You’re looking at Reg 76(3) and noting that it does not seem to contain any time limit at all, right?
The argument that there is a limit of 12 (not 13) months relies on s1(2) of the Social Security Administration Act 1992:
“Where under subsection (1) a person is required to make a claim or to be treated as making a claim for a benefit in order to be entitled to it, the person is not entitled to it in respect of any period more than 12 months before the date on which the claim is made or treated as made.”
I think that limits Reg 76(3) to a period of 12 months before the date of claim determined in the usual way under Reg 83.
