9	+0.9
People in poverty, AHC (k)	+0.0	+0.0	+0.0	+0.0	-0.0	+0.0

• No CTR family loses. Universal Credit and Pension Credit don't change.

• 2025-26 uses main's 2025 HB scale, which Set DWP benefit rates to the announced amounts, not CPI projections #1925 corrects.

• Housing Benefit, decomposed. Separate real runs of this branch for 2026-27, adding one part at a time (variable overrides in a separate process per run):

  Step	HB (£m)
  Inclusive bands alone, everyone banded on their own income	-7.4
  Only remunerative work banded (reg 6(6) included), on the couple's gross income including family UC, tax credits and child benefit	+0.9
  One deduction per couple, other members separate	0.0
  Non-dependant exemptions	+4.2
  Claimant exemption	+9.7
  Total	+7.5

  • The first step is the "banding fix alone" that the Set DWP benefit rates to the announced amounts, not CPI projections #1925 review measured at −£7m to −£8m.
  • The couple step is zero because no non-dependant couples live with HB recipients in this dataset. The tests cover the rule.
  • The last step reproduces the branch run to the penny.

• Who is affected. About 14k non-dependants live with HB recipients:

  • 3.6k are now exempt;
  • 11.3k work under 16 hours a week, so pay the lowest amount whatever their income;
  • the deductions taken from HB recipients fall from £14.1m to £5.9m (2026-27).

• HB losers. The losers are households whose non-dependant has no income, is not exempt, and now pays the lowest amount (£20.40 a week in 2026-27). Before, zero income paid nothing. Those losses put 0.9k people below the BHC line from 2027-28; the poverty line itself doesn't change.

• Council Tax Reduction.

  • England pensioner scheme only. All of the change is there. In the survey records, about nine in ten Welsh and Scottish applicant families with non-dependants have income above their applicable amount, and fewer than one in ten are modelled as claiming. So smaller deductions rarely create an award.
  • Where deductions disappear. Among CTR recipients in the national schemes, deductions fall from £14.9m to under £0.1m. About two-thirds of recipient households with non-dependants have an applicant or partner who is blind or on AA, DLA care, PIP daily living or AFIP. Most of the other non-dependants are exempt themselves.

Merge order and overlaps

• Set DWP benefit rates to the announced amounts, not CPI projections #1925 (DWP rates) sets the 2025-26 HB bands and amounts and edits household_benefits_individual_non_dep_deduction.yaml.
  • This PR's HB tests use 2026-27, where main and Set DWP benefit rates to the announced amounts, not CPI projections #1925 agree, plus the 2025 counterexample, which is exempt so it doesn't depend on the amount.
  • Whichever merges second takes this PR's version of that test file.
  • Set DWP benefit rates to the announced amounts, not CPI projections #1925 already defers the formula change to this PR.
• Give sharers, boarders and lodgers their own rent, tenure and LHA category #2006 (draft, boarders and lodgers) changes who is charged (UC head-only, HB rent share, CTR joint-liability share), and touches the same two aggregation variables. We agreed how they compose: this PR's per-family amount and exemption, times Give sharers, boarders and lodgers their own rent, tenure and LHA category #2006's shares. Whoever lands second rebases.
• Branch ctr-claimant-household-head (stacked on Give sharers, boarders and lodgers their own rent, tenure and LHA category #2006) makes the CTR applicant the family holding is_household_head, not every family tied for oldest. It also excludes every claimant family from non-dependant eligibility. The changes compose, since this PR doesn't touch either variable, and its CTR tests make the applicant strictly oldest. Older relatives it reclassifies as non-dependants get this PR's scheme scales and exemptions (including SPC). Whichever lands second reruns its impact.
• Replace generic child and adult flags with each programme's legal definitions #1896 adds a general is_claimant_or_partner. This PR uses the HB and CTR legal definition (s.142, plus the benefit unit's head) and changes council_tax_reduction_household_has_non_dep_exemption from is_adult to it, which Replace generic child and adult flags with each programme's legal definitions #1896 also edits. Whichever merges second takes one definition.
• Give Scotland and Wales working-age council tax reduction their own rules (UC routes, passport, child amounts) #1966 (Scotland and Wales working-age CTR) deferred non-dependant deductions to National council tax reduction: non-dependant deductions use Housing Benefit amounts and skip exemptions; pensioner gate ignores benefit exclusions #1934. It reads council_tax_reduction_non_dep_deductions, so it picks this up.

