Managed migration in 2025
Simon Osborne reviews where the managed migration to universal credit (UC) process has got to and what lies ahead in 2025.
Summary
•By April 2025, all remaining awards of tax credits will have been subject to the managed migration process, and all awards of tax credits will have ended. (The tax credits scheme will close in April.)
•By April 2025, all remaining awards of income support (IS), income-based jobseeker’s allowance (JSA) – and of housing benefit (HB), except where paid with income-related employment and support allowance (ESA) – will have been subject to the managed migration process.
•From April 2025, activity will concentrate on the migration of remaining awards of income-related ESA, including where paid with HB. Migration notices will have been sent by December, so that all remaining awards will have ended (and the managed migration process is finished) by April 2026.
Where are we now?
By February 2025, managed migration had already ended most remaining awards of tax credits, IS and income-based JSA – and HB-only awards. The official intent is that this be complete by April.
For tax credits, there will be no remaining awards by April (for more, see ''). For IS and income-based JSA, the official intent is also that there will be no awards by then; but it is understood that in practice there may still be a small number of extant awards come April. However, these will have been subject to a migration notice and so in practice will only remain extant for a short time.
Managed migration of the remaining awards of income-based ESA, including where combined with HB, started in late 2024. The official intent is that migration notices will have been sent out in all such cases by the end of December 2025, so that the migration process is complete by April 2026.
So, from April 2025 managed migration will in essence be about the managed migration of the remaining awards of income-related ESA.
What happened in 2024/2025
During 2023/24, managed migration had focused on claimants solely in receipt of tax credits. Plans for 2024 were set out in a ministerial statement back in January 2024.
1At that stage, the managed migration process and official arrangements were referred to as the ‘Move to Universal Credit’ programme. The statement said:
‘...Our plans for 2024/25 are to undertake the issuing of migration notices to in scope working age benefit households sequentially, starting with income support claimants and those claiming tax credits with housing benefit from April, housing benefit only claimants from June, employment support allowance with child tax credits from July and jobseeker’s allowance in September....From August, we will also contact those claiming tax credits who are over state pension age, with households being asked to apply for either universal credit or pension credit, depending on their circumstances.’
A subsequent statement in May 2024 announced that the process would also begin to be applied to income-related ESA awards without child tax credit from autumn 2024.
2Plans for 2025/2026
In November 2024, DWP minister Sir Stephen Timms announced that in 2025 activity was to focus on the remaining income-related ESA awards, with an aim to have sent out the final migration notices by December 2025, so that the migration to UC process will have been finalised by 2026.
3 Timms said:
‘Move to UC statistics published today show that, by the end of September, the department had, since 2022, notified 943,343 households of the need to make the transition to UC. The latest published complaints data show that as of March 2024 with over 500,000 households asked to move to UC, DWP had only 35 complaints about the process, with 10 upheld. Plans have now been agreed to notify the remaining households receiving income related employment and support allowance (ESA), building on the insight that DWP has gathered through the summer...
‘DWP is investing up to a further £15m in Help to Claim to support employment and support allowance customers moving to universal credit. This means that free confidential and impartial support will continue to be available to help people make a new universal credit claim and manage their claim, up to receiving their first correct payment.
‘DWP will steadily increase the number of migration notices being sent to people receiving ESA over the next months and are aiming to issue 63,000 migration notices each month from February, sending the final notices in early December 2025 and fully moving people to universal credit and closing legacy benefits by the end of March 2026.
‘As DWP moves into this final phase for Move to UC, it will make the transition from delivering “Move to UC” from a programme-led approach to a “business as usual” operation. I am therefore announcing today the intention to formally close the Move to UC Programme by the end of March 2025, as the work of the programme will be complete by then...’
Subsequently, the December 2024 edition of LA Welfare Direct confirmed those plans, including the official intent that (allowing time after sending of the migration notice) by April 2025, awards of tax credits, IS, income-based JSA and HB without ESA will have been dealt with:
4‘61. DWP will steadily increase the number of migration notices being sent to claimants receiving ESA during the upcoming months, with all notices due to be sent by the end of December 2025. Benefit claimants, other than those on ESA and ESA HB, will receive their final migration notice by the end of December 2024.’
What to look out for in 2025
In much of 2025, managed migration will essentially be about income-related ESA. Issues regarding that benefit, and the application of managed migration to it, will increasingly take centre stage. Both legal and policy/practice issues will feature.
Legal issues
•Limited capability for work (LCW) and work-related activity (LCWRA). ESA recipients are at the point of the UC claim treated as having LCW, and if in the support group are automatically entitled to the LCWRA element from the start of the award.
5Reg 19 Universal Credit (Transitional Provisions) Regulations 2014; CPAG, Welfare Benefits and Tax Credits Handbook 2024/2025, p73; ‘’, Welfare Rights Bulletin 300, June 2024 But there have been problems with the DWP ignoring this and so (wrongly) applying conditionality to claimants with LCWRA. Since 25 November 2024, the online claim includes a specific question about ESA receipt. So hopefully these errors will cease.
6‘ESA claimants who migrate to universal credit should no longer be asked to supply a fit note or have conditionality applied’, Rightsnet news item, 27 November 2024 •Earnings from permitted work. In income-related ESA, these are all ignored. In UC they are not, although a work allowance should apply. The managed migration rules on the transitional element imply, however, that they are ignored for that purpose – which would result in a higher indicative amount and an unfairly low transitional element. However, it seems that in practice the DWP is aware of this issue and is calculating the indicative amount so as to ensure proper transitional protection. Hopefully, therefore, claimants will not lose out.
7The relevant rule is at reg 54 of the Universal Credit (Transitional Provisions) Regulations 2014. For how the DWP seems to be applying it regarding permitted work earnings, see ‘’, Welfare Rights Bulletin 302, October 2024. •‘Erosion’ of the transitional element (and under shared rules, the transitional SDP element). In general, this will be lawful, but ‘cliff-edge’ loss of benefit (in the context of complete loss of protection after moving from specified to standard rented accommodation) has already been held to breach human rights and prompted a change in the rules.
8SSWP v JA (UC) [2024] UKUT 52 (AAC) (19 February 2024), , p12; and the amended rules in SI2025 No.3. See also ‘At a glance – ‘Erosion’ of UC transitional elements’, , June 2024, ‘’, Welfare Rights Bulletin 286, February 2022. Further challenges may follow – in particular, a decision is awaited regarding erosion following a carer becoming entitled to the LCWRA element.
9MJ v SSWP – see
Policy/practice issues
•Will income-related ESA claimants, especially those with additional or safeguarding needs, be adequately supported to make their UC claim? The closure of the Move to UC programme has prompted concern, as expressed to the Work and Pensions Committee by the National Association of Welfare Rights Advisers (NAWRA), that there will be a deficit, not properly compensated for by increased support for the Help to Claim service, which relies on telephony.
10‘’, 28 November 2024, nawra.org.uk •The DWP employs an ‘enhanced support journey’ for a claimant who (with a week to go before their deadline) has not claimed UC. How effective will this prove? The journey involves additional contact, including text messaging and telephone calls, and if that does not result in contact, then a home visit is attempted, with ‘further escalation’ if necessary (see also News in brief, p2, , February 2025). But calls for improvement continue to bemade.
11See, for example, Beneath the Trends – a detailed look at the issue facing claimants going through managed migration, CPAG report, November 2024, available at Initial DWP research into managed migration from ESA indicates that early signs are that, in general, claims for UC are being made by notified claimants.
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