The Independent Review of Carer’s Allowance Overpayments, published in November 2025, found that the prevalence of overpayments related to earnings had been caused not by widespread individual error by carers in reporting their earnings, but by systemic issues preventing them from fulfilling their responsibility to report. This included the Department’s operational guidance that was inconsistent with the governing regulations.54 The Department told us that the guidance it had issued in 2015 had not allowed its staff discretion to average fluctuating earnings where claimants had an irregular earnings pattern, despite the law allowing this.55