Apply the UC minimum income floor only to claimants subject to all work-related requirements

[MaxGhenis]

Summary

After #1973 the Universal Credit minimum income floor (MIF) applies to every claimant with self-employment profit or loss outside a start-up period. The law is narrower. UC Regs 2013 reg 62(1) applies the floor only to a claimant who:

(a) is in gainful self-employment (see regulation 64); and
(b) would, apart from this regulation or regulation 90, fall within section 22 of the Act (claimants subject to all work-related requirements).

So the floor does not reach claimants whom Welfare Reform Act 2012 ss.19 to 21 put in another group. That includes claimants with limited capability for work or work-related activity, carers, claimants over State Pension Credit qualifying age, the responsible carer of a child under 3, and the prescribed descriptions in regs 89 and 91. Two other rules change the amount:

• Expected hours. The floor uses each claimant's expected hours, which reg 88(2) lowers for the responsible carer of a child under 13. DWP uses up to 30 hours for these carers, against 35 for everyone else.
• Couple threshold. For a couple, the threshold adds up each partner's own amount (reg 90(2) and (3)). That is 16 hours for a partner in the work-focused interview or work preparation group, and nothing for a partner with no work-related requirements.

This PR adds the work-related group, the responsible carer, the expected hours and the per-partner thresholds. It finishes the three scope gaps #1973 listed.

Two 2026 examples, each a lone parent aged 30 with £5,000 of profits and council rent of £9,600:

• Youngest child aged 1 (s.20, so no floor). Apply the UC minimum income floor to net earned income against a net threshold #1973 treated the parent as earning the net floor of £20,386.03, giving UC of £9,951.96. Here they keep their £5,000, which is under the £5,124 work allowance, so UC is £18,346.08: £8,394.12 a year more.
• Youngest child aged 5 (s.22, at 30 expected hours). The net floor is £17,940.62, so UC is £11,296.94: £1,344.98 a year more.

On the Enhanced FRS this raises 2026 UC by £0.266bn. About 81,000 benefit units gain (65 records), by a mean of £3,272 a year, and nobody loses. The couple's nomination of the responsible carer is the main modelling choice: nominating the other partner gives +£0.367bn (see "Modelling choices").

Stacked on #1973 (head ae8f59fd1, merged into this branch). Retarget to main after #1973 merges; CI runs only on PRs into main.

Law (legislation.gov.uk, read 2026-09-30 and 2026-10-01)

Welfare Reform Act 2012 (https://www.legislation.gov.uk/ukpga/2012/5/part/1/chapter/2/crossheading/application-of-workrelated-requirements):

19(2) A claimant falls within this section if— (a) the claimant has limited capability for work and work-related activity, (b) the claimant has regular and substantial caring responsibilities for a severely disabled person, (c) the claimant is the responsible carer for a child under the age of 1, or (d) the claimant is of a prescribed description.

19(6) In this Part "responsible carer", in relation to a child means— (a) a single person who is responsible for the child, or (b) a person who is a member of a couple where— (i) the person or the other member of the couple is responsible for the child, and (ii) the person has been nominated by the couple jointly as responsible for the child.

20(1) A claimant falls within this section if— (a) the claimant is the responsible carer for a child who is aged 1, or (b) the claimant is of a prescribed description.

21(1) A claimant falls within this section if the claimant does not fall within section 19 or 20 and— (a) the claimant has limited capability for work, (aa) the claimant is the responsible carer for a child who is aged 2, or (b) the claimant is of a prescribed description.

22(1) A claimant not falling within any of sections 19 to 21 falls within this section.

The child ages took this form on 3 April 2017 (Welfare Reform and Work Act 2016 s.17). Before that, s.20(1)(a) covered "a child who is aged at least 1 and is under a prescribed age". The prescribed age was 5 (reg 91(1) as made), then 3 from 28 April 2014 (SI 2014/1097 reg 16). From 28 April 2014, reg 91A put the responsible carer of "a child aged 3 or 4" in s.21. The parameters carry these dates.

UC Regs 2013:

• Reg 86(2) (https://www.legislation.gov.uk/uksi/2013/376/regulation/86): "Only one of joint claimants may be nominated as a responsible carer". Reg 86(3): "The nomination applies to all the children".

