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		<title>Through the Roof: How to reduce housing benefits spending</title>
		<link>https://ukonward.com/reports/through-the-roof-how-to-reduce-housing-benefits-spending/</link>
		
		<dc:creator><![CDATA[Caroline Elsom]]></dc:creator>
		<pubDate>Tue, 06 Oct 2026 09:09:57 +0000</pubDate>
				<category><![CDATA[Reshaping the State]]></category>
		<category><![CDATA[Welfare]]></category>
		<category><![CDATA[Housing]]></category>
		<guid isPermaLink="false">https://ukonward.com/?post_type=reports&#038;p=42311</guid>

					<description><![CDATA[<p>Foreword For too long we have failed to ask hard questions about the state of Britain’s housing benefit system. Growth in the cost of housing benefits has been relentless &#8211; with a nearly 20% increase in spending projected over just 5 years – and costs set to reach £44 billion by the end of the [&#8230;]</p>
<p>The post <a href="https://ukonward.com/reports/through-the-roof-how-to-reduce-housing-benefits-spending/">Through the Roof: How to reduce housing benefits spending</a> appeared first on <a href="https://ukonward.com">Onward</a>.</p>
]]></description>
										<content:encoded><![CDATA[
<h3 class="wp-block-heading has-text-color has-link-color wp-elements-16" style="color:#c2203f">Foreword</h3>



<p class="wp-block-paragraph">For too long we have failed to ask hard questions about the state of Britain’s housing benefit system. Growth in the cost of housing benefits has been relentless &#8211; with a nearly 20% increase in spending projected over just 5 years – and costs set to reach £44 billion by the end of the decade.</p>



<p class="wp-block-paragraph">We have not asked if this is fair. Fair to taxpayers, paying their own rents and mortgages. Fair to housing benefit claimants in the private rental sector, where the generosity of housing benefits seesaws unpredictably through freezes and uplifts, with no ability to plan. Or fair to families who really and often urgently need a stable roof over their heads, stuck on council waiting lists whilst high earners – and even some foreign nationals – benefit from lifetime tenancies.&nbsp;</p>



<p class="wp-block-paragraph">This excellent paper asks these fundamental questions. It makes a compelling case that so much of our housing benefit system is failing. It sets out a range of thoughtful proposals for how government can control costs and build a better, fairer system. As we do the hard work in opposition to plan our reforms to housing benefits, I welcome contributions like this that add to this vital debate.&nbsp;</p>



<p class="wp-block-paragraph">Fixing housing benefits and social housing is a difficult but essential challenge. We must ensure our housing stock and the benefits that fund it support those most in need and enable opportunity, rather than incentivising people to remain stuck in homes that hard-up taxpayers can ill-afford to subsidise. Yet the most urgent pressure is to grip the system and end the inexorable rises in spending that form a growing part of our ballooning welfare bill. This package is a compelling solution to that pressing problem.</p>



<p class="wp-block-paragraph"><strong>Helen Whately</strong></p>



<p class="wp-block-paragraph"><strong>Shadow Secretary of State for Work &amp; Pensions</strong></p>



<h3 class="wp-block-heading has-text-color has-link-color wp-elements-17" style="color:#c2203f">Introduction</h3>



<p class="wp-block-paragraph">Housing is the largest single living expense that most families face. Many people work and save for years to own their home outright to be freed from high housing costs. But another group is also living rent-free, with their costs met by the state. One in five households in Britain have their housing costs covered at least in part by the benefits system, through Housing Benefit or the Universal Credit housing element.<a href="#_ftn1" id="_ftnref1">[1]</a> This is equivalent to all the households in England’s nine largest cities combined.<a href="#_ftn2" id="_ftnref2">[2]</a></p>



<p class="wp-block-paragraph">Paying the rent of over 5.75 million households a year comes with a heavy price &#8211; one that is rising fast. Official forecasts suggest that by the end of the decade, the cost of housing benefits will be more than double the cost in 2018.<a href="#_ftn3" id="_ftnref3">[3]</a> Even this alarming trajectory is severely under-pricing recent and upcoming policy decisions which will accelerate costs further. By the end of the next parliament, core housing benefits spending could exceed £52 billion, up from £30 billion today.<a href="#_ftn4" id="_ftnref4">[4]</a></p>



<p class="wp-block-paragraph">This paper reveals that the current estimates for future housing welfare spending are implausibly low and builds a more realistic baseline for spending in the private and social rented sectors for households without additional housing support needs. It then looks at how this higher projected spending can be brought under greater control quickly and without the need for new primary legislation, saving £4.5 billion a year by the end of the next parliament in 2033/34.</p>



<p class="wp-block-paragraph">Without the usual price signals that drive other renters to choose carefully a home in the right location they can afford, the benefits system creates an array of perverse incentives for claimants that are neither in their best interests, nor in taxpayers’. As well as addressing the unsustainability of housing benefits spending, this paper also considers ways to correct some of the underlying unfairness to those paying for both their own housing and their neighbours’.</p>



<h3 class="wp-block-heading has-text-color has-link-color wp-elements-18" style="color:#c2203f">Home truths</h3>



<p class="wp-block-paragraph">Housing benefits are paid by the Universal Credit (UC) housing element to most working age claimants or by Housing Benefit (HB) to pension age claimants, those with additional housing support needs and those still on legacy working age benefits.<a href="#_ftn5" id="_ftnref5">[5]</a> These benefits are paid on different terms to those in the private rented sector and those in the social rented sector, creating a series of perverse incentives:</p>



<ol start="1" class="wp-block-list">
<li><strong>Geographic generosity –</strong> Claimants in the private rented sector can choose to live in more expensive areas and receive a higher value subsidy from the taxpayer to do so. Rates paid for housing benefits in the private rented sector are set based on the distribution of local market rents. In the social rented sector, properties are allocated via local lists that provide well below-market rents, which housing benefits can cover in full, linked to the shape of the property and labour market in 1999. </li>
</ol>



<ol start="2" class="wp-block-list">
<li><strong>Tenure security –</strong> Social housing is awarded based on an assessment of need at a particular point in time. A majority of social tenancies are awarded on a lifetime basis, even if the occupants no longer meet the allocation rules or are no longer eligible for housing benefits at all. Lifetime security at a highly subsidised rent creates an incentive to gain priority on local housing lists through crisis, often via statutory homelessness duties and temporary accommodation, which are the route to 28% of new social lettings.<a href="#_ftn6" id="_ftnref6">[6]</a></li>
</ol>



<ol start="3" class="wp-block-list">
<li><strong>Labour mobility</strong> <strong>–</strong> Social housing allocation policies reward those with a continuous record of residence in the area. Local connection tests advantage those who stay within a council area, even if moving elsewhere may help to find work. While there is some incentive to earn enough to be exempted from the benefit cap, there is a stronger incentive to claim incapacity and disability benefits in order to be exempted from the cap if housing benefits do not fully cover rent.</li>
</ol>



<p class="wp-block-paragraph">The dynamics governing how claimants respond to housing benefits policy sit both within the housing benefits themselves, and in the wider structure of the benefit system and local government. This paper focuses on measures possible within allowances and rent-setting that could be implemented immediately at the start of a new parliament in 2029/30, without changing allocation policies, work conditionality, tenancy terms or other benefit eligibility.</p>



<p class="wp-block-paragraph">With so many reasons to stay dependent on the welfare state or choose more expensive areas from which to draw housing benefits, the impact on the public finances should be no surprise. The latest 2026 Spring Forecast indicates that housing benefits spending will be the same proportion of welfare spending this financial year as it was in 2010/11 at 10.9%.<a href="#_ftn7" id="_ftnref7">[7]</a> Against a much larger overall welfare bill, this stubborn constancy in share is concerning, especially as housing benefits were an area of spending restraint through much of the intervening period.&nbsp;</p>



<p class="wp-block-paragraph">After a period of cutting, capping and freezing affecting both tenures in the 2010s, housing benefits spending dipped to £20.7 billion by 2018/19. This was followed by two sharp increases when allowances were restored to the 30th percentile of local market rents in 2020 and again in 2024. In the current financial year, £38.8 billion is forecast to be spent on housing benefits.<a href="#_ftn8" id="_ftnref8">[8]</a> By 2030/31, this is expected to exceed £43.5 billion &#8211; more than double the cost in 2010/11 or 2018/19.</p>



<p class="wp-block-paragraph"><strong>Figure 1 &#8211; Housing benefits spending, 2010/11-2030/31</strong></p>



<p class="wp-block-paragraph"><em>Source: DWP, Benefit expenditure and caseload tables 2026</em><a href="#_ftn9" id="_ftnref9">[9]</a></p>



<div class="flourish-embed flourish-chart" data-src="visualisation/30357056"><script src="https://public.flourish.studio/resources/embed.js"></script><noscript><img decoding="async" src="https://public.flourish.studio/visualisation/30357056/thumbnail" width="100%" alt="chart visualization" /></noscript></div>



<p class="wp-block-paragraph">The increase across the forecast period shows that, even with an assumed continuation of the private rented sector freeze, there is no sign that spending will start to come down as it did during the freeze in the latter half of the 2010s. Likewise, in the social rented sector forecast, the increase in permitted social rent rises in the latest Rent Settlement will add an average of £300 million a year to housing benefits spending.<a href="#_ftn10" id="_ftnref10">[10]</a> Even with the private rented sector freeze in place, total spending continues to rise sharply.</p>



<p class="wp-block-paragraph">The deeper problem with this already bleak forecast for the public finances is that it does not even begin to capture the true extent of likely housing benefits growth within the forecast period and beyond. The section that follows explains why the forecast is implausible and seeks to build a more likely baseline from which savings from policy changes can then be measured.</p>



<h4 class="wp-block-heading has-text-color has-link-color wp-elements-19" style="color:#c2203f">Thawing private rented sector support</h4>



<p class="wp-block-paragraph">The forecast assumes that the current freeze in Local Housing Allowance (LHA) rates that keeps rates at 2024/25 levels will continue at least until 2030/31. This is based on the 2026 Spring Forecast stating that LHA rates will remain frozen until at least March 2027.<a href="#_ftn11" id="_ftnref11">[11]</a> The OBR simply takes the current policy and has no choice but to assume it continues, absent an affirmative policy decision beyond next March. To understand why the freeze being renewed in the next financial year is highly improbable, it is first necessary to understand how LHA rates are set in policy and legal terms.</p>



