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.

Stacked on #2027 (legacy-award-readers-claimant-partner, head 200a1cdc4), which is stacked on #2013 → #2001 → #1896. It uses #2027's is_on_income_related_esa, is_on_income_based_jsa and is_on_income_support.

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. SI 2025/969 reg 3 asks whether a relevant benefit "has been, or falls to be, paid to P". SI 2024/869 reg 2(2)(b) asks whether "the person" is entitled to one, and reg 2(5) extends that to "the other member of the couple". SSI 2024/351 reg 2A (and reg 7(2) as made, reg 10(8) as substituted) treats an individual as entitled where "the other member of that couple ... is entitled".
• 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 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).
• 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, is_on_universal_credit and is_on_tax_credits, in Count only the claimant's and partner's legacy awards in means tests and passports #2027's pattern: the couple's award for the claimant and partner, the person's own reported award for anyone else. A positive tax_credits award is at least the £26 minimum (SI 2002/2008 reg 9).
• is_on_winter_fuel_payment_relevant_benefit and is_on_pawhp_relevant_benefit, read from new dated list parameters gov.dwp.winter_fuel_payment.eligibility.relevant_benefits and gov.social_security_scotland.pawhp.eligibility.relevant_benefits.

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.

In a relevant-benefit couple the model pays the eldest qualifying member; the amount is the same whichever member is paid. Everyone in a household is taken to live together; residential care, long hospital stays and custody are not modelled.

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 a follow-up; see below.

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 and amounts, 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 whose pension-age members are all in one benefit unit 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 check: each property suite was run against four deliberate bugs, and every bug was caught:

• 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.

Tests

• YAML, each case worked by hand from the regulations:
  • tests/policy/baseline/gov/dwp/winter_fuel_payment/relevant_benefit_receipt.yaml: 18 cases, 2023-2025, including a pensioner with a non-dependant on income-related ESA, in a separate benefit unit and as a non-partner member;
  • tests/policy/baseline/gov/social_security_scotland/pawhp.yaml: 16 cases, 2024-2026.
• On the base (200a1cdc4), 24 of the 34 cases give a household total that differs from the law:

Case	Year	Base (#2027 head)	This branch = law
relevant_benefit_receipt: 2024 a non-dependant's income-related ESA does not entitle the pensioner	2024	£200.00 ✗	£0.00
relevant_benefit_receipt: 2024 a non-dependant who is neither claimant nor partner does not pass their ESA to the pensioner	2024	£200.00 ✗	£0.00
relevant_benefit_receipt: 2024 a pensioner on Pension Credit living with a non-dependant gets £200	2024	£200.00	£200.00
relevant_benefit_receipt: 2024 a Pension Credit couple gets one payment of £300 when one partner is 80	2024	£300.00	£300.00
relevant_benefit_receipt: 2024 two pensioners in separate benefit units each on Pension Credit get a payment each	2024	£200.00 ✗	£400.00
relevant_benefit_receipt: 2024 a pensioner in a mixed-age couple on Universal Credit gets £200	2024	£0.00 ✗	£200.00
relevant_benefit_receipt: 2024 a pensioner with a tax credit award of at least £26 gets £200	2024	£0.00 ✗	£200.00
relevant_benefit_receipt: 2025 a non-dependant's income-related ESA does not exempt the pensioner from the income test	2025	£200.00 ✗	£0.00
relevant_benefit_receipt: 2025 a pensioner under the income limit living with a non-dependant on ESA gets £200	2025	£200.00	£200.00
relevant_benefit_receipt: 2025 a pensioner on Pension Credit and one who is not, in separate benefit units	2025	£200.00 ✗	£300.00
relevant_benefit_receipt: 2025 an 85-year-old not on Pension Credit living with a 70-year-old who is	2025	£300.00 ✗	£400.00
relevant_benefit_receipt: 2025 a couple aged 70 and 82 not on a relevant benefit gets £300 between them	2025	£300.00	£300.00
relevant_benefit_receipt: 2025 a couple both over 80 not on a relevant benefit gets £150 each	2025	£300.00	£300.00
relevant_benefit_receipt: 2025 an over-80 living with entitled people both over and under 80 gets £150	2025	£300.00 ✗	£400.00
relevant_benefit_receipt: 2025 a Pension Credit couple gets one payment	2025	£200.00	£200.00
relevant_benefit_receipt: 2023 Scotland's pensioners get the Winter Fuel Payment, not PAWHP	2023	£200.00	£200.00
relevant_benefit_receipt: 2023 a pensioner on Pension Credit and one who is not, in separate benefit units	2023	£200.00 ✗	£300.00
relevant_benefit_receipt: 2023 Universal Credit is not a relevant benefit under the 2000 regulations	2023	£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: 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: 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: The Winter Fuel Payment is not paid in Scotland from 2024	2025	£100.00 ✗	£203.40

• 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.

Enhanced FRS impact

Pending: real Microsimulation runs on a private copy of the Enhanced FRS 2024-25 for 2023-2030 (base 200a1cdc4 against this branch) run after the host's heavy-run hold ends. This section will be filled in from them.

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

• The winter fuel payment charge per person (ITEPA 2003 s.681I): 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.
• pawhp is in gov_spending but not in household_benefits or HBAI income. Since Add the Scottish WFP #1000, Scottish pensioners' winter heating payment has been missing from household net income.

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