Good question – I have genuinely seen both approaches used (and unchallenged by auditors) and have struggled to decide which I consider to be correct.
One clear thing here is that the switch to non-dep (student or otherwise) should be 11th September not 4th. The first day that they are not a QYP is 4th September so it takes effect from the following Monday.
I’ve actually always leaned with reluctance towards the need for a lowest deduction until the term commenced but, having looked at it again today, I feel compelled to find that no deduction is required:
https://www.gov.uk/guidance/understanding-academic-years
This is quite persuasive in determining that they can be viewed as a student from 1st September. HB Regs Part 7 can appear to negate this but, if they are not “a full-time student during a period of study within the meaning of Part 7 (Students)”, what are they?? Surely they must be a student during a recognised summer vacation appropriate to their course – even though they have not yet started…
There’s my starter…
