EIM21845 contains the following:
"For the purposes of this exemption welfare counselling is counselling of any kind except:
- advice on finance, other than advice on debt problems, or
- advice on tax, or
- advice on leisure or recreation, or
- legal advice"
Any of the counselling outlined at EIM21845 would be exempt if provided through an app.
Anything that is not outlined at EIM21845 would be a reportable benefit in kind.