<p class="wp-block-paragraph">LHA rates are the maximum weekly rate of housing benefits claimants in the private rented sector can receive. Claimant households receive benefits for the full amount of their rent if it is lower than this rate, or part of their rent up to this maximum. Households may receive less after their rate has been applied, such as if their total benefit award exceeds the benefit cap or if they have savings above certain thresholds. There are also national caps that apply to LHA rates in the most expensive areas.</p>



<p class="wp-block-paragraph">The rate applied depends on which area a claimant lives in, known as the Broad Rental Market Area (BRMA), and the bedroom eligibility of the household. Size criteria for LHA rates usually allow one bedroom for each of the following: a couple; any other person aged 16 or over; two children of the same sex; two children under 10 regardless of sex; and any other child. Eligibility is capped at four bedrooms however large the household. A single claimant under 35 with no dependants is limited to the shared accommodation rate (the rate for a room in a shared house) rather than the one-bedroom rate, subject to exemptions for disability or vulnerability.</p>



<p class="wp-block-paragraph">There are 192 BRMAs in Great Britain, varying in size and population. In England, rates are calculated by Valuation Office Rent Officers collecting a sample of rental information from letting agents, landlords and tenants about private market rents each year. In Wales, they are set by Rent Officers Wales and in Scotland by the Rent Service Scotland via a similar process. From these lists of rents, Rent Officers are bound by legislation to calculate the 30th percentile of local rents for each BRMA.<a href="#_ftn12" id="_ftnref12">[12]</a> Secondary legislation is then laid each year for which a freeze is applied to override this policy.<a href="#_ftn13" id="_ftnref13">[13]</a> These negative instruments can be “prayed against” in the House of Commons or the House of Lords, which can lead to debate on the issue. The statutory default remains to uplift rates to the 30th percentile in each area each year, not a continuous freeze.</p>



<p class="wp-block-paragraph">Second, the current freeze has already eroded the value of LHA rates significantly, making even one further year of freeze difficult for the government to sustain. Shortly after the last uplift to the 30th percentile in 2024, 45.6% of private resented sector households on UC with a housing element were subject to an LHA rate that did not fully cover their rent.<a href="#_ftn14" id="_ftnref14">[14]</a> In the latest month for which information is available, shortfalls stand at 58.2%. By April 2027, the number of claimant households with shortfalls is on course to have well exceeded the number with shortfalls directly before the last LHA rate uplift to the 30th percentile, and has likely surpassed one million already.<a href="#_ftn15" id="_ftnref15">[15]</a></p>



<p class="wp-block-paragraph">Already, the size of the gap between LHA rates and the affordability of tenancies is significant. In 2026/27, out of the 960 different BRMAs and bedroom categories, 34% already have frozen LHA rates that are lower than the 10th percentile of local market rents in that year.<a href="#_ftn16" id="_ftnref16">[16]</a> In the next financial year when the freeze or uplift decision comes, this is likely to exceed 55% of areas and bedroom categories, based on the ten-year average of ONS price index of private rents (PIPR).<a href="#_ftn17" id="_ftnref17">[17]</a> By 2030/31, 95% are likely to be below the 10th percentile.</p>



<p class="wp-block-paragraph">The extent of the shortfall between the default 30th percentile and a continuation of the LHA freeze at 2024/25 rates into next year is acute. The gap between the likely 30th percentile of market rents for 2027/28 and a continued freeze of LHA rates will leave an average shortfall of around £156 per month. For larger properties, the gap is even more cavernous, with four-bedroom frozen LHA rates an average of £241 per month below the 30th percentile. Even in the BRMAs with the median shortfall across all bedroom categories &#8211; Wigan and Barrow-in-Furness &#8211; the gap is around £135 per month. For claimant households, these mounting gaps represent a significant share of their total awards, making it difficult to bridge the shortfall from other parts of their benefits awards.</p>



<p class="wp-block-paragraph">Claimants who entered private rented sector tenancies that were at or above the LHA rate at the 30th percentile in 2024 will likely have experienced a profound erosion in what their housing benefits cover. They would not have known when taking on the tenancy that their housing award would remain frozen for years afterwards as their rent increased. Tenants cannot make long-term decisions about which properties and areas are affordable for their family circumstances, including for sustaining employment, if housing benefits rates see-saw between generous leaps and punitive freezes at unpredictable intervals.</p>



<p class="wp-block-paragraph"><strong>Figure 2 &#8211; Average monthly difference between 30th percentile and frozen LHA rates in 2027/28</strong> </p>



<p class="wp-block-paragraph"><em>Source: Onward analysis, MHCLG, Welsh Government, Scottish Government and ONS PIPR data</em><a href="#_ftn18" id="_ftnref18">[18]</a></p>



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<p class="wp-block-paragraph">Third and finally, there is the political likelihood of the freeze continuing into next year or longer. The current freeze has held LHA rates at the same cash level for three years already. If it continues into next year, it will be on par with the 2020/21 to 2023/24 freeze and one year off the 2016/17 to 2019/20 freeze.<a href="#_ftn19" id="_ftnref19">[19]</a> Continuing to 2030/31, as per the OBR forecast assumption, would be the longest LHA freeze ever. Given how fiercely these long freezes were opposed by those now on the government side, it will be increasingly challenging to maintain discipline in support of this position.</p>



<p class="wp-block-paragraph">The likelihood of the Government supporting another year of a freeze is reduced by the fact that Labour’s original LHA rates were far more generous than the 30th percentile. When LHA rates were introduced during the last Labour Government, they were set at the 50th percentile (median rent). In addition, if tenants chose tenancies with rents below the median, they were allowed to keep up to £15 per week of the cash difference to encourage them to choose cheaper properties than the maximum and avoid rent inflation up to the median. Claimants could also be eligible to claim for up to five bedrooms, rather than four. The case for reverting to these policy positions was made vociferously by opposition parties during the coalition and Conservative governments.</p>



<p class="wp-block-paragraph">This historic position has not been forgotten. Ahead of the decision to freeze LHA rates last year, the then Labour Chair of the Housing, Communities and Local Government Select Committee, Florence Eshalomi MP, lent her support to a coalition of forty organisations calling on the government to restore LHA rates to at least the 30th percentile and to assess the impact of returning to the median.<a href="#_ftn20" id="_ftnref20">[20]</a> She is now a Minister of State in MHCLG. Early Day Motions were signed by Labour, Liberal Democrat, Green and Plaid Cymru MPs calling for LHA rates to be restored to the median.<a href="#_ftn21" id="_ftnref21">[21]</a> The chorus of stakeholders calling for an end to the freeze has only become louder this year.<a href="#_ftn22" id="_ftnref22">[22]</a></p>



<p class="wp-block-paragraph">The Prime Minister himself has repeatedly referred to the damaging impact of LHA freezes and the need for regular uplifts. In a major speech as the candidate to become the Labour leader in June 2026, three weeks before becoming Prime Minister, Andy Burnham stated:</p>



<blockquote class="wp-block-quote is-layout-flow wp-block-quote-is-layout-flow">
<p class="wp-block-paragraph">“We are forced to chase rents in the private-rented sector through the benefits system. When governments try to control these costs by freezing Local Housing Allowance, it makes families homeless and places unfunded pressures on councils when they have to pay for temporary accommodation.”<a href="#_ftn23" id="_ftnref23"><strong>[23]</strong></a></p>
</blockquote>



<p class="wp-block-paragraph">This landmark speech is consistent with his earlier calls for ending the freeze to reflect rental market conditions. A fortnight before the November 2025 Budget, while Mayor of Greater Manchester, he called for “restoring LHA to reflect real rental costs,” although he fell short of specifying whether this means median rents or another market link.<a href="#_ftn24" id="_ftnref24">[24]</a> When the previous uplift to the 30th percentile was announced in the 2023 Autumn Statement, he issued a press release saying, “one of our biggest calls has been the urgent need to unfreeze Local Housing Allowance and I am pleased that the Chancellor has listened.”<a href="#_ftn25" id="_ftnref25">[25]</a></p>



<p class="wp-block-paragraph">Recent Resolution Foundation analysis casts doubt on the Prime Minister’s claim about benefits chasing, or driving up, rents in the private rented sector. Findings indicate that only around 10p in every pound of uplift was fed through to higher rents at the bottom of the market after the April 2024 uplift.<a href="#_ftn26" id="_ftnref26">[26]</a> This means the Prime Minister has less need to avoid the uplift out of a principled aversion to passing on the increase to private landlords.</p>



<p class="wp-block-paragraph">Against this legislative, affordability and political backdrop, it is highly improbable that a freeze will continue into the next financial year, let alone through to the end of 2030/31 as the Spring Forecast assumes. This context is consequential for any incoming government after the next election. Housing benefits spending will almost inevitably be materially higher than is expected currently &#8211; and the imperative to exert spending restraint will be overwhelming.&nbsp;</p>



<h4 class="wp-block-heading has-text-color has-link-color wp-elements-20" style="color:#c2203f">Resetting the private rented sector baseline</h4>



<p class="wp-block-paragraph">This paper models a plausible baseline for private rented sector housing benefits spending: it assumes that LHA rates are uplifted to the 30th percentile each year from 2027/28, in line with the legislative default. A list of the key assumptions is given below.</p>



<p class="wp-block-paragraph"><strong>Figure 3 &#8211; Private rented sector baselines</strong></p>



<p class="wp-block-paragraph"><em>Source: Onward analysis, DWP outturn and forecast, Spring 2026</em><a href="#_ftn27" id="_ftnref27">[27]</a></p>



<p class="wp-block-paragraph"></p>



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<h6 class="wp-block-heading">Assumption 1 &#8211; Distribution of rents</h6>



<p class="wp-block-paragraph">To create this baseline, the model analyses the latest Valuation Office lists of local market rents, known as the Shadow List of Rents, and the devolved equivalents, to commence with the latest snapshot of the distribution of market rents by BRMA on the same basis that LHA rates are set.<a href="#_ftn28" id="_ftnref28">[28]</a></p>



<h6 class="wp-block-heading">Assumption 2 &#8211; Rent growth</h6>



<p class="wp-block-paragraph">The model then applies the ten-year average growth rate from the ONS’s PIPR to estimate how rents rise until the end of the next parliament in 2033/34.<a href="#_ftn29" id="_ftnref29">[29]</a> At a national level, the compound annual growth rate is 3.81%. This aligns with the latest PIPR, which shows average UK monthly private rent increased by 3.8% in the 12 months to August 2026.<a href="#_ftn30" id="_ftnref30">[30]</a> If more recent multi-year compound annual average growth rates were used, such as three or five years, the rate would be materially higher, at around 6% nationally. A ten-year average is used to avoid embedding distortion from the period following the Covid-19 pandemic when rents surged and to avoid possible local anomalies from taking single year values alone.</p>