• Reg 89(1) (https://www.legislation.gov.uk/uksi/2013/376/regulation/89): these claimants fall within s.19:

  • (a) "the claimant has reached the qualifying age for state pension credit";
  • (b) carers of a severely disabled person for 35 hours a week;
  • (c) "the claimant is pregnant and it is 11 weeks or less before her expected week of confinement, or was pregnant and it is 15 weeks or less since the date of her confinement";
  • (d) adopters in the first 12 months;
  • (da) and (e) students;
  • (f) "the responsible foster parent of a child under the age of 1".

• Reg 91(2) (https://www.legislation.gov.uk/uksi/2013/376/regulation/91): foster parents, and friend or family carers in their first 12 months, fall within s.20.

• Reg 88 (https://www.legislation.gov.uk/uksi/2013/376/regulation/88):

  (1) The "expected number of hours per week" in relation to a claimant for the purposes of determining their individual threshold in regulation 90 ... is 35 unless some lesser number of hours applies under paragraph (2).

  (2) The lesser number of hours is— ... (aa) where the claimant is a responsible carer of a child who has not yet reached compulsory school age, the number of hours that the Secretary of State considers is compatible with those caring responsibilities; (b) where the claimant is a responsible carer for a child who has reached compulsory school age but who is under the age of 13, the number of hours that the Secretary of State considers is compatible with the child's normal school hours (including the normal time it takes the child to travel to and from school); or (c) where the claimant has a physical or mental impairment, the number of hours that the Secretary of State considers is reasonable in light of the impairment.

• Reg 90 (https://www.legislation.gov.uk/uksi/2013/376/regulation/90):

  (2) A claimant's individual threshold is the amount that a person of the same age as the claimant would be paid at the hourly rate applicable under regulation 4 or regulation 4A(1)(a) to (c) of the National Minimum Wage Regulations for— (a) 16 hours per week, in the case of a claimant who would otherwise fall within section 20 ... or section 21 ...; or (b) the expected number of hours per week in the case of a claimant who would otherwise fall within section 22 ...

  (3) ... (a) in the case of joint claimants, the sum of their individual thresholds; or (b) in the case of a claimant who claims universal credit as a single person by virtue of regulation 3(3), the sum of— (i) the claimant's individual threshold, and (ii) the amount a person would be paid for 35 hours per week at the hourly rate specified in regulation 4 of the National Minimum Wage Regulations ...

DWP guidance agrees on the scope.

• ADM H4060: the floor applies where the claimant "would normally but for the minimum income floor be subject to all work-related requirements".
• ADM H4061, example 3: a claimant who has had a baby "moves into the no work-related requirements group. The minimum income floor no longer applies".

Change

New variables, under variables/gov/dwp/universal_credit/work_related_requirements/:

• uc_work_related_group_apart_from_earnings (Enum). The group the claimant would fall within apart from regs 62 and 90: no work-related requirements, interview only, work preparation, all requirements, or not a claimant. The sections are tested in the Act's order: s.21 only takes someone outside ss.19-20, and s.22 is what is left. The earnings routes of reg 90 are left out, as reg 62(1)(b) and reg 90(2) both require. The routes are:
  • s.19:
    • LCWRA (uc_limited_capability_for_WRA);
    • carers (is_carer_for_benefits; reg 30 and reg 89(1)(b));
    • the responsible carer of a child under 1;
    • State Pension Credit qualifying age (is_SP_age; reg 89(1)(a));
    • the reg 89(1)(c)-(f) inputs.
  • s.20: the responsible carer of a child aged 1; the reg 91(2) input.
  • s.21: limited capability for work (input); the responsible carer of a child aged 2.
• uc_is_responsible_carer. A lone claimant with a child, or one member of a couple (s.19(6), reg 86). It is an input where the nomination is known; the default is described under "Modelling choices".
• uc_youngest_child_age (benefit unit). The youngest person under 16 (WRA s.40) in the benefit unit who is not a member of the couple and is not looked after by a local authority (reg 4(6)(a)).
• uc_expected_hours (reg 88). This is 35, or DWP's figure for the responsible carer of a child under 13. It is an input for the discretionary relevant-carer and impairment reductions.
• uc_is_in_gainful_self_employment (reg 64). By default, any self-employment profit or loss. It is an input for a trader who breaks even, or whose self-employment is not gainful.
• Inputs, all default false:
  • uc_has_limited_capability_for_work;
  • uc_is_in_pregnancy_or_post_confinement_period;
  • uc_is_adopter_in_first_year;
  • uc_is_student_with_no_work_related_requirements;
  • uc_is_responsible_foster_parent_of_child_under_one;
  • uc_is_foster_parent_or_new_friend_or_family_carer;
  • uc_is_ineligible_partner (reg 3(3)).