Axiom

axiom: uk/regulation/uksi/2006/213/74, uksi/2006/214/55, uksi/2012/2885/schedule/1/paragraph/8, wsi/2013/3029/schedule/1/paragraph/3 and schedule/6/paragraph/5, ssi/2012/319/48, ssi/2021/249/90 queued TheAxiomFoundation/rulespec-uk#407

• HB. rulespec-uk's HB pipeline (uk/policies/housing_benefit_composed_entitlement_pipeline.yaml) has the reg 74 bands for 2026-27 only, with inclusive >= edges. But it bands every non-dependant, multiplies one amount by a non-dependant count, and has no couple rule or exemptions. The 2025-26 amounts are in rulespec-uk#382.
• CTR. Every CTR spine takes non-dependant deductions as a supplied input.
• The issue. All seven provisions are in axiom-corpus. rulespec-uk#407 is dispatch-ready: module paths, verbatim law, required outputs, a pasteable review_finding, and companion tests from the same 2026-27 law as this PR's YAML tests. It carries the pe-parity label.
• Why queued. The signed encodes are OpenAI-billed, so they need Max's approval.

🤖 Generated with Claude Code

[MaxGhenis]

Composition note: #2015 (stacked on #2009 → #2006) deletes the two household flags this PR reads. council_tax_reduction_household_has_pensioner becomes council_tax_reduction_pensioner and council_tax_reduction_household_has_non_dep_exemption becomes council_tax_reduction_applicant_has_non_dep_exemption; both are BenUnit, so each jointly liable claimant uses its own family. #2015 does not add the national applicant exemption; that stays here. Whichever lands second should do three things:

1. Read the applicant's own exemption flag for applicant_exempt.
2. Do not substitute the family flag into each_member_deducted: that is evaluated on the non-dependant family, and Sch 6 para 5(3) turns on the applicant's scheme. Instead build two household pools of non-dependant families' deductions, the higher member's and the sum for a non-dependant couple on UC. Each claimant takes the sum pool when it is in Wales and its own council_tax_reduction_pensioner is false, and the higher-member pool otherwise.
3. Pick England's pensioner scale in the person-level variables by country only. Each claim's own scheme already decides whether its award uses it. The two tests that pin "no national deduction in English working-age households" then check that the working-age award is unaffected instead.

See the "National schemes and the exemption" section of #2015. (Corrected per this PR's author.)

[MaxGhenis]

Response to review r1 of #2007 (59c7082)

The review asked for changes and was right on all five P1s. Each is fixed below with the law, the change, and a test that fails on 59c7082 and passes now.

#	Finding	Disposition	Change	Test
1	is_adult is not "claimant or partner" (an 18-year-old dependant's PIP exempted the claimant; a 17-year-old claimant's PIP did not)	Fixed	New helper is_claimant_or_partner: the benefit unit's head, or any member who is not an SSCBA s.142 child or qualifying young person (is_child_or_qualifying_young_person_for_child_benefit, already on main). That is how HB Regs 2006 regs 2(1) and 19 and the English and Welsh CTR regs (reg 2(1)) define a family's members other than claimant and partner. It is used in the HB claimant exemption and in council_tax_reduction_household_has_non_dep_exemption (which the local schemes also read)	non_dependant_deduction_review_cases.yaml: "A dependent 18-year-old's PIP does not exempt the claimant" (HB £6,232.20, CTR £691.60); "A 17-year-old claimant's PIP exempts their family"
2	A dependent child's income was added to the couple's	Fixed	Joint income (reg 74(4), para 8(4)) sums only the claimant and partner of the non-dependant's family. Other members are banded on their own income. One deduction per couple (reg 74(3)) covers only the couple; each other member is deducted separately	"A parent non-dependant is banded on their own income…" (HB £1,060.80, CTR £270.40); household_benefits_individual_non_dep_deduction.yaml "A dependent young person in the family is banded on their own income"
3	HB reg 6(6): a person on IS, JSA(IB) or ESA(IR) is not in remunerative work	Fixed	The HB individual deduction treats the claimant or partner of an IS, JSA(IB) or ESA(IR) award as not in remunerative work. CTR exempts those recipients outright, so it needs no equivalent	"On income-related ESA, 16 hours is not remunerative work" (£1,060.80)
4	A self-employment loss cancelled wages in the UC no-earned-income test	Fixed	has_earned_income: employment income plus self-employed earnings floored at nil (UC reg 57(2) step 3)	"A self-employed loss does not cancel wages…" (both exemptions false; HB £1,060.80, CTR £270.40)
5	Taxable total_income omits UC, tax credits and child benefit	Fixed	Gross income for a claimant or partner adds the family's UC (before the benefit cap, which would be circular through HB), CTC, WTC and child benefit to the couple's taxable income. The disability benefits disregarded by reg 74(9) are still excluded, since they are untaxed and not added	"Universal Credit counts towards gross income" (£290 a week, £3,346.20)