<h6 class="wp-block-heading">Assumption 3 &#8211; Caseload shares by bedroom rate</h6>



<p class="wp-block-paragraph">In order to model how many claimants are eligible for different LHA rates, it is necessary to estimate the proportions of claimants in each BRMA and each bedroom rate. For example, some areas will attract a higher proportion of younger claimants only eligible for the shared accommodation rate, whereas others will have more family homes at the lower end of the rental market and therefore attract a higher proportion eligible for three- and four-bedroom rates.</p>



<p class="wp-block-paragraph">As UC household caseload data does not split by bedroom category, nor gives sufficient detail on household characteristics from which to estimate this, bedroom level caseload proportions applied for each BRMA are based on bedroom category proportions from 2018 Housing Benefit caseload data. While this is lagged, it is the last year before managed migration to UC began, giving the most up to date and reasonably complete picture of the general shape of the entire caseload by eligible bedrooms in each area.<a href="#_ftn31" id="_ftnref31">[31]</a> At a national level, just over two thirds of the caseload were eligible for one or two bedroom rates, with the rest split between three bedrooms, the shared accommodation rate and four-bedroom rates in descending order of proportion.</p>



<p class="wp-block-paragraph"><strong>Figure 4 &#8211; National share of private rented sector caseload by bedroom eligibility, April 2018</strong></p>



<p class="wp-block-paragraph"><em>Source: Onward analysis, DWP Stat-Xplore</em><a href="#_ftn32" id="_ftnref32">[32]</a></p>



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<h6 class="wp-block-heading">Assumption 4 &#8211; Caseload growth</h6>



<p class="wp-block-paragraph">Next, the model assesses how much the caseload is likely to grow in each BRMA across the seven year time horizon, against which the bedroom shares for that area are applied. Caseload growth rates are calculated from the compound annual growth rate in caseload across those receiving housing benefits through UC and HB in each BRMA since April 2018.<a href="#_ftn33" id="_ftnref33">[33]</a> Extreme outliers in caseload growth are capped to ensure that the total growth remains in line with the overall national rate.</p>



<h6 class="wp-block-heading">Assumption 5 &#8211; Average award</h6>



<p class="wp-block-paragraph">There is no published breakdown of the amount of UC award claimants receive from just the housing element, let alone by each BRMA and for each bedroom category. Again, the model relies on HB, taking the latest month for which data is available for each LA (then converted to BRMA) and each bedroom category.<a href="#_ftn34" id="_ftnref34">[34]</a> This is then calibrated against the 2026 Spring Forecast, which gives the only breakdown of how much is spent in total on UC housing element in the private rented sector as a separate component within awards to combine with private rented sector HB awards.<a href="#_ftn35" id="_ftnref35">[35]</a></p>



<h6 class="wp-block-heading">Assumption 6 &#8211; Rent less than LHA adjustment</h6>



<p class="wp-block-paragraph">To reflect that housing benefits in the private rented sector pay the lower of LHA rates and rent, an adjustment factor is modelled to give an implied pass through of any change in rate. Claimants who already have a shortfall between their LHA rate and rent stand to benefit from a rate rise to the 30th percentile, whereas those for whom the frozen LHA rates still cover their rent will see no change from an uplift.</p>



<p class="wp-block-paragraph">Those with rents that sit somewhere between the old LHA rate and the new one will gain part of the uplift amount. The model considers the number of claimants in each BRMA that have rents above the previous year’s LHA rate, the gap between old and new LHA rate and where rents are likely to sit between the old and new rates according to the local rent growth rate. At a national level, the model estimates a pass through to benefits of 56.3%.<a href="#_ftn36" id="_ftnref36">[36]</a></p>



<h4 class="wp-block-heading has-text-color has-link-color wp-elements-21" style="color:#c2203f">Social renting like it’s 1999</h4>



<p class="wp-block-paragraph">The UK still has one of the largest social rented sectors in Europe as a proportion of total dwellings, despite the stock declining steadily since the 1980s.<a href="#_ftn37" id="_ftnref37">[37]</a> There are around 3.4 million homes for general needs social rent, and a further 400,000 for general needs affordable rent.<a href="#_ftn38" id="_ftnref38">[38]</a> The almost three quarters of the sector that comprises general needs social rent is governed by a jumble of archaic rent policies, tied to the shape of the labour and property market in 1999.</p>



<p class="wp-block-paragraph">Before the millennium, there was no single basis for setting social rents, with a series of policy changes through the 1970s and 80s having led to wide rent variation between both council housing and housing association tenants, as well as between newer tenants and longstanding ones. From 2002, a new rent-setting policy was introduced, called formula rent, which was meant to provide a single basis for the vast majority of social rents after a ten-year period of gradual adjustment.</p>



<p class="wp-block-paragraph">The basic input values and caps for formula rent are based on 1999 figures, including individual property values, manual worker earnings and rent distributions from properties of different sizes. This snapshot means formula rent is comparatively lower than market rents in London, while it over-values rents in other areas that have experienced decline.</p>



<p class="wp-block-paragraph">After a long period of social rent cuts and caps from 2015, only around a quarter of eligible social tenancies have converged up to formula rent. Just 0.1% of local authority social rents and 43% of private registered provider social rents have arrived at formula rent.<a href="#_ftn39" id="_ftnref39">[39]</a> Lack of progress towards a single social rent-setting basis means that social rents and their associated housing benefits costs are still determined by a mismatch of legacy inputs. There are also discrepancies between housing benefits in the social rented sector and the private rented sector in how bedrooms are weighted in rent calculations, with more generous allowances for very large homes in the social rented sector compared to four in the private rented sector.</p>



<p class="wp-block-paragraph">Soon after the 2024 general election, the new government consulted on changes to social rent policies. However, it declined to re-open the underlying basis of formula rent, citing a need to move quickly and avoid instability or uncertainty in the sector.<a href="#_ftn40" id="_ftnref40">[40]</a> Instead, the scope was limited to the annual uprating basis (and some minor technical amendments).</p>



<p class="wp-block-paragraph">In January 2026, the Government confirmed that convergence would resume over a ten-year period, stepping up to £1/week from April 2027, rising to £2/week from April 2028 onwards, on top of CPI+1%.<a href="#_ftn41" id="_ftnref41">[41]</a> Social rents above formula rent and affordable rents can increase by CPI+1% only. Accelerating towards a rent goal linked indelibly to a formula based in conditions over a quarter of a century old will further embed distortion in the sector.</p>



<h4 class="wp-block-heading has-text-color has-link-color wp-elements-22" style="color:#c2203f">Splitting the social rented sector baseline</h4>



<p class="wp-block-paragraph">The array of different stock types, rent-setting bases and benefit eligibility means the trajectory of housing benefits in the social rented sector is far more complex to project into the future than the private rented sector. The Spring 2026 forecast for housing benefits in the social rented sector captures a reasonable baseline for this tenure type to 2030/31 in Great Britain. Crucially, it includes a significant policy change announced in January 2026, which will accelerate English social rent increases across the period, beyond the usual CPI+1%.<a href="#_ftn42" id="_ftnref42">[42]</a> <strong><br></strong></p>



<p class="wp-block-paragraph"><strong>Figure 5 &#8211; Social rented sector tenures and benefit eligibility</strong></p>



<figure class="wp-block-table"><table class="has-fixed-layout"><tbody><tr><td>&nbsp;</td><td><strong>Paying benefit</strong></td><td colspan="2"><strong>Eligible costs</strong></td></tr><tr><td>General needs</td><td><strong>Working age:</strong> UC housing element (+HB legacy) <strong>Pension age:</strong> HB</td><td><strong>Social rent:</strong> Actual rent + eligible service charges</td><td><strong>Affordable rent:</strong> &lt;80% market rent (including service charges)</td></tr><tr><td>Supported housing</td><td>HB</td><td><strong>Social rent:</strong> Actual rent + eligible service charges +IHM if applicable</td><td><strong>Affordable rent:</strong> &lt;80% market rent (including service charges) + IHM if applicable</td></tr></tbody></table></figure>



<p class="wp-block-paragraph">Housing benefits awards are a reserved matter, but rent setting policies are devolved. To assess the impact of the social rented sector rent policies discussed in this paper, it is therefore necessary to model a more limited baseline than the Spring 2026 forecast to exclude Scotland and Wales, service charges, supported housing (and the associated intensive housing management costs, or IHM) and temporary accommodation costs paid by DWP.</p>



<p class="wp-block-paragraph">This paper’s baseline therefore only includes general needs social rented sector claimants in England whose rent type is social rent (excluding eligible service charges) or affordable rents. The starting difference in baselines between the 2026 Spring Forecast for the relevant combined categories and the modelled baseline is therefore largely down to service charges being excluded in the model. By 2030/31 the modelled baseline moves above the Spring 2026 forecast baseline due to more recent higher-than-expected inflation forecasts used for uprating purposes.<a href="#_ftn43" id="_ftnref43">[43]</a></p>



<p class="wp-block-paragraph"><strong>Figure 6 &#8211; England general needs social rented sector baselines</strong></p>



<p class="wp-block-paragraph"><em>Source: Onward analysis, DWP outturn and forecast, Spring 2026</em><a href="#_ftn44" id="_ftnref44">[44]</a></p>



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<h6 class="wp-block-heading">Assumption 1 &#8211; Stock splits</h6>



<p class="wp-block-paragraph">Stock, tenure and average rents by local authority and bedroom size come from the Regulator of Social Housing&#8217;s 2025 statistical data returns for private registered providers (PRPs) and local authority registered providers (LARPs).<a href="#_ftn45" id="_ftnref45">[45]</a> The model calculates formula rent for each authority and bedroom size according to the methodology in the 2026 policy statement on rents for social housing and January 1999 property values.<a href="#_ftn46" id="_ftnref46">[46]</a> It calibrates this to the Regulator&#8217;s published formula rents and compares it with actual rents. Homes below formula rent are treated as still converging.</p>



<h6 class="wp-block-heading">Assumption 2 &#8211; Turnover and rent paths</h6>



<p class="wp-block-paragraph">Each April, social rents can rise by the previous September&#8217;s CPI+1%. For social rent, the different rent policies are applied for those above formula rent or still converging up to it across the period according to the 2026 Rent Settlement terms. Estimated turnover is calculated from official social housing lettings data, showing a national churn rate of 4.97% per year.<a href="#_ftn47" id="_ftnref47">[47]</a> In line with modelling from the Chartered Institute of Housing, the National Housing Federation and others, it is assumed that providers re-let vacant properties at formula rent.<a href="#_ftn48" id="_ftnref48">[48]</a> Affordable rent is modelled using the Shadow List of Rents for local market rent data with CPI+1% applied.<a href="#_ftn49" id="_ftnref49">[49]</a> Both paths use the latest CPI forecasts compiled by HMT or 2% for beyond that horizon (for 2029 uprating onwards).<a href="#_ftn50" id="_ftnref50">[50]</a></p>