Changed:

• uc_mif_applies: the group is all requirements, the claimant is in gainful self-employment, and they are not in a start-up period.

• uc_minimum_income_floor_gross: the hours follow the group.

  • All requirements: expected hours (reg 90(2)(b)).
  • Interview only or work preparation: 16 (reg 90(2)(a)).
  • No requirements: the no_requirements_partner_hours parameter (0).
  • A partner who cannot be a joint claimant: 35 hours at the national living wage, whatever their age (reg 90(3)(b)(ii)).
  • Not a claimant: nothing.

  uc_individual_earned_income is unchanged: the couple threshold was already the sum of the two members' uc_minimum_income_floor, which now follows the group.

New parameters:

• under gov.dwp.universal_credit.work_requirements:
  • responsible_carer.child_age.{no_requirements, interview_only, work_preparation}, with the 2013, 2014 and 2017 ages;
  • responsible_carer.expected_hours.{below_compulsory_school_age, compulsory_school_age, child_age_limit};
  • interview_or_preparation_threshold_hours (16);
• gov.dwp.universal_credit.means_test.minimum_income_floor.no_requirements_partner_hours (0).

Modelling choices

1. Who is the responsible carer in a couple. The law leaves the nomination to the couple (s.19(6)(b)(ii); reg 86), and the FRS does not record it. By default the model takes the claimant with fewer hours of paid work (hours_worked), then the elder.
   • Among the 105,000 people (76 records) in couples with a child under 13 whom Apply the UC minimum income floor to net earned income against a net threshold #1973's floor lifts in 2026, the self-employed partner usually works more paid hours than the other partner (84,000 of them, 56 records). On average they work 34 hours a week and their partners 16. So the default usually nominates the other partner, and the floor stays on the self-employed one with 35 expected hours. The default nominates 20,000 of the 105,000 (18 records).
   • Nominating the other partner instead is the run in the "Other nomination" column: 2026 UC +£0.367bn, against +£0.266bn here. That is the range the choice spans.
   • An earlier version took the nomination that gives the couple the higher award. That assumes couples choose the lead carer to beat the floor, which nothing in DWP's material supports, so I dropped it.
   • Datasets and calculator users can set uc_is_responsible_carer. An input set for some people sets it for everyone, so set it on both members.
2. A partner with no work-related requirements adds nothing to the couple threshold. Reg 90(2) sets an individual threshold only for a claimant who would otherwise be in s.20 or 21 (16 hours) or s.22 (expected hours). It sets none for an LCWRA partner, a carer, a partner caring for a baby, or a partner over pension age. The ADM and the DWP floor guidance (v9 to v23) give no figure either. The model follows the text and gives such a partner nothing (parameter no_requirements_partner_hours, 0). The partner's earned income then reduces the self-employed partner's floor pound for pound (reg 62(3)). Setting it to 35 hours gives 2026 UC +£0.258bn (the "Partner at 35 hours" column).
3. Expected hours are DWP's practice figures. Reg 88(2) leaves the number to the Secretary of State.
   • From 3 April 2017 DWP's guidance used up to 16 hours for a child aged 3 or 4 and 25 for a school-age child under 13 (ADM J2086; Work-related requirements for claimants with children, v1).
   • DWP raised both to a maximum of 30 hours for the floor. That applied to new gainfully self-employed claimants from 31 January 2024, and DWP began raising existing floors from February 2025 (DEP2024-0673/073, Gainfully self-employed lead carers with youngest child aged 3-12). The parameters switch on 1 February 2025.
   • Written answer 129349 (28 April 2026): "self-employed individuals with children aged 3-12 typically have their Minimum Income Floor set using a maximum of 30 hours per week".
   • The model uses the maximum. Work coaches can set fewer hours. DWP documents 25 hours first in April 2017, and the model uses it back to 2013, where reg 88(2)(b) already set hours "compatible with the child's normal school hours".
4. Compulsory school age is age 5, the model's existing gov.dfe.compulsory_school_age scale in whole years. England and Wales start it on a prescribed day after the fifth birthday, and Scotland uses school commencement dates.
5. State Pension Credit qualifying age is is_SP_age until Use the State Pension Credit qualifying age, and start-of-year status for Class 4 NI #1907 lands has_attained_state_pension_credit_qualifying_age.
6. Carers are is_carer_for_benefits: Carer's Allowance or Carer Support Payment receipt, or 35 hours of care. Reg 30 also requires that the person cared for gets a qualifying disability benefit, and excludes paid caring (reg 30(3)). The flag checks neither, so it can over-include. In the Enhanced FRS it equals reported Carer's Allowance receipt, because care_hours is not stored. Its earnings are untested, which matches reg 30(1)(a)(i): a carer earning over the Carer's Allowance limit is still in s.19.

