DLE v The Secretary of State for Work and Pensions (UC): [2026] UKUT 414 (AAC)
Summary
The Upper Tribunal Administrative Appeals Chamber issued guidance on how the First-tier Tribunal should assess whether a claimant meets regulation 25(3) of the Universal Credit Regulations 2013, which concerns liability for accommodation payments. It also confirmed that the principles in R(H) 1/03 remain relevant when deciding whether that liability is on a commercial basis under regulation 25(3)(a)(i).
Why it matters
This is relevant to surveyors where accommodation arrangements, rent liability and occupancy terms may be scrutinised in benefit-related disputes. It may also be of interest in cases involving supported, informal or non-standard housing arrangements where the commercial nature of payments is questioned.
Key points
- Upper Tribunal provided guidance on the order of analysis under regulation 25(3).
- The decision concerns whether a claimant is treated as liable or not liable to make accommodation payments.
- R(H) 1/03 remains relevant to the commercial-basis test under regulation 25(3)(a)(i).
- The case arises in the context of Universal Credit housing-related liability assessments.
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