<h6 class="wp-block-heading">Assumption 3 &#8211; Stock growth</h6>



<p class="wp-block-paragraph">A new Social and Affordable Homes Programme was introduced in 2026, shifting the priority towards social rent homes.<a href="#_ftn51" id="_ftnref51">[51]</a> Previous local stock growth rates are measured from the Regulator of Social Housing stock data between 2020 and 2025.<a href="#_ftn52" id="_ftnref52">[52]</a> These rates are then scaled down for affordable rent and up for social rent to reflect the new planned tenure mix. While the new Prime Minister has indicated that he will expand social rent building further, there are not yet details sufficient to quantify this.</p>



<h6 class="wp-block-heading">Assumption 4 &#8211; Housing benefits factor</h6>



<p class="wp-block-paragraph">As rents change, not all of this feeds through into housing benefits awards, because some tenants are not claimants and some claimants have deductions from their awards (such as the under-occupation deduction or the benefit cap). The draft Impact Assessment for the 2026 rent convergence policy notes that social security impacts are calculated as two thirds of the change in rental income.<a href="#_ftn53" id="_ftnref53">[53]</a> This factor is applied to the model to scale the pass through to benefits of rent changes.</p>



<h4 class="wp-block-heading has-text-color has-link-color wp-elements-23" style="color:#c2203f">Going through the roof</h4>



<p class="wp-block-paragraph">By combining the private and social rented sector baselines, a substantial underestimation of the likely cost of housing benefits is revealed. By the end of the forecast period in 2030/31, spending on housing benefits in the private rented sector and the general needs social rented sector is set to exceed £40 billion, around £7.6 billion higher than the 2026 Spring Forecast indicates. By the end of the next parliament in 2033/34, it is on course to have more than doubled since 2023/24 if the likely private rented sector uplift occurs.&nbsp;</p>



<p class="wp-block-paragraph"><strong>Figure 7 &#8211; Combined baseline</strong></p>



<p class="wp-block-paragraph"><em>Source: Onward analysis</em></p>



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<h3 class="wp-block-heading has-text-color has-link-color wp-elements-24" style="color:#c2203f">Savings options</h3>



<p class="wp-block-paragraph">The policy options in this package are costed against the combined baseline above, using the same underlying basis from which to build the new policy scenarios. It is assumed that they are introduced at the start of a new parliament in the financial year 2029/30 and implemented over the five-year period to the end of 2033/34.</p>



<h4 class="wp-block-heading has-text-color has-link-color wp-elements-25" style="color:#c2203f">Recommendation 1: Uplift LHA rates to the 10th percentile each year.</h4>



<p class="wp-block-paragraph"><em>Rates move from the 30th to the 10th percentile of local market rents and are uplifted to the 10th percentile every April thereafter. Existing claimants receive transitional protection that keeps their rate frozen in cash terms from 2029 until the yearly uplift to the 10th percentile overtakes it, or a new tenancy is signed. Claimants above state pension age may claim up to the 30th percentile.</em></p>



<p class="wp-block-paragraph">The constant freezing and sporadic uplifting of rates to the 30th percentile is bad for tenants and taxpayers alike. The arbitrary and compounding impact of freezes on claimants, as demonstrated above, shows why this is a particularly regrettable way to achieve spending restraint. If LHA rates remain frozen in cash terms in line with the OBR forecast, they will erode to implausibly low rates, leaving many claimants exposed to growing shortfalls if they remain in their current tenancies or unable to find a property in a given area at all.</p>



<p class="wp-block-paragraph">As the modelled baseline highlights, the 30th percentile is clearly an unaffordable long-term basis for uplifting housing benefits, and could see the total housing benefits bill quadruple from current levels by 2040 as the caseload continues to grow.<a href="#_ftn54" id="_ftnref54">[54]</a> It is equally unfair to those who are not reliant on benefits to be priced out of some parts of the country while those on benefits can choose to live in more expensive areas and be subsidised to access effectively a third of the housing market there.</p>



<p class="wp-block-paragraph">Shifting permanently down to subsidise only up to the bottom tenth of the market in each area is both fairer and more affordable for the government. To prevent further volatility for claimants who are already assumed to have seen LHA rates uplifted to the 30th percentile from 2027/28, a grandfathering arrangement is proposed. Existing claimants in the private rented sector would have their housing benefits awards frozen going into 2029/30 and held in cash terms until the yearly uplift to the 10th percentile overtakes their award. In areas with high local market rent growth rates, this protection will erode faster than in areas with slower growth.</p>



<p class="wp-block-paragraph"><strong>Figure 8 &#8211; Mean year for 10th percentile overtake of frozen 2028/29 30th percentile LHA rates</strong></p>



<p class="wp-block-paragraph"><em>Source: Onward analysis</em><a href="#_ftn55" id="_ftnref55">[55]</a></p>



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<p class="wp-block-paragraph">New claimants or those taking on a new tenancy are only eligible for the 10th percentile LHA rate, calculated on the same basis as the baseline. Claimants above State Pension age, who are less able to adjust their income and outgoings, remain able to claim up to the 30th percentile throughout the period. Over a five year period from 2029/30 to 2033/34, this recommendation is estimated to save a cumulative £6.9 billion. In 2033/34, the in-year saving reaches £1.9 billion.&nbsp;</p>



<p class="wp-block-paragraph"><strong>Figure 9 &#8211; 10th percentile LHA rate policy savings</strong></p>



<p class="wp-block-paragraph"><em>Source: Onward analysis</em></p>



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<h4 class="wp-block-heading has-text-color has-link-color wp-elements-26" style="color:#c2203f">Recommendation 2: Extend LHA rate-based caps to the general needs social rented sector</h4>



<p class="wp-block-paragraph"><em>Eligible rent is capped at 10th percentile LHA rates for general needs social and affordable rent tenancies. Existing claimants have a maximum cash loss of £10 a week for the duration of that tenancy.</em><a href="#_ftn56" id="_ftnref56">[56]</a> <em>Pensioners are exempted from the cap.</em></p>



<p class="wp-block-paragraph">Claimants in the social rented sector receive high effective subsidies from the state when compared to the full rental market value of the properties they are occupying. On top of this, there is no LHA-style maximum on eligible rent, so housing benefits can exceed private rented sector rates for that area. There is no equivalent to the shared accommodation rate for under 35s in the social rented sector. Extending 10th percentile LHA rates into the social rented sector as a cap on eligible rent creates a single, consistent maximum.</p>



<p class="wp-block-paragraph">Eligible rent is currently set on a property basis rather than by household characteristics. This means that this policy would act as an additional underoccupancy penalty for those with rents hitting the LHA maximum. Almost a fifth (18.1%) of general needs social rented sector claimant households have one or more spare bedrooms.<a href="#_ftn57" id="_ftnref57">[57]</a> As with the private rented sector, pensioners are exempted as they will be less able to adjust to this change in circumstances by increasing their income to cover any shortfall. To protect any claimants at the LHA maximum from sudden losses of housing benefits, a further cap is proposed to limit the weekly deduction to £10 per week.</p>



<p class="wp-block-paragraph">Bringing LHA rates into the social rented sector was proposed previously at the Spending Review in 2015, but never took effect. According to analysis from the National Housing Federation, 18.2% of eligible households were expected to be affected by the cap.<a href="#_ftn58" id="_ftnref58">[58]</a> A principal reason for this policy’s downfall last time was the inclusion of supported housing, which this recommendation excludes. As social rents have since been held low for so long, this policy only affects a much smaller proportion of total social rented sector properties, predominantly affordable rent tenants.</p>



<p class="wp-block-paragraph">In 2029/30 when this policy is proposed to be introduced, just over 207,000 social and affordable rent homes are estimated to exceed a 10th percentile cap.<a href="#_ftn59" id="_ftnref59">[59]</a> This is much lower than estimates for the 2015 cap, which was expected to affect around 800,000 homes in the long run.<a href="#_ftn60" id="_ftnref60">[60]</a> Just over a third of those estimated to be impacted if this were introduced in 2029/30 are social rent properties, with the majority being affordable rent where the rents can be set up to 80% of market rents. In practice, many providers already use LHA rates as a guide for the maximum affordable rent to charge by number of bedrooms in the house, which is why the cap affects so few claimant households.<a href="#_ftn61" id="_ftnref61">[61]</a></p>



<p class="wp-block-paragraph">As LHA rates only allow claims for up to four bedrooms, those with five or more bedrooms in the social and affordable rent sector would not be eligible to claim higher rates that account for additional bedrooms. There are around 12,500 social and affordable rent homes with five or more bedrooms, or around 0.34% of the total general needs stock.<a href="#_ftn62" id="_ftnref62">[62]</a> There are only expected to be around 700 homes facing a further reduction at the cap due to having more bedrooms than they are eligible for under LHA rates.</p>



<p class="wp-block-paragraph">The shared accommodation rate would impact those in the general needs social rented sector who are living alone and under 35 in the small number of areas hitting the LHA cap. As with the private rented sector, exemptions from the shared accommodation rate for disability and vulnerability would apply here too. The 2021 Census indicates that there are just under 89,500 households in England, or 2.1% of social rented sector households, with one resident under 35 with no disability or long-term health condition.<a href="#_ftn63" id="_ftnref63">[63]</a> 44% of these households are also recorded as not in employment.<a href="#_ftn64" id="_ftnref64">[64]</a></p>



<p class="wp-block-paragraph">Some of these single under 35s will be in supported housing or would be exempt from the shared accommodation rate by vulnerability criteria, such as being a care leaver under 25, a victim of domestic abuse or a former homeless hostel resident. As there is no equivalent to shared accommodation in the general needs social rented sector, the small number affected would need to move into the private rented sector if they cannot afford the shortfall, freeing up a one bedroom property for a couple or tenants over 35.&nbsp;</p>



<p class="wp-block-paragraph">This policy saves between £42 million and £45 million a year between 2029/30 and 2033/34. As this recommendation interacts with savings from Recommendation 3, these savings should not be summed and the total savings are given below.</p>



<h4 class="wp-block-heading has-text-color has-link-color wp-elements-27" style="color:#c2203f">Recommendation 3: Freeze rents in the social rented sector for five years.</h4>