Tests

• YAML: 77 new cases. Each expectation is computed by hand from the law, with the arithmetic in a comment.
  • work_related_requirements/uc_work_related_group_apart_from_earnings.yaml covers every route, the order of the sections, the 2016 child ages and qualifying young people.
  • work_related_requirements/uc_is_responsible_carer.yaml and work_related_requirements/uc_expected_hours.yaml cover the nomination and the hours.
  • income_floor/uc_MIF_applies.yaml covers scope for each route and for gainful self-employment.
  • income_floor/uc_minimum_income_floor.yaml covers 30- and 16-hour thresholds; ADM J2082 "Alison", J2085 "Louise", and J2086 "Richard" and "Laura" (Laura's arithmetic corrected: £7.05 × 25 × 52 / 12 is £763.75, not the ADM's £763.25); and the reg 90(3)(b) partner aged 17 at the national living wage.
  • income_floor/uc_mif_earned_income.yaml covers couples. Cases include an LCWRA partner's earnings reducing the floor pound for pound, a mixed-age couple, a partner with a 16-hour threshold (s.20) and one with a work-preparation threshold (s.21), a baby, and reg 3(3) partners.
  • Apply the UC minimum income floor to net earned income against a net threshold #1973's couple case with children aged 5 and 3 now uses children aged 15 and 14, keeping its 35-hour numbers. A new case covers the 30-hour responsible carer: the floor falls from £19,252.46 to £16,807.06 and UC rises from £7,691.77 to £9,036.74.
  • All 275 YAML cases in the Universal Credit folder pass.
• Hypothesis: tests/test_uc_work_related_groups_properties.py, 7 properties.
  • Populations are drawn across 2016, 2020 and 2026. They mix single people, couples and mixed-age couples; children of any age; disability, caring and every prescribed circumstance; paid hours, profits and losses, pay, pension contributions and start-up periods; and four regions. Each property is listed under "Invariants".
  • The existing floor, earnings-deduction and State Pension property files also pass. Each file was run in its own process.

Invariants

1. Scope. uc_mif_applies is exactly: in the all-requirements group, in gainful self-employment, and not in a start-up period. Everyone else keeps their actual earned income, and the floor never lowers anyone's earned income.
2. Thresholds. The gross threshold is the minimum wage for the person's age × 52 × their expected hours (s.22), × 16 (ss.20-21), or nothing (s.19, or not a claimant). Expected hours are 35 unless a lesser number applies to the responsible carer of a child under 13, and never more than 35.
3. Nomination. A benefit unit has exactly one responsible carer if it has a child under 16, and none otherwise; the responsible carer is always a claimant. A differential check compares the model with the default rule as written: fewest paid hours, then the elder, then the first listed.
4. Either nomination. Whichever member of a couple is nominated, invariants 1 and 2 hold. The nomination changes nothing in a benefit unit with no child under 13 or no claimant the floor could apply to.
5. Differential against Apply the UC minimum income floor to net earned income against a net threshold #1973's rule. Forcing every claimant into the all-requirements group at 35 hours reproduces Apply the UC minimum income floor to net earned income against a net threshold #1973. The scope rules never raise anyone's earned income, so they never lower UC before the benefit cap, under either nomination.
6. Monotone. More earnings never lower a benefit unit's earned income and never raise its UC before the cap. The default nomination does not depend on earnings. The intended exception, from Apply the UC minimum income floor to net earned income against a net threshold #1973, is a loss raised to exactly zero, which the model reads as no self-employment.
7. Reg 3(3) partner. A partner who cannot be a joint claimant never has the floor, and adds 35 hours at the national living wage to the couple threshold whatever their age.

