What is ELTO?

The Employers' Liability Tracing Office (ELTO) manages a market-wide electronic database of employers' liability (EL) policy records. The database, known as the employers' liability database (ELD) will enable claimants and or their representatives to easily access information about old Employers' Liability insurance policies and help to speed up the process in the event of a potential Employers' Liability claim.

FCA regulations state that since 1 April 2012 insurers must supply:

  • Details of each employer covered by a policy, which will include a full listing of all subsidiary companies
  • The Employer Reference Number (ERN), for the policyholder and each subsidiary employer (if ERN different from parent/policyholder) covered on the policy.

What you need to know

Brokers, particularly those operating delegated authorities (DAs), MGAs and software houses are important stakeholders for ELTO, since they will be the link between the insurer and the client, in capturing policy information for the ELD.

From 1 April 2011: Mandatory policy record data for new and renewed policies to be added to ELD.

From 1 April 2012: Additional information to be supplied, namely full listing of Subsidiary Companies and all ERNs (including those of Subsidiary Companies if different from parent/policyholder).

We can collect the data from you on individual cases or, if you prefer, in volume, through a spreadsheet of all your AXA cases. Individual risk presentations will need to provide all insurers that write EL insurance with the relevant mandatory information required for ELD.

Where to find Employee Reference Numbers (ERNs)

An ERN is allocated to all UK businesses where any employee is paid above the prevailing PAYE threshold. The ERN is shown on the P45, P60, P11/D and many payslips.

A minority of employers do not have an ERN, including those that:

  • Pay all employees below the Lower Earnings Limit, (none of these employees has another job, and none of the employees is in receipt of a state or occupational pension or other employee benefits),


  • Are registered in the Isle of Man, or the Channel Islands (these have no tax presence in the UK).

Some employers may possess more than one ERN, including those operating separate PAYE schemes for different business locations, mergers or company directors. We need to be supplied with all ERNs.

What does the FCA say should be captured and supplied?

The FCA's regulations require insurers capture the following information, within three months of policies incepting or renewing:

  • new and renewed EL policies from 1 April 2011
  • new and old policies for which claims are made on or after 1 April 2011
  • Insured's Full Name
  • Insured's Address
  • Insured's Postcode
  • Insured's Name
  • Policy Number
  • Policy Cover Date
  • Policy Renewal Date
  • from April 2012
  • full list of subsidiary companies
  • ERNs

How are insurers collecting and publishing the EL policy data?

Insurers are collecting EL policy data in different ways. Some insurers are happy for intermediaries to adapt existing Bordeaux, whereas others are requesting information to be supplied in an Excel template.

The FCA's regulations require insurers to publish EL policy data in an easily accessible electronic database. ELD fulfils this requirement.

What information is available for intermediaries?

BIBA has helped to produce a guide specifically for brokers, MGAs and DAs which is available to download. You can also talk to your usual AXA contact and we can give guidance on to make sure that EL policy data is captured and supplied in a consistent way.

Why is there a requirement for the ERN (Employer Reference Number)?

ELTO has adopted the Employer Reference Number (ERN) as the most effective unique identifier available. This is also commonly referred to as 'Employer PAYE Reference'. Insurers will be required to supply the ERN to the ELD, and for policies transacted by a broker or DA, will need them to obtain this information.

Do all companies have an ERN (Employer PAYE reference), if not who is exempt?

UK businesses are required to have the ERN, which is the reference number for their employees' income tax and national insurance contributions. A minority of employers do not have an ERN. The only exemption is where the employer pays all their employees below the PAYE threshold.

What are the timescales for getting the ERN loaded onto ELD?

Since April 2012, insurers are required to supply the EL policy data, including ERNs, for the policyholder and all subsidiaries within 3 months of policy covering incepting or renewing.

Will brokers be able to use ELTO to trace policies for their insurers?

The purpose of ELTO is to provide claimants and or their representatives with information to help them trace an EL insurer. However, brokers will also be able to use the service where their insurer is facing a specific claim and they need to identify their former insurer.

Further information

For more information on current threshold limits, visit Gov UK.

For more information on the threshold limits on ERNs, visit HMRC.

Further information is available on the ELTO website.