<p class="wp-block-paragraph"><em>Social and affordable rents are held at their 2028/29 cash level until 2033/34 while a new rent-setting basis is developed.</em></p>



<p class="wp-block-paragraph">The basis for setting and uprating social rent is highly distorted. It is providing unreasonable effective subsidies to millions of tenants while private renters not on housing benefits are squeezed out of many desirable areas. Racing stock that sits below formula rent towards a calculation tied to 1999 does not to fix the underlying system for determining the value of social homes. As demonstrated by Recommendation 2, affordable rent is also distortionary, providing relatively generous rent levels in some areas compared to the local market.</p>



<p class="wp-block-paragraph">As the consultation for the 2026 rent settlement acknowledged, preparing an entirely new system for rent-setting requires time for providers to adapt. It remains to be seen what the detail of the proposed devolution settlements will entail too, which could radically alter the structure of council responsibilities by 2029/30. Amidst this uncertainty, there remains a central fiscal imperative: to bring down the cost of welfare. As bringing LHA caps into the social rented sector is not enough to make significant savings on its own, a further step is proposed. A rent freeze should be brought in during the next parliament, while a new long-term rent-setting system is devised.</p>



<p class="wp-block-paragraph">In addition to welfare savings, it is relevant to account for the loss of revenue to local authorities in the form of rent. The final saving is therefore given in public sector net borrowing terms, in line with the 2015 HMT assessment of the rent cut which includes this as a behavioural effect.<a href="#_ftn65" id="_ftnref65">[65]</a> Housing associations were reclassified into the public sector in 2015 and then back into private sector classification from 2017, so they are not included in offset accounting.</p>



<p class="wp-block-paragraph">Providers previously absorbed a 1% rent cut for four years from 2016/17 to 2019/20. The financial position of providers going into a freeze from 2029/30 is uncertain. The latest published forecasts from the Regulator of Social Housing do not include the 2026 Rent Settlement changes for convergence. There are also a number of new legal requirements on property standards and safety that increase costs to providers.</p>



<p class="wp-block-paragraph">For local authority providers, previous analysis from Savills for the Local Government Association projects that a ten-year rent convergence policy would put Housing Revenue Accounts into a cumulative revenue surplus after around nine years and overall surplus (including borrowing for capital needs) after 30 years, while CPI alone deepens deficits.<a href="#_ftn66" id="_ftnref66">[66]</a> A freeze from 2029/30 would arrive two years into convergence, before many HRAs are likely to have reached cumulative revenue surplus. The Regulator of Social Housing judged the majority of private registered providers to be financially robust in 2025, prior to convergence increasing their revenue.<a href="#_ftn67" id="_ftnref67">[67]</a> Pre-convergence forecasts for private registered providers suggest that interest cover was due to go from 89.9% in 2026 to 118.8% in 2030.<a href="#_ftn68" id="_ftnref68">[68]</a></p>



<p class="wp-block-paragraph">In recognition that the financial position of providers would deteriorate during a freeze, it is limited to five years while a new rent-setting basis can replace it that does not chase the outdated formula. There are existing hardship measures that allow an exemption where complying would jeopardise a provider&#8217;s viability.<a href="#_ftn69" id="_ftnref69">[69]</a> Providers are also allowed to set rents for households with incomes above £60,000 at full market rent, so at least some of the windfall for non-claimant social tenants can be recouped.</p>



<p class="wp-block-paragraph">Recommendations 2 and 3 interact with each other, as the rent freeze reduces the number of households subject to LHA caps as they are uplifted each year. Together, they are expected to save £7.5 billion by 2033/34, net of LA revenue loss. In 2033/34, the in-year saving reaches £2.5 billion. In addition to Recommendation 1, the three policies save a total of £14.4 billion over the five years, and an in-year saving of £4.5 billion in 2033/34.</p>



<p class="wp-block-paragraph"><strong>Figure 10 &#8211; Total savings from recommendations 1, 2 and 3</strong></p>



<p class="wp-block-paragraph"><em>Source: Onward analysis</em></p>



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<h4 class="wp-block-heading has-text-color has-link-color wp-elements-28" style="color:#c2203f">Recommendation 4: Update national LHA caps to a 10th percentile-linked rate.</h4>



<p class="wp-block-paragraph"><em>Update the national LHA rate caps to uplift with the 10th percentile of the highest outer London BRMA, plus 20%.</em></p>



<p class="wp-block-paragraph">There are national caps on LHA rates which limit rates in more expensive areas where market rents are highest. When these were introduced in the 2010 Budget, they were based on the principle that those on benefits should not be able to live in areas that were out of reach to many people in work. Recent implementation of the caps has followed the 30th percentile rent of the highest outer London BRMA, plus 20%.<a href="#_ftn70" id="_ftnref70">[70]</a> Current caps have been in place since 2024/25 and have likewise been frozen since. The shared accommodation rate national cap is the same as the one bedroom rate cap.</p>



<p class="wp-block-paragraph">As LHA rates are moved to the 10th percentile, the national caps should also reflect the 10th percentile to remain in step. This prevents inner London LHA rates from becoming more generous in relative terms over the period. The current national cap policy is assumed to continue uprating with the 30th percentile plus 20%, along with LHA rates uprating to the 30th percentile. Changing to a 10th percentile-linked cap creates an additional saving of £120 million over the five years to 2033/34.<a href="#_ftn71" id="_ftnref71">[71]</a> In 2033/34, it saves an extra £38 million in-year.</p>



<p class="wp-block-paragraph"><strong>Figure 11 – Proposed weekly national LHA caps</strong></p>



<figure class="wp-block-table"><table class="has-fixed-layout"><tbody><tr><td><strong>&nbsp;</strong></td><td><strong>Shared</strong></td><td><strong>1 bed</strong></td><td><strong>2 bed</strong></td><td><strong>3 bed</strong></td><td><strong>4+ bed</strong></td></tr><tr><td>Current frozen caps</td><td>£331.39</td><td>£331.39</td><td>£412.86</td><td>£497.10</td><td>£704.22</td></tr><tr><td>2029/30 caps</td><td>£366.38</td><td>£366.38</td><td>£429.31</td><td>£529.89</td><td>£716.22</td></tr><tr><td>2033/34 caps</td><td>£430.63</td><td>£430.63</td><td>£508.81</td><td>£628.01</td><td>£848.84</td></tr></tbody></table></figure>



<h4 class="wp-block-heading has-text-color has-link-color wp-elements-29" style="color:#c2203f">Recommendation 5: Move additional bedroom eligibility and deductions to 18.</h4>



<p class="wp-block-paragraph"><em>Raise same-sex sharing age threshold to 18 and apply the housing cost contribution or non-dependant deduction from 18.</em></p>



<p class="wp-block-paragraph">The housing benefits system currently treats young people inconsistently. According to the official statistical measure of overcrowding, known as the bedroom standard, a household is considered overcrowded if any single person (not in a couple) aged 21 or over does not have their own room.<a href="#_ftn72" id="_ftnref72">[72]</a> This minimum standard is referenced in social rented sector allocations guidance to local authorities for the purposes of determining household needs, but local allocations policies can vary.<a href="#_ftn73" id="_ftnref73">[73]</a> At the same time, social rented sector households are not considered underoccupied for the purposes of a housing benefits under-occupation deduction if someone between 16 and 21 has their own room.</p>



<p class="wp-block-paragraph">When a child in a private rented sector claimant household turns 16, their family becomes eligible to claim for a separate room if they are sharing with a same-sex sibling. If the family does not move house to take up this extra room, they simply receive this as a larger benefit award if their rent is above their previous LHA rate. In UC, a housing cost contribution only applies from the age of 21. HB applies a non-dependant deduction from age 18 for some households.</p>



<p class="wp-block-paragraph">There is a clear mismatch between the statistical measure of occupancy which applies to all homes, including those not claiming benefits, and the benefit treatment of occupancy. Uneven thresholds make housing benefits more generous for families from 16, right at the point where childcare costs are diminishing and that young person could start contributing to household income. It incentivises moving or being allocated to larger homes that may then become unaffordable when that 16 year old leaves in just a few years when the housing cost contribution, non-dependant deduction or under-occupation deduction applies.</p>



<p class="wp-block-paragraph">Adults can live independently making their own UC claim from 18, with individuals under 35 usually limited to the shared accommodation rate. Moving bedroom sharing rules all the way to the bedroom standard at 21 could therefore be more expensive if more young people moved out to start their own claim. Instead, this recommendation proposes aligning same-sex sharing rules up to 18 while bringing the housing cost contribution or non-dependant deduction to 18 too, aligning with the threshold for an independent claim.</p>



<p class="wp-block-paragraph">These measures set a clear expectation for young people that having their own room (if previously same-sex sharing) requires contribution from them or their family. Making their own claim at 18 likewise comes with usual conditionality requirements. Claimant families will continue to be eligible for the UC child element for young people in the household until the August after they turn 19 if they are in non-advanced education or training.</p>



<p class="wp-block-paragraph">Together with the harmonisation of housing-related age boundaries, these steps create a stronger incentive for young people to take on employment, education or training &#8211; or for their parents to work to meet the shortfall. Benefit savings are expected, but likely to be small. There are insufficient breakdowns of household composition available to quantify the effect.</p>



<h3 class="wp-block-heading has-text-color has-link-color wp-elements-30" style="color:#c2203f">Conclusion</h3>



<p class="wp-block-paragraph">This package presents a series of options to control a housing benefits bill that is likely to grow rapidly without reform. There are many other ways in which benefit eligibility, conditionality and tenancies can &#8211; and should &#8211; be changed to improve the housing benefits system, but most require significant time for primary legislation and implementation.</p>



<p class="wp-block-paragraph">Despite many attempts to restrain spending through freezes, caps and cuts, the housing benefits bill risks spiralling to even more unsustainable levels if likely policy decisions are taken over the next few years. Making serious savings within a single parliament requires decisive action through existing powers and regulation changes.</p>



<p class="wp-block-paragraph">Permanently uplifting LHA rates to the 10th percentile offers a more sustainable path that avoids the cycle of arbitrary freezes and sudden cost jumps in the future. Extending the same ceiling to general needs social housing creates a single, consistent maximum across tenures.&nbsp; An immediate social and affordable rent freeze can keep spending under control while longer term reform is considered that leaves behind a rent formula crafted in the last century.</p>



<p class="wp-block-paragraph">The final two measures on national caps and bedroom eligibility begin to address some of the geographic and contribution-related unfairness that offers choices to claimants that are not available to many working families. This package provides the starting point for rationalising housing benefits spending that is more predictable for claimants and more affordable for the state.</p>