The Enhanced FRS runs check invariants 1 and 5 on every record in every year 2025-2030. No earned income rises, no UC before the cap falls, the floor never lowers anyone, and everyone outside its scope is unchanged.

Impact (Enhanced FRS, real runs)

These are real microsimulation runs. The dataset is a private copy of enhanced_frs_2024_25.h5 (sha256 e433e532…68712). The base is #1973's head ae8f59fd1 and the branch is 94b7129b4; both are clean checkouts, run one at a time. The two sensitivity columns are full runs of the branch:

• "Other nomination": every couple with a child nominates the other member, set as an input.
• "Partner at 35 hours": no_requirements_partner_hours set to 35.

Year	UC on #1973	UC here	Change	Benefit units gaining	Mean gain	People the floor lifts (#1973 → here)	Other nomination	Partner at 35 hours
2025	£72.86bn	£73.12bn	+£0.255bn	81k (66 records)	£3,144	210k → 178k	+£0.353bn	+£0.248bn
2026	£76.84bn	£77.10bn	+£0.266bn	81k (65 records)	£3,272	197k → 165k	+£0.367bn	+£0.258bn
2027	£78.56bn	£78.83bn	+£0.262bn	82k (67 records)	£3,201	195k → 160k	+£0.360bn	+£0.255bn
2028	£80.02bn	£80.28bn	+£0.258bn	81k (65 records)	£3,181	193k → 160k	+£0.352bn	+£0.252bn
2029	£81.02bn	£81.27bn	+£0.254bn	82k (67 records)	£3,107	195k → 161k	+£0.346bn	+£0.249bn
2030	£77.88bn	£78.13bn	+£0.245bn	80k (66 records)	£3,053	192k → 154k	+£0.334bn	+£0.243bn

2026 detail:

• Nobody loses UC. Housing Benefit, council tax reduction, Pension Credit and the benefit cap are unchanged, so household net income rises by the same £0.266bn. The UC caseload rises by about 2,100 (3 records).
• Of the 199,000 people (159 records) in UC benefit units whom Apply the UC minimum income floor to net earned income against a net threshold #1973's floor lifts:
  • 35,000 (27 records) are no longer lifted. 28,000 (20 records) are in ss.19-21: LCWRA 5,800, carers 5,300, and the responsible carer of a child under 1 (7,500), aged 1 (4,500) or aged 2 (5,300). Each of those groups is under 10 records, so the split is rough. The other 6,500 (7 records) are still in s.22, but their lower floor or couple threshold is now below their own earnings.
  • 47,000 (40 records) are lifted by less. 39,000 (28 records) are responsible carers of a child aged 3 to 12 with a 30-hour floor. 8,000 (12 records) keep 35 hours but have a partner whose 16-hour or zero threshold lowers the couple threshold.
  • 118,000 (92 records) are lifted by the same amount.
  • Their earned income falls by £0.486bn in all, £0.346bn of it from the people now in ss.19-21.
• One benefit unit accounts for 30% of the 2026 change, and the largest five for 62%. With 65 gaining records, treat the total as an estimate with a wide margin.
• Poverty falls slightly: children before housing costs −0.08 points, all people after housing costs −0.01 points.

The scripts (dataset_impact.py, compare_impact.py) write aggregates only.

