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Employer NI ignores the under-21 and apprentice zero rates and the Employment Allowance #1918
ni_class_1_employer applies the full employer rate (15% from 2025-26) above the secondary threshold to every earner aged 16 or over. The model does not implement:
SSCBA 1992 s.9A. 0% secondary rate for earners under 21, up to the upper secondary threshold (SI 2001/1004 reg 10(e); £967 a week in 2026-27).
s.9B. 0% for relevant apprentices under 25, up to the apprentice upper secondary threshold (reg 10(f)). is_apprentice exists, but NI does not use it.
The Employment Allowance (NICA 2014 s.1): £10,500 per eligible employer in 2026-27, set against the employer's total secondary Class 1. It is employer-level, so the right representation in a person-level model needs a design decision.
The elective veterans and freeport/investment zone reliefs (NICA 2022 ss.1 and 6–7), for completeness.
So ni_employer is overstated for under-21s and young apprentices, and gross of the Employment Allowance.
policyengine-uk-data calibrates weights to OBR "Class 1 Employer NICs" using this model's ni_employer (targets/sources/obr.py, obr/ni_employer). Any fix interacts with calibration.
Found while fixing #1894 (PR #1895). There, the property test checks the statutory s.9 amount only from age 21, because of this gap.
Thresholds for whoever models the under-21 and apprentice zero rates here. I checked these against the primary sources on 2026-09-30.
2026-27 (law): the UST and AUST are £967 a week (SI 2001/1004 reg 10(e)-(f)), or £4,189 a month and £50,270 a year (reg 11(3B)-(3C)). For a period that is a multiple of a week, reg 11(3B)(c)/(3C)(c) gives £50,270 / 52 per week, the same convention the model uses for the UEL.
2027-28 to 2030-31 (announced, not yet legislated): the Budget 2025 policy paper says "the UST and AUST thresholds will remain aligned to the National Insurance contributions UEL at £967 per week up until the 2030 to 2031 tax year" (HMRC). Budget 2025 para 4.111 covers "other employer NICs relief thresholds aligned with the UEL".
The veterans' UST is enacted only through 2027-28 (NICA 2022 s.6(4)(e)-(f) and s.8(2), as amended by SI 2026/231 reg 6).
The freeport and investment zone UST is £481 a week for 2026-27 (HMRC rates page); I found no announced value for later years.
#1959 freezes the UEL itself through 2030-31. Tying new UST and AUST parameters to it would keep them aligned.
The Employment Allowance part of this issue is split out as #2459. It is the largest of these gaps from 2025-26 (HMRC forecasts £7.4bn), and it needs its own design decision because the allowance is set per employer and the model has no employer entity. #2459 proposes the parameters, a per-employee attribution and acceptance tests. The under-21 and apprentice zero rates and the veterans and freeport reliefs stay here.
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MaxGhenis commentedon Sep 30, 2026
Thresholds for whoever models the under-21 and apprentice zero rates here. I checked these against the primary sources on 2026-09-30.
#1959 freezes the UEL itself through 2030-31. Tying new UST and AUST parameters to it would keep them aligned.
juaristi22 commentedon Oct 16, 2026
The Employment Allowance part of this issue is split out as #2459. It is the largest of these gaps from 2025-26 (HMRC forecasts £7.4bn), and it needs its own design decision because the allowance is set per employer and the model has no employer entity. #2459 proposes the parameters, a per-employee attribution and acceptance tests. The under-21 and apprentice zero rates and the veterans and freeport reliefs stay here.