Z2K response to Public Authorities (Fraud, Error and Recovery) Act DWP Codes of Practice consultation
Published February 2026
New powers to directly request claimant bank account information, introduced under the PA(FER) Act, risks exposing more people who rely on social security payments to the risk of incorrect benefit suspensions. Incorrect universal credit suspensions can have severe consequences, pushing claimants – often reliant on it as their sole income – into hardship, debt, and homelessness.
While supporting efforts to reduce fraud, this consultation response calls for the Code of Practice on these powers to include stronger safeguards, clearer limits on powers, improved transparency, and robust protections to ensure fairness and avoid harm to legitimate claimants.
This consultation response focuses on the Eligibility Verification Measure (EVM) Code of Practice, and addresses consultation questions 15, 16 and 32 (relating to the use of the data obtained under the EVM). We disagree that chapter 3 clearly explains how the Department for Work and Pensions will use EVM information, and believe that there are several areas that the EVM Code of Practice has not sufficiently considered. We are of the view that, as currently drafted, the Code of Practice (‘the Code’) does not provide sufficient safeguards against the risk of people entitled to support being pushed into significant financial hardship, destitution and homelessness by having their payments wrongly suspended or terminated as a result of being flagged by data obtained under the EVM.
Z2K's recommendations
- The Code should include a clear and comprehensive list of relevant non-EVM information, aligned to each eligibility indicator, that must be reviewed before an EVM-linked suspension is applied.
- The Code should require that, where a question about someone’s entitlement has arisen as a result of EVM information, the DWP must attempt to contact the affected individual and give them at least one month to provide evidence demonstrating their entitlement prior to suspending their payment.
- The Code should include an exhaustive list of the different types of eligibility indicators the DWP plans to use under the EVM.
- The Code should mandate that EVM information must not result in a payment suspension where there is reason to believe that an affected person would be at risk of hardship as a result.