Known gaps

• Reg 3(3) single claims are modelled only for the floor. uc_is_ineligible_partner keeps the partner out of the floor and puts the 35-hour amount into the couple threshold. The rest of a single claim by a member of a couple is not modelled: the standard allowance (reg 36(3)), capital (reg 18(2)) and the work allowance (reg 22(3)).
• The discretionary reductions for relevant carers (reg 88(2)(a)) and impairment (reg 88(2)(c)) are inputs through uc_expected_hours. So are pregnancy, adoption, students, fostering and limited capability for work alone: the Enhanced FRS has no fields for them.
• Zero-profit self-employment. In the 2026 run, about 122,000 claimants (104 records) in UC benefit units report a self-employed status but zero profit. The model reads them as not self-employed, as Apply the UC minimum income floor to net earned income against a net threshold #1973 did. Whether they are gainfully self-employed traders who broke even is a data question; uc_is_in_gainful_self_employment takes the answer when there is one.
• Years before 2015. uc_mif_applies now reads is_carer_for_benefits, which needs Carer's Allowance parameters that start in 2015, so it raises a missing-parameter error for 2013 and 2014. universal_credit itself already raises one in those years on Apply the UC minimum income floor to net earned income against a net threshold #1973 (other UC parameters start later), so no award changes.
• Annual ages. Child ages are whole years, so a child's birthday inside the year does not move the group mid-year.

Axiom parity

axiom: TheAxiomFoundation/rulespec-uk#396 queued (scope comment TheAxiomFoundation/rulespec-uk#396 (comment): UC Regs 2013 regs 62(1)(b), 88 and 90(2)-(3); WRA 2012 ss.19-22; new modules for regs 3, 30, 85, 86, 89, 91 and 91A)

🤖 Generated with Claude Code

[MaxGhenis]

Follow-up for item 5 of the caveats (reg 89(1)(a) uses is_SP_age until #1907 lands). It is prepared and will not be stacked on this PR or on #1907. When both this PR and #1907 have merged, a scheduled job opens a separate PR from main (branch uc-wrr-spc-qualifying-age). That PR:

• switches the reg 89(1)(a) line in uc_work_related_group_apart_from_earnings to has_attained_state_pension_credit_qualifying_age;
• adds YAML cases where the two ages differ (a man born 6 April 1952 in 2016-17, a man born 6 June 1953 in 2016-17 and 2017-18, and the floor case), checked against Pensions Act 1995 Sch 4 para 1 as at 6 October 2016;
• adds a statute differential and a Hypothesis differential to test_uc_work_related_groups_properties.py.

Nothing in this PR needs to change for it. The prepared patch is anchored on these lines of this PR:

• # Reg. 89(1)(a): the qualifying age for State Pension Credit. / | person("is_SP_age", period)
• the reg 62(1)(b) reference entry
• the YAML case "A claimant over State Pension Credit qualifying age, regulation 89(1)(a)"
• the property file's import block and the "Marriage Allowance is switched off throughout" docstring line

If you change those before merging, the follow-up adapts by hand.

[MaxGhenis]

#2084 is stacked on this PR. It models the rest of a reg 3(3) single claim: single amounts (reg 36(3)), the elements, the benefit cap and the shared accommodation rate. Two things in it touch this PR:

1. uc_is_ineligible_partner gets a formula for limb (a). A member of a couple who fails meets_uc_minimum_age_condition is the ineligible partner. This is ADM E2017's example: Jane is 17, Tom is 19, and "Tom is required to claim for himself as a single person". It is still an input for limbs (b)-(e). This PR's floor rules read it unchanged. On the Enhanced FRS the formula never fires: no couple has a member under 18.
2. A fixture fix this PR will need when it merges main. Main's claimant-or-partner presumption (Replace generic child and adult flags with each programme's legal definitions #1896) reads a generated 18-year-old partner of a 52-year-old as their child. So test_partner_who_cannot_be_a_joint_claimant in test_uc_work_related_groups_properties.py fails once main is merged in, with the flag landing on someone outside the couple. Model a Universal Credit claim by a member of a couple as a single person (UC Regs 2013 reg 3(3)) #2084's commit 0dfcc26 declares is_claimant_or_partner in the fixtures, as Deduct only each person's own tax and NI on earnings from UC earned income #1949 did in a57caf1; the same two lines will do here.