<hr class="wp-block-separator has-alpha-channel-opacity"/>



<p class="wp-block-paragraph"><a href="#_ftnref1" id="_ftn1">[1]</a> Onward analysis of: DWP, <em>Annual DWP Benefits Statistics Compendium</em>, September 2026, <a href="https://www.gov.uk/government/statistics/annual-dwp-benefits-statistics-compendium-2026/annual-dwp-benefits-statistics-compendium-2026">link</a>; ONS, <em>Households by household size, regions of England and Great Britain constituent countries</em>, April 2026 <a href="https://www.ons.gov.uk/peoplepopulationandcommunity/birthsdeathsandmarriages/families/datasets/householdsbyhouseholdsizeregionsofenglandandgbconstituentcountries">link</a>.</p>



<p class="wp-block-paragraph"><a href="#_ftnref2" id="_ftn2">[2]</a> Onward analysis: ONS, <em>Census 2021, Number of households</em>, <a href="https://www.ons.gov.uk/datasets/TS041/editions/2021/versions/3">link</a>.</p>



<p class="wp-block-paragraph"><a href="#_ftnref3" id="_ftn3">[3]</a> DWP, <em>Benefit expenditure and caseload tables 2026</em>, <a href="https://www.gov.uk/government/publications/benefit-expenditure-and-caseload-tables-2026">link</a>.</p>



<p class="wp-block-paragraph"><a href="#_ftnref4" id="_ftn4">[4]</a> Onward analysis; Local Housing Allowance-bound private rented sector tenants and general needs social rented sector tenants only.</p>



<p class="wp-block-paragraph"><a href="#_ftnref5" id="_ftn5">[5]</a> The Universal Credit housing element and Housing Benefit are referred to collectively as “housing benefits.”</p>



<p class="wp-block-paragraph"><a href="#_ftnref6" id="_ftn6">[6]</a> MHCLG, <em>Social housing lettings in England, tenants: April 2024 to March 2025</em>, November 2025, <a href="https://www.gov.uk/government/statistics/social-housing-lettings-in-england-april-2024-to-march-2025/social-housing-lettings-in-england-tenants-april-2024-to-march-2025">link</a>.</p>



<p class="wp-block-paragraph"><a href="#_ftnref7" id="_ftn7">[7]</a> DWP, <em>Benefit expenditure and caseload tables 2026</em>, <a href="https://www.gov.uk/government/publications/benefit-expenditure-and-caseload-tables-2026">link</a>.</p>



<p class="wp-block-paragraph"><a href="#_ftnref8" id="_ftn8">[8]</a> DWP, <em>Benefit expenditure and caseload tables 2026</em>, <a href="https://www.gov.uk/government/publications/benefit-expenditure-and-caseload-tables-2026">link</a>.&nbsp;</p>



<p class="wp-block-paragraph"><a href="#_ftnref9" id="_ftn9">[9]</a> DWP, <em>Benefit expenditure and caseload tables 2026</em>, <a href="https://www.gov.uk/government/publications/benefit-expenditure-and-caseload-tables-2026">link</a>.</p>



<p class="wp-block-paragraph"><a href="#_ftnref10" id="_ftn10">[10]</a> OBR, <em>Economic and fiscal outlook – March 2026</em>, Annex B, <a href="https://obr.uk/efo/economic-and-fiscal-outlook-march-2026/#annex-b">link</a>.</p>



<p class="wp-block-paragraph"><a href="#_ftnref11" id="_ftn11">[11]</a> HM Treasury, <em>Spring Forecast 2026</em>, <a href="https://www.gov.uk/government/news/spring-forecast-2026-the-right-economic-plan-for-britain">link</a>.</p>



<p class="wp-block-paragraph"><a href="#_ftnref12" id="_ftn12">[12]</a> As per paragraph 2 of Schedule 3B to <em>The Rent Officers (Housing Benefit Functions) Order 1997</em> (<a href="https://www.legislation.gov.uk/uksi/1997/1984">link</a>) made under s.122 of the <em>Housing Act 1996</em>. Paragraph 2(2) sets the LHA as the lower of the 30th percentile, determined under sub-paragraphs (4) to (8), and the national cap. The same structure appears in Schedule 1 para 2 of the <em>Rent Officers (Universal Credit Functions) Order 2013</em> (<a href="https://www.legislation.gov.uk/uksi/2013/382">link</a>) and in Schedule 3B of the equivalent Scotland Order (<a href="https://www.legislation.gov.uk/uksi/1997/1995">link</a>).</p>



<p class="wp-block-paragraph"><a href="#_ftnref13" id="_ftn13">[13]</a> For example, the latest freeze year is set out under <em>The Rent Officers (Housing Benefit and Universal Credit Functions) (Modification) Order 2026</em>, <a href="https://www.legislation.gov.uk/uksi/2026/5/made">link</a>.</p>



<p class="wp-block-paragraph"><a href="#_ftnref14" id="_ftn14">[14]</a> Onward analysis, DWP Stat-Xplore, <em>Local Housing Allowance indicator by Month</em>, counting Households on Universal Credit, split by proportion with LHA that covers rent and LHA that does not cover rent.</p>



<p class="wp-block-paragraph"><a href="#_ftnref15" id="_ftn15">[15]</a> Onward analysis, DWP Stat-Xplore, <em>Local Housing Allowance indicator by Month</em>, counting Households on Universal Credit. By March 2024, claimants with LHA that did not cover rent was 1,009,604. In December 2023, the number of households with LHA that did not cover rent was 985,697, roughly the same as the volume in May 2026 of 985,372, meaning the climb took around three months.</p>



<p class="wp-block-paragraph"><a href="#_ftnref16" id="_ftn16">[16]</a> Onward analysis, 329 out of 960 BRMAs and bedroom categories fall below the 10th percentile, calculated from the Valuation Office Rent Officers’ Shadow Lists of Rents and their Scotland and Wales equivalents, <a href="https://www.gov.uk/government/publications/shadow-list-of-rents-april-2026-collated-1st-october-2024-30th-september-2025">link</a>.&nbsp;</p>



<p class="wp-block-paragraph"><a href="#_ftnref17" id="_ftn17">[17]</a> Onward analysis, as above with expected growth rate calculated from the ONS Price Index of Private Rents 10 year growth rate by local authority, applied to BRMAs by share of each local authority in each BRMA, <a href="https://www.ons.gov.uk/economy/inflationandpriceindices/bulletins/privaterentandhousepricesuk/august2026">link</a>.</p>



<p class="wp-block-paragraph"><a href="#_ftnref18" id="_ftn18">[18]</a> Central London BRMA is omitted from the scale due to an extremely high gap of £1,538 per month. 30<sup>th</sup> percentile comparison does not include national caps.</p>



<p class="wp-block-paragraph"><a href="#_ftnref19" id="_ftn19">[19]</a> The 2015/16 freeze started from below the 30th percentile when rates had been uprated by CPI and then 1% in the years previously. It also later included recycling some of the savings through Targeted Affordability Funding to raise LHA rates in areas that had fallen furthest below the 30th percentile.</p>



<p class="wp-block-paragraph"><a href="#_ftnref20" id="_ftn20">[20]</a> Chartered Institute of Housing, <em>CIH among 40-strong coalition urging government to unfreeze local housing allowance</em>, October 2025, <a href="https://www.cih.org/news/cih-among-40-strong-coalition-urging-government-to-unfreeze-local-housing-allowance/">link</a>.</p>



<p class="wp-block-paragraph"><a href="#_ftnref21" id="_ftn21">[21]</a> EDM 2202: <em>Freezing of Local Housing Allowance</em>, <a href="https://edm.parliament.uk/early-day-motion/64626/freezing-of-local-housing-allowance">link</a>; also this year, EDM 616: <em>Local Housing Allowance rates</em>, <a href="https://edm.parliament.uk/early-day-motion/66374">link</a>.</p>



<p class="wp-block-paragraph"><a href="#_ftnref22" id="_ftn22">[22]</a> See, for example, Crisis, <em>No Home to Go To,</em> July 2026, <a href="https://www.crisis.org.uk/about-us/crisis-media-centre/fewer-than-2-of-properties-in-britain-considered-affordable-for-renters-on-housing-benefit-1/">link</a>; Resolution Foundation, <em>Saving Private Renters,</em> September 2026, <a href="https://www.resolutionfoundation.org/publications/saving-private-renters/">link</a>.</p>



<p class="wp-block-paragraph"><a href="#_ftnref23" id="_ftn23">[23]</a> Andy Burnham, <em>Andy Burnham Speech at the People’s History Museum, Manchester,</em> June 2026, <a href="https://andyburnham.org.uk/2026/07/20/andy-burnham-speech-at-the-peoples-history-museum-manchester-29-june-2026/">link</a>.</p>



<p class="wp-block-paragraph"><a href="#_ftnref24" id="_ftn24">[24]</a> PoliticsHome, <em>Boost Local Housing Allowance To Tackle Rough Sleeping, Says Andy Burnham</em>, November 2025, <a href="https://www.politicshome.com/news/article/burnham-and-crisis-urge-government-to-raise-local-housing-allowance">link</a>.</p>



<p class="wp-block-paragraph"><a href="#_ftnref25" id="_ftn25">[25]</a> Greater Manchester Combined Authority, <em>Statement from The Mayor on today&#8217;s Autumn Statement</em>, November 2023 <a href="https://www.greatermanchester-ca.gov.uk/news/statement-from-the-mayor-on-today-s-autumn-statement">link</a>.</p>



<p class="wp-block-paragraph"><a href="#_ftnref26" id="_ftn26">[26]</a> Resolution Foundation, <em>Saving Private Renters,</em> September 2026, <a href="https://www.resolutionfoundation.org/publications/saving-private-renters/">link</a>.</p>



<p class="wp-block-paragraph"><a href="#_ftnref27" id="_ftn27">[27]</a> Onward analysis, DWP, <em>Benefit expenditure and caseload tables 2026</em>, <a href="https://www.gov.uk/government/publications/benefit-expenditure-and-caseload-tables-2026">link</a>.</p>