Also from the review:

• Benefit receipt (IS, JSA(IB), ESA(IR), SPC, UC) now exempts only the claimant or partner of the award, in both exemption variables.
• Two omissions are now listed as not modelled, because no input exists:
  • pension-age HB's 26-week deferral of a deduction increase (SI 2006/214 reg 59(10)-(13));
  • the CTR applicant exemption's protection while AA, DLA or PIP is suspended in hospital (para 8(6)).
• The property tests' generator now includes dependent young people with their own income (in full-time education, or on approved training and so not exempt) and self-employed losses. The oracles use the claimant-or-partner rule, reg 6(6) and the floored earnings.
• The Welsh "award of universal credit" reading stays as stated in the PR description, an interpretation.

Not changed: the review's UNVERIFIED items on impact (exact zeros, decomposition, poverty causation). The impact is rerun on the new head after the host is free (the Axiom build has priority until about 10:00Z). The PR description's impact section is replaced with the rerun.

[MaxGhenis]

Response to review r2 of #2007 (6257277)

The review asked for changes again and was right on all five P1s. Findings 2-5 are fixed in the next commit, each with a YAML test that fails on 6257277 (non_dependant_deduction_review_cases.yaml, "Round 2" section). Finding 1 is fixed by adopting #1896's is_claimant_or_partner when #1896 lands; it is about to merge, and its owner asked #2007 to use it.

#	Finding	Disposition	Change	Test
1	Claimant or partner via "head or not a child benefit QYP" misclassifies explicit young partners (HB reg 2(1) "partner"), and in the reverse direction a third adult; this reaches the English local schemes through the shared exemption flag	Fixed with #1896	The helper is replaced by #1896's is_claimant_or_partner, which caps the set at the head and one partner (SSCBA s.137 couple) and can be supplied as an input for explicit couples. The r1 original student case also resolves, since #1896 presumes a 19-year-old 26 years younger than the parent is their child	The r2 explicit-couple cases are added after the rebase, along with the r1 cases
2	"No earned income" missed SMP, relievable pension contributions and the minimum income floor (UC regs 55 and 62)	Fixed	has_earned_income: employment income plus SSP and SMP, less relievable pension contributions (reg 55(4)-(5)); self-employed earnings, a loss nil (reg 57(2)), with the minimum income floor where the UC model applies it (reg 62); and other paid work	SMP £8,000 → not exempt (£1,060.80/£270.40); wages all paid into a pension → exempt (£0/£0); MIF applies → not exempt (£1,060.80/£270.40)
3	ESA(IR) receipt was extended to the working partner (HB reg 2(3A): "payable to him")	Fixed	is_award_payee: IS, JSA(IB), ESA(IR) and SPC count only for the member who reports the award, or the head where none does; UC still counts for both joint claimants (HB reg 2(3B): entitlement). Used for the exemptions and for HB reg 6(6)	Recipient and partner earning £210 a week at 16 hours → HB £2,436.20, CTR £270.40
4	Pre-cap UC overstated gross income (UC reg 81)	Fixed	Gross income now uses UC after the benefit cap. The cap is applied to the capped benefits other than Housing Benefit, which a non-rent-liable family does not receive; this avoids the HB → UC → cap → HB cycle	Pre-cap £30,000, cap £20,000 → HB £5,470.40 (365 band), CTR £551.20
5	CTR's LGFA 1992 Sch 1 para 3 disregard (an adult for whom another person is entitled to child benefit) was omitted although inputs exist	Fixed	The CTR exemption adds an adult qualifying young person (child benefit, s.142) who is not the claimant or partner of their family	19-year-old on approved training with child benefit → CTR exempt, parent alone £270.40; HB still charges both (£3,497.00)

On the property tests, the review said the oracles repeat the implementation's classification. They now take the payee as the head (the generator reports no awards) and read the child benefit QYP flag from the model. After the #1896 rebase they read is_claimant_or_partner from the model, which is not code under test. The generator now draws dependent young people and losses. SMP, pension and MIF cases are pinned in YAML rather than generated.