Record keeping12 min readReviewed 7 October 2026

Direct Payment reviews: the records to prepare and how to organise them

A practical evidence-pack checklist for council monitoring, with a clear explanation of which requirements are standard and which are set locally.

For Direct Payment employers, council reviewers and support organisations

In brief

Most reviews need to connect money leaving the Direct Payment account with the support or employment cost it paid for.
Bank evidence, invoices or receipts, payroll reports, payslips and timesheets appear repeatedly in council guidance.
The exact form, period and submission route genuinely vary, so use the council's request to finalise—not to invent—the evidence pack.

What a review is trying to establish

A council review is not just a request for a folder of receipts. It needs to establish whether the Direct Payment is meeting the agreed outcomes, whether the money has been used as agreed and whether the arrangement remains appropriate. Where the recipient employs a PA, employment evidence explains a significant part of the account activity.

England requires a review within the first six months and at intervals of no more than 12 months after that. Wales uses the same broad timetable through its statutory code. Scotland separates financial monitoring from welfare monitoring and says the process should be as light-touch as possible. Northern Ireland guidance includes more prescriptive quarterly statement arrangements. These differences affect council process; they do not change the value of keeping a reconciled monthly record.

Prepare this core evidence pack

The following items recur across published council policies. A council may use a prepaid card or managed account and already hold some of them, so do not send duplicates unless asked.

Core review evidence and what it demonstrates
Evidence	What the reviewer can check
Direct Payment account statements or prepaid-card history	Money received, payments made, unspent balance and whether personal spending has been kept separate.
Invoices and receipts	What non-payroll purchases were for and whether they relate to the agreed support.
Payroll summary and individual payslips	Gross pay, deductions, employer costs and net pay for each pay period.
Approved PA timesheets	The dates and hours supporting the payroll input; these should reconcile to the payroll period.
HMRC and pension payment evidence	That withheld deductions and employer liabilities were passed to the appropriate body.
Employers' liability insurance	That current cover is in place where required.
Employment records requested for the review	For example, written terms, leave records, right-to-work check evidence or proof of self-employed status where a worker is genuinely self-employed.

Do not automatically send a DBS certificate.

Some councils list it, others do not, and DBS guidance supports keeping certificate information only as long as necessary. Send identity or safeguarding information only where the request has a clear basis and uses a secure route.

Reconcile one pay period at a time

For each period, the approved hours should lead to the payroll report, and the payroll report should lead to the payments visible in the account. Differences are not automatically wrong, but they need an explanation.

Example reconciliation for one monthly payroll
Record	Example reference	Check
Approved timesheet	PA-01 / September 2026 / 82 hours	Matches the base hours sent to payroll.
Payroll report	Payroll run 2026-09	Shows gross pay, tax, NI, pension and net pay.
Bank payment to PA	30 September / net pay	Matches the payroll report's net-pay figure.
HMRC payment	Tax month 6	Matches the employer liability report or is included in a combined payment.
Pension payment	September schedule	Matches the scheme contribution schedule.

Deal with exceptions before submission

Create a short exception note where the documents do not match at first sight. Useful examples include a payroll correction made in the following month, several employees included in one HMRC payment, a refund, an agreed contingency purchase or a payment that crossed the statement date.

The note should state the amount, date, reason and linked evidence. It should not contain a narrative about the person's care unless that information is necessary to answer the review question.

What actually varies by council

The statement that council requirements differ is true, but it has a limited meaning. Councils do not all use the same monitoring form, request the same date range or collect documents through the same system. Some can inspect prepaid-card transactions directly. Some ask for a Universal Tax Reference where a genuinely self-employed worker is used. Some request employment documents only when a concern arises.

The practical response is straightforward: maintain the core pack above throughout the year, then map it to the council's checklist. If the request is unclear, ask which period, which documents and which secure submission route are required.

—Do not accept a verbal request for sensitive records without confirming the recipient and purpose.
—Do not mix personal account statements with the Direct Payment account evidence.
—Do not send every document held about a PA when a summary or specific record answers the request.
—Do not alter old approvals to remove a discrepancy; retain the correction trail.

Use a review-ready folder structure

—01 Funding agreement and latest support plan
—02 Direct Payment statements by month
—03 Receipts and invoices by month
—04 Payroll reports, payslips and HMRC liabilities by pay period
—05 Approved timesheets, leave and expense decisions by pay period
—06 Pension schedules and payments
—07 Insurance and requested employment evidence
—08 Review correspondence, submitted pack and questions resolved

Sources and further guidance

These links are provided so readers can check the underlying official guidance. Local Direct Payment agreements and individual employment circumstances still need to be considered.