<p class="wp-block-paragraph"><a href="#_ftnref28" id="_ftn28">[28]</a> Onward analysis, DWP, <em>Shadow List of Rents April 2026: collated 1st October 2024 – 30th September 2025</em>, <a href="https://www.gov.uk/government/publications/shadow-list-of-rents-april-2026-collated-1st-october-2024-30th-september-2025">link</a>; Scottish Government, <em>Private Sector Rent Statistics, Scotland, 2010 to 2025</em>, <a href="https://www.gov.scot/publications/private-sector-rent-statistics-scotland-2010-to-2025/">link</a>; Wales does not publish a consistent shadow list of rents, but publishes this data by local authority under ad-hoc statistical requests, the latest of which contains information from 23 October to 3 November 2023 and is adjusted to align with the English and Scottish start years, <a href="https://www.gov.wales/ad-hoc-statistical-requests-23-october-3-november-2023">link</a>.</p>



<p class="wp-block-paragraph"><a href="#_ftnref29" id="_ftn29">[29]</a> Onward analysis of ONS, <em>Price Index of Private Rents</em>, September 2026, <a href="https://www.ons.gov.uk/economy/inflationandpriceindices/bulletins/privaterentandhousepricesuk/august2026">link</a>.</p>



<p class="wp-block-paragraph"><a href="#_ftnref30" id="_ftn30">[30]</a> ONS, <em>Price Index of Private Rents</em>, September 2026, <a href="https://www.ons.gov.uk/economy/inflationandpriceindices/bulletins/privaterentandhousepricesuk/august2026">link</a>; note that the PIPR figure is UK wide, while the model excludes Northern Ireland where this policy area is devolved. The national figure given is the average while the model itself uses local growth rates.</p>



<p class="wp-block-paragraph"><a href="#_ftnref31" id="_ftn31">[31]</a> Only small volumes of claimants migrated onto UC via natural migration (triggered by a change of circumstances), voluntary migration or new claims before this point.</p>



<p class="wp-block-paragraph"><a href="#_ftnref32" id="_ftn32">[32]</a> Onward analysis, DWP Stat-Xplore, <em>Local authority, entitled Bedrooms (LHA only)</em>, April 2018. LA to BRMA proportions applied.</p>



<p class="wp-block-paragraph"><a href="#_ftnref33" id="_ftn33">[33]</a> HB data on Stat-Xplore is split by pre-April 2018 and post-April 2018, so this date was selected to give the longest possible view from single consistent extracts.</p>



<p class="wp-block-paragraph"><a href="#_ftnref34" id="_ftn34">[34]</a> Regional and national scaling factors are used for missing values where volumes are too low to show values.</p>



<p class="wp-block-paragraph"><a href="#_ftnref35" id="_ftn35">[35]</a> DWP, <em>Benefit expenditure and caseload tables 2026</em>, <a href="https://www.gov.uk/government/publications/benefit-expenditure-and-caseload-tables-2026">link</a>.</p>



<p class="wp-block-paragraph"><a href="#_ftnref36" id="_ftn36">[36]</a> Onward analysis, DWP Stat-Xplore LHA covers rent and LHA does not cover rents and Shadow list of rents calculations.</p>



<p class="wp-block-paragraph"><a href="#_ftnref37" id="_ftn37">[37]</a> OECD, <em>Social rental housing stock</em>, 2022, <a href="https://www.oecd.org/content/dam/oecd/en/data/datasets/affordable-housing-database/ph4-2-social-rental-housing-stock.pdf">link</a>; MHCLG, <em>English Housing Survey, Chapter 1: Profile of households and dwellings</em>, July 2026, <a href="https://www.gov.uk/government/statistics/chapters-for-english-housing-survey-2024-to-2025-headline-findings-on-demographics-and-household-resilience/chapter-1-profile-of-households-and-dwellings">link</a>.</p>



<p class="wp-block-paragraph"><a href="#_ftnref38" id="_ftn38">[38]</a> Regulator of Social Housing, <em>Registered provider social housing in England &#8211; stock and rents</em>, October 2025, <a href="https://assets.publishing.service.gov.uk/media/6900e16fab5cc9c8937994ed/2025_RP_Briefing_Note_FINAL_V1.1.pdf">link</a>.</p>



<p class="wp-block-paragraph"><a href="#_ftnref39" id="_ftn39">[39]</a> MHCLG, <em>How to implement Social Rent convergence</em>, March 2026, <a href="https://www.gov.uk/government/consultations/how-to-implement-social-rent-convergence/how-to-implement-social-rent-convergence">link</a>.</p>



<p class="wp-block-paragraph"><a href="#_ftnref40" id="_ftn40">[40]</a> MHCLG, <em>Future social housing rent policy, Consultation outcome,</em> January 2026, <a href="https://www.gov.uk/government/consultations/consultation-on-future-social-housing-rent-policy/future-social-housing-rent-policy">link</a>.</p>



<p class="wp-block-paragraph"><a href="#_ftnref41" id="_ftn41">[41]</a> MHCLG, <em>How to implement Social Rent convergence, Consultation outcome,</em> March 2026, <a href="https://www.gov.uk/government/consultations/how-to-implement-social-rent-convergence/how-to-implement-social-rent-convergence">link</a>.</p>



<p class="wp-block-paragraph"><a href="#_ftnref42" id="_ftn42">[42]</a> MHCLG, <em>How to implement Social Rent convergence, Consultation outcome,</em> March 2026, <a href="https://www.gov.uk/government/consultations/how-to-implement-social-rent-convergence">link</a>; OBR, <em>Economic and fiscal outlook – March 2026</em>, Annex B, <a href="https://obr.uk/efo/economic-and-fiscal-outlook-march-2026/#annex-b">link</a>.</p>



<p class="wp-block-paragraph"><a href="#_ftnref43" id="_ftn43">[43]</a> HMT, <em>Forecasts for the UK economy</em>, September 2026, <a href="https://assets.publishing.service.gov.uk/media/6aa9660644ec1aa417346aeb/Forecomp_Sept26.pdf">link</a>.</p>



<p class="wp-block-paragraph"><a href="#_ftnref44" id="_ftn44">[44]</a> Onward analysis, DWP, <em>Benefit expenditure and caseload tables 2026</em>, <a href="https://www.gov.uk/government/publications/benefit-expenditure-and-caseload-tables-2026">link</a>.</p>



<p class="wp-block-paragraph"><a href="#_ftnref45" id="_ftn45">[45]</a> Regulator of Social Housing, <em>Registered provider social housing stock and rents in England</em>, <a href="https://www.gov.uk/government/collections/registered-provider-social-housing-stock-and-rents-in-england">link</a>. Regulator of Social Housing, <em>Local authority registered provider social housing stock in England</em>, <a href="https://www.gov.uk/government/statistics/local-authority-registered-provider-social-housing-stock-and-rents-in-england-2024-to-2025">link</a>; Regulator of Social Housing, <em>Private registered provider social housing stock in England</em>, <a href="https://www.gov.uk/government/collections/private-registered-provider-social-housing-stock-in-england">link</a>.</p>



<p class="wp-block-paragraph"><a href="#_ftnref46" id="_ftn46">[46]</a> MHCLG, <em>Policy statement on rents for social housing</em>, April 2026, <a href="https://www.gov.uk/government/publications/direction-on-the-rent-standard-2026/policy-statement-on-rents-for-social-housing">link</a>.</p>



<p class="wp-block-paragraph"><a href="#_ftnref47" id="_ftn47">[47]</a> MHCLG, <em>Social housing lettings in England, tenants: April 2024 to March 2025</em>, November 2025, <a href="https://www.gov.uk/government/statistics/social-housing-lettings-in-england-april-2024-to-march-2025/social-housing-lettings-in-england-tenants-april-2024-to-march-2025">link</a>.</p>



<p class="wp-block-paragraph"><a href="#_ftnref48" id="_ftn48">[48]</a> Chartered Institute of Housing, <em>Rent consultation analysis,</em> December 2024, <a href="https://www.cih.org/media/vwlgpspr/annex-1-rents-analysis-summary.pdf">link</a>; National Housing Federation, <em>How to implement rent convergence,</em> <a href="https://www.housing.org.uk/globalassets/files/rural/how-to-implement-rent-convergence_nhf-response_final-2025.pdf">link</a>.</p>



<p class="wp-block-paragraph"><a href="#_ftnref49" id="_ftn49">[49]</a> DWP, <em>Shadow List of Rents April 2026: collated 1st October 2024 – 30th September 2025</em>, <a href="https://www.gov.uk/government/publications/shadow-list-of-rents-april-2026-collated-1st-october-2024-30th-september-2025">link</a>.</p>



<p class="wp-block-paragraph"><a href="#_ftnref50" id="_ftn50">[50]</a> HMT, <em>Forecasts for the UK economy</em>, September 2026, <a href="https://assets.publishing.service.gov.uk/media/6aa9660644ec1aa417346aeb/Forecomp_Sept26.pdf">link</a>.</p>



<p class="wp-block-paragraph"><a href="#_ftnref51" id="_ftn51">[51]</a> Homes England, <em>Social and Affordable Homes Programme (SAHP) 2026 to 2036,</em> November 2025, <a href="https://www.gov.uk/guidance/social-and-affordable-homes-programme-sahp-2026-to-2036">link</a>.</p>



<p class="wp-block-paragraph"><a href="#_ftnref52" id="_ftn52">[52]</a> Regulator of Social Housing, <em>Registered provider social housing stock and rents in England</em>, <a href="https://www.gov.uk/government/collections/registered-provider-social-housing-stock-and-rents-in-england">link</a>. Regulator of Social Housing, <em>Local authority registered provider social housing stock in England</em>, <a href="https://www.gov.uk/government/statistics/local-authority-registered-provider-social-housing-stock-and-rents-in-england-2024-to-2025">link</a>; Regulator of Social Housing, <em>Private registered provider social housing stock in England</em>, <a href="https://www.gov.uk/government/collections/private-registered-provider-social-housing-stock-in-england">link</a>.</p>



<p class="wp-block-paragraph"><a href="#_ftnref53" id="_ftn53">[53]</a> MHCLG, <em>Future social housing rent policy from 2026-36: CPI+1% plus convergence options</em>, July 2025, <a href="https://assets.publishing.service.gov.uk/media/6864f26108bf2f5376121b2e/Annex_C_-_draft_impact_assessment.pdf">link</a>.</p>



<p class="wp-block-paragraph"><a href="#_ftnref54" id="_ftn54">[54]</a> Onward analysis.</p>



<p class="wp-block-paragraph"><a href="#_ftnref55" id="_ftn55">[55]</a> Aberdeen and Shire’s frozen 2028/29 30th percentile LHA rate does not cross the 10th percentile due to negative rental market growth.</p>



<p class="wp-block-paragraph"><a href="#_ftnref56" id="_ftn56">[56]</a> Onward analysis; this policy is costed for England only in line with the England only baseline.</p>



