National insurance numbers | CPAG

National insurance numbers

Refusal to pay benefit while a claimant is waiting for a NINo to be issued


UC NINo Gatekeeping or delay

Please get in touch (by emailing [email protected]) if you have a client whose Universal Credit has not been paid / payment is delayed because they do not yet have a NINo

JR105 Claimant has applied for but not yet received a NINo and UC not paid/ delayed  (last updated May 2021)

JR106 Claimant has NOT already applied for a NINo and JC+ have not at all, or have not triggered a NINo application before the end of the 1st UC assessment period (last updated March 2021)

child benefit gatekeeping or delay
Please contact [email protected] and we will prepare a template.
PIP NINo Gatekeeping or delay

If your client has experienced ‘gatekeeping’ via the telephone, request a form via post ASAP as well as sending a pre-action letter (or getting in touch with CPAG). The DWP website states:

Claim by post

You can get a form to send information by post (although this can delay the decision on your claim). Write a letter to ask for the form.

Personal Independence Payment New Claims
Post Handling Site B
WV99 1AH


DWP say in response to CPAG correspondence on this issue:

PIP policy colleagues have made enquiries with the DWP Work and Health Services Group who have looked at the concerns you identified with compliance with the guidance where individuals do not have a NiNO.  I understand that changes have been made to ensure compliance, including identifying any cases in addition to those mentioned in your email of 24 March 2021.  
I also understand that the inconsistency on will be addressed* and our clients have offered to review the cases you mention where guidance appears not to have been followed or other cases which may help identify any additional training for call handlers.
If you would like to take up this offer, calls that have no NiNO are difficult to find because they are not linked to a specific reference, so it would be helpful if you can provide the following details:
•       Date and time the call was made
•       The number the call was made from
•       Was the call made to the New claim or Enquiry line

CPAG are keen to ensure compliance with DWP guidance and to resolve individual cases for clients. Please let us know (by emailing [email protected]) if you are contacted by anyone who has, when they have tried to claim PIP, been told they must have a NINo before they can claim. If possible, please include the details requested above. If these details are not held, CPAG are still happy to raise cases with DWP using other identifying details (name, date of birth etc).

* NB the website had not been amended as at 07/07/21:

Claimant with no NINo calls to make PIP claim 
Paper PIP1 form sent to claimant 
Paper PIP1 returned to DWP. DWP create a 'Prospect Person record'
PIP2 'How your disability affects you' sent to claimant
PIP2 returned to DWP
NINo application triggered
NINo allocated. DWP update from 'Prospect Person' to 'Person' recor

The DWP learning guide “PIP17 Paper Claims” (made available in response to a Freedom of Information request), makes clear procedurally what should happen where a claimant makes a claim without a NINo: 
A paper version of the initial claim form (PIP1) will be issued where the claimant or their PAB:

does not have a National Insurance Number (NINO)
The date of claim is then the date that the claimant telephoned to make the claim providing the claim form is retuned within one calendar month:
Claimants have one calendar month from date of issue to complete and return the paper claim form to the issuing office. If returned in time, the date of claim will be the date that the claimant telephoned the Department to request the form or the date a letter requesting the form was received.  
DWP staff guide “PIP New Claim telephony data gather” (also provided in response to the FOI) confirms that a NINo is not required to issue a paper form. 
There is a requirement for minimum data to issue a paper claim form: 
•     Name, address and either date of birth or NINO of claimant
The ‘PIP17 Paper Claims’ and ‘PIP New Claim telephony data gather’ guides for DWP staff are clear that where a claimant does not have a NINo, procedurally a paper claim form should be sent out to the claimant on provision of the claimant’s name, address and date of birth. Provided this is returned within one month, the claim will start from the date of the telephone call. 
The DWP guidance “Missing NINO” (also provided in response to the FOI request) states that following completion of paper PIP1 and PIP2 forms, where no NINo is held by the claimant, DWP will trigger a NINo application on the claimant’s behalf by completion of the DCI1 form:
If a PIP award is appropriate, the CM creates a manual task on PIPCS for the NINO allocation specialist team to take the appropriate action to establish the claimant’s NINO. On receipt of such a task, the Specialist user will complete specialist trace action and if appropriate make further enquiries with the claimant to identify the NINO. If the NINO has still not been established following these enquiries, the Specialist user will complete form DCI1 and refer it to the NINO Centre (NC)… In all cases where a NINO is allocated, the Specialist user will change the Prospect Person record to a Person record in PIPCS and update the Communication Record and create a task to the CM to input the decision.  
Refusal to acknowledge an appointee who does not have a NINo

JR84 appointee does not have a NINo (last updated Aug 2020) (Update pending)


By emailing [email protected]

This helps us keep the letters up to date and effective for other advisers.