Impact assessment

Post Office Card Account (POCA) – product cessation

Published 5 April 2022

Project objectives

HMRC pays some of its Tax Credit and Child Benefit customers via Post Office Card Accounts (POCA). These accounts are provided to government by Post Office Ltd through a contract held by Department for Work and Pensions (DWP). The existing contract comes to an end on 30 November 2022.

HMRC and DWP (and the other government departments that have been using POCAs) have been contacting customers to tell them of the forthcoming change and the need to therefore move their payments into other bank accounts.

Attempts to contact customers include:

• letter: between HMRC and DWP, a POCA customer will have received up to 12 hard copy pieces of correspondence between Oct 2019 and December 2021

• press and digital: there has already been substantial media coverage. Media activity will continue in early 2022

• GOV.UK: amended the GOV.UK pages to make it clear what action customers need to take

• SMS/Text comms: SMS awareness campaign started mid 2021 and may continue. Outbound telephony has produced a good level of conversion - HMRC will continue with this method of attempted communication until POCA cessation on 5 April 2022

• External Affairs/stakeholders: HMRC have engaged with stakeholders who can help us reach this audience, using their own channels - we will provide Q&A’s and other assets for their use, which will include:

  • entries in Top 100 and MP digest
  • informing Tax Credit Consultation Forum and ISA forums
  • DWP local authority newsletter

HMRC has agreed that it will cease to have monies paid into POCAs with effect from 6 April 2022 (this coincides with the Tax Credit renewal timings).

Customer groups affected

The customer groups affected by the scheme are:

• 5,600 individual child benefit recipients

• 2,000 individual tax credit recipients

What customers will need to do

What customers need to do as a result of the change

Customers will need to notify HMRC of an alternative bank account in which to receive their tax credit and child benefit.

How customers will access this service.

Alternative account details can be provided by phone, by letter, by completing and returning a form already sent, or by accessing the Personal Tax Account.

When customers need to do this

Customers must notify HMRC of an alternative bank account by the 5 April 2022. In the most exceptional circumstances where customers cannot obtain a bank account, an alternative method of payment will be considered.

Assessing the impact

We assessed the equality impacts on all the protected characteristic groups in line with the Equality Act and Public Sector Equality Duty; and section 75 of the Northern Ireland Act:

• gender reassignment
• sexual orientation
• age
• Religion or belief
• pregnancy and maternity
• marriage and civil partnership
• people with or without dependents
• political opinion (for Northern Ireland only)

There is no evidence to suggest any specific impacts on those customers within any of the protected characteristic groups (listed above).

Mitigations applicable to all customers

HMRC will telephone all remaining HMRC POCA customers (for which we hold telephone numbers) and remind them of the need to convert by 5 April 2022.

HMRC have consulted with representative bodies though the Tax Credits Consultation Forum and multiple other bodies, eg moneyhelper.org.uk. These parties have agreed to publicise the change on the various websites they own.

If it is noted through customer liaison that a customer is experiencing extraordinary challenges in opening a bank account that customer (or their representatives) will be directed to HMRC’s Extra Support Team for bespoke help (which may include voucher payment).

Racial groups

Impact on customers

HMRC does not hold protected characteristics information on POCA customers other than sex. We do not anticipate any specific impacts on the stated ‘protected characteristics’ noted in this document.
 However, we recognise that some customers encounter language challenges.

Proposed mitigation

To mitigate language issues HMRC staff are able to access interpretative resources as part of ‘business as usual’.

For customers where HMRC holds details of an authorised ‘other’ (appointee) who acts on the customers behalf, contact will be directed to that individual (letters).

Disabled

Impact on customers

Some customers will require additional support to understand what they need to do.

Proposed mitigation

Customers or their representative who required additional support will be directed to HMRC’s Extra Support Team. For customers where HMRC holds details of an authorised ‘other’ (appointee) who acts on the customers behalf, contact will be directed to that individual (letters).

Sex

Impact on customers

A greater proportion of women than men are the recipients of Child Benefit payments. This is a conscious decision and relates to legislative/regulatory direction.

In consequence it should be noted that there is a conscious, positive bias to pay the female/maternal role in any partnership applying for Child Benefit payments.

However, the removal of POCA as a payment receipt platform will not discriminate based on sex as all POCA accounts are being withdrawn.

People who use different languages (including Welsh language and British Sign Language)

Impact on customers

Some.

Proposed mitigation

To mitigate language issues HMRC staff are able to access interpretative resources as part of ‘business as usual’.

All outgoing HMRC communications to identified Welsh language customers is translated and issued (including bilingual options where required).

Opportunities to promote equalities

We have considered opportunities to promote equalities and good relations between people in each of the protected characteristic groups and those outside of that group.

None have been identified.

A full equality impact assessment is not recommended.