This Practice Note looks at when a claimant is entitled, subject to evidence in support, to recover any past loss of earnings. It considers both the conventional approach and alternative approach to calculating this loss. Conventionally, a past loss of earnings claim is calculated by reference to a claimant’s average earnings for 13 weeks prior to the accident. The conventional approach may be inappropriate if a claimant’s earnings fluctuated before the accident or if a promotion, bonus or pay rise was anticipated. The impact of employee benefits on the calculation is considered as well the evidence that may be required if a claimant is self-employed or unemployed.