<p class="wp-block-paragraph"><a href="#_ftnref57" id="_ftn57">[57]</a> Onward analysis, <em>DWP Stat-Xplore</em>, February 2026 figures.</p>



<p class="wp-block-paragraph"><a href="#_ftnref58" id="_ftn58">[58]</a> National Housing Federation, <em>Impact of applying Local Housing Allowance rates to general needs social tenants</em>, October 2016, <a href="https://s3-eu-west-1.amazonaws.com/pub.housing.org.uk/LHA_cap_analysis.pdf">link</a>. Note the analysis uses CORE data from 2012/13 due to lack of more recent breakdowns.</p>



<p class="wp-block-paragraph"><a href="#_ftnref59" id="_ftn59">[59]</a> Onward analysis, <em>DWP Stat-Xplore,</em> February 2026 figures.</p>



<p class="wp-block-paragraph"><a href="#_ftnref60" id="_ftn60">[60]</a> Institute for Fiscal Studies, <em>The Budget and Spending Review: what do they mean for social housing?</em>, December 2015, <a href="https://ifs.org.uk/publications/budget-and-spending-review-what-do-they-mean-social-housing">link</a>.</p>



<p class="wp-block-paragraph"><a href="#_ftnref61" id="_ftn61">[61]</a> National Housing Federation, <em>Considerations on rent,</em> 2022, <a href="https://www.housing.org.uk/our-work/finance/views-from-our-advisory-group/considerations-on-rent">link</a>.</p>



<p class="wp-block-paragraph"><a href="#_ftnref62" id="_ftn62">[62]</a> Regulator of Social Housing, <em>Registered provider social housing in England &#8211; stock and rents</em>, October 2025, <a href="https://assets.publishing.service.gov.uk/media/6900e16fab5cc9c8937994ed/2025_RP_Briefing_Note_FINAL_V1.1.pdf">link</a>.</p>



<p class="wp-block-paragraph"><a href="#_ftnref63" id="_ftn63">[63]</a> Onward analysis, Census 2021, <em>Lifestage of household reference person, number of people in household with no long-term health condition and tenure of household</em>, <a href="https://www.ons.gov.uk/datasets/create/filter-outputs/f5de1eb8-6230-4234-bcb0-a21f519f55ec#get-data">link</a>.</p>



<p class="wp-block-paragraph"><a href="#_ftnref64" id="_ftn64">[64]</a> Onward analysis, Census 2021, <em>Lifestage of household reference person, number of adults in employment in household, number of people in household with no long-term health condition and tenure of household</em>, <a href="https://www.ons.gov.uk/datasets/create/filter-outputs/f5de1eb8-6230-4234-bcb0-a21f519f55ec#get-data">link</a>.</p>



<p class="wp-block-paragraph"><a href="#_ftnref65" id="_ftn65">[65]</a> HM Treasury, <em>Summer Budget 2015: policy costings</em>, July 2015, <a href="https://assets.publishing.service.gov.uk/government/uploads/system/uploads/attachment_data/file/443195/Policy_costings_summer_budget_2015.pdf">link</a>.</p>



<p class="wp-block-paragraph"><a href="#_ftnref66" id="_ftn66">[66]</a> Savills for the Local Government Association, <em>Housing Revenue Account Research Update</em>, October 2024, <a href="https://www.thinkhouse.org.uk/site/assets/files/3058/lga1024.pdf">link</a>.</p>



<p class="wp-block-paragraph"><a href="#_ftnref67" id="_ftn67">[67]</a> Regulator of Social Housing, <em>2025 financial forecasts of private registered providers</em>, January 2026, <a href="https://www.gov.uk/government/publications/2025-financial-forecasts-of-private-registered-providers/2025-financial-forecasts-of-private-registered-providers">link</a>.</p>



<p class="wp-block-paragraph"><a href="#_ftnref68" id="_ftn68">[68]</a> Regulator of Social Housing, <em>2025 financial forecasts of private registered providers</em>, January 2026, <a href="https://www.gov.uk/government/publications/2025-financial-forecasts-of-private-registered-providers/2025-financial-forecasts-of-private-registered-providers">link</a>.</p>



<p class="wp-block-paragraph"><a href="#_ftnref69" id="_ftn69">[69]</a> MHCLG, <em>The Direction on the Rent Standard,</em> January 2026, <a href="https://assets.publishing.service.gov.uk/media/6979ba2ed6ab92f1d3a4d6f9/Annex_A_-_Direction_on_the_Rent_Standard_2026.pdf">link</a>; MHCLG, <em>Policy statement on rents for social housing</em>, April 2026, <a href="https://www.gov.uk/government/publications/direction-on-the-rent-standard-2026/policy-statement-on-rents-for-social-housing">link</a>.</p>



<p class="wp-block-paragraph"><a href="#_ftnref70" id="_ftn70">[70]</a> Explanatory Memorandum to <em>The Rent Officers (Housing Benefit and Universal Credit Functions) (Amendment) Order 2024,</em> <a href="https://www.legislation.gov.uk/uksi/2024/11/pdfs/uksiem_20240011_en_001.pdf">link</a>.</p>



<p class="wp-block-paragraph"><a href="#_ftnref71" id="_ftn71">[71]</a> Onward analysis of impact in addition to Recommendation 1.</p>



<p class="wp-block-paragraph"><a href="#_ftnref72" id="_ftn72">[72]</a> MHCLG, <em>English Housing Survey 2024 to 2025, Chapter 1: Housing quality</em>, January 2026, <a href="https://www.gov.uk/government/statistics/chapters-for-english-housing-survey-2024-to-2025-headline-findings-on-housing-quality-and-energy-efficiency/chapter-1-housing-quality">link</a>.</p>



<p class="wp-block-paragraph"><a href="#_ftnref73" id="_ftn73">[73]</a> MHCLG, <em>Allocation of accommodation: guidance for local authorities,</em> updated April 2026, <a href="https://www.gov.uk/guidance/allocation-of-accommodation-guidance-for-local-authorities/chapter-4-framing-an-allocation-scheme">link</a>.</p>
<p>The post <a href="https://ukonward.com/reports/through-the-roof-how-to-reduce-housing-benefits-spending/">Through the Roof: How to reduce housing benefits spending</a> appeared first on <a href="https://ukonward.com">Onward</a>.</p>
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		<title>A State that works for us</title>
		<link>https://ukonward.com/onward-corner/a-state-that-works-for-us/</link>
		
		<dc:creator><![CDATA[Joanna Marchong]]></dc:creator>
		<pubDate>Wed, 23 Sep 2026 10:42:14 +0000</pubDate>
				<category><![CDATA[Reshaping the State]]></category>
		<guid isPermaLink="false">https://ukonward.com/?post_type=onward-corner&#038;p=41958</guid>

					<description><![CDATA[<p>What if public sector services worked as seamlessly as your favourite app? We all know the state could work better for us. Yet, as anyone who has tried to change it discovers, that’s easier said than done. This is why it is essential for an aspiring incoming Government to have a clear plan from Day [&#8230;]</p>
<p>The post <a href="https://ukonward.com/onward-corner/a-state-that-works-for-us/">A State that works for us</a> appeared first on <a href="https://ukonward.com">Onward</a>.</p>
]]></description>
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<p class="wp-block-paragraph">What if public sector services worked as seamlessly as your favourite app?</p>



<p class="wp-block-paragraph">We all know the state could work better for us. Yet, as anyone who has tried to change it discovers, that’s easier said than done. This is why it is essential for an aspiring incoming Government to have a clear plan from Day 1 otherwise, as it is said, “if you fail to prepare, prepare to fail.”</p>



<p class="wp-block-paragraph">Public services are central to our lives. Around 18% of the UK workforce- some six million people &#8211; are employed in delivering them. That’s more than one in six working adults. Many are friends, neighbours, and family members doing vital work, often in difficult circumstances. Yet productivity in the public sector has fallen over the past five years, even as budgets have grown. Meanwhile, the UK’s public finances are under severe strain: debt now stands at £2.9 trillion, with rising interest payments crowding out investment. The reality is stark &#8211; the status quo is no longer viable. Something has to change.</p>



<p class="wp-block-paragraph">Other countries are wrestling with similar challenges. In the United States, the Department of Government Efficiency- informally “DOGE” &#8211; was launched with Elon Musk’s involvement. Closer to home, the Rt Hon Kemi Badenoch has argued for “a state that does fewer things, but does them well.” That raises two questions: what exactly should the state stop doing, and how should it do the remaining tasks better? Trade-offs about scope will always be politically charged. But the deeper issue &#8211; how the state delivers more effectively &#8211; remains unresolved.</p>



<p class="wp-block-paragraph">Whilst plans for the incoming Burnham government are unclear, this issue was recognised by the outgoing Starmer government with Chief Secretary to the Treasury Darren Jones announcing that every government department would establish a dedicated delivery unit. Many will wonder what the rest of government is doing if it is not delivering for us, the taxpayers. A glance at the Blavatnik Index, a global benchmarking tool published by the University of Oxford, shows that whilst the UK Civil Service ranked joint 6th this masks some significant deviations.&nbsp; The UK was ranked 3rd for Public Policy globally, whilst it only ranked 14th for National Delivery.</p>



<p class="wp-block-paragraph">I saw this first-hand when I moved from the private to the public sector. After two decades as a senior finance manager and later as the founder of an award-winning start-up, I joined my first public sector board. I entered a world of acronyms, Treasury rulebooks, and exchanges that felt like something out of&nbsp;<em>Yes Minister</em>. Over the past five years, I have served on boards across business, energy, and health, witnessing a variety of quangos in action.</p>



<p class="wp-block-paragraph">What struck me was not a lack of commitment- on the contrary, I have met many dedicated civil servants who want to deliver for the public. The barriers lie elsewhere: in culture, in the ecosystem, and in accountability. These are areas where lessons from the private sector could make a real difference.&nbsp;</p>



<p class="wp-block-paragraph">So what does an incoming Government need to get right on Day 1 to ensure the State works better for us? There are three key areas: culture, ecosystem and accountability.</p>



<ol class="wp-block-list">
<li><strong>Culture</strong></li>
</ol>



<p class="wp-block-paragraph">As Peter Drucker observed, “culture eats strategy for breakfast.” In the public sector, cultural inertia can be a powerful brake on reform. Without the right people in the right roles, motivated and empowered to deliver the right outcomes, new ways of working struggle to gain traction. Recent government legislation such as the changes in employee rights may act as a further break on change and enforce the “job for life” mentality. Unless cultural change is prioritised, structural reform risks failure.&nbsp;</p>



<p class="wp-block-paragraph"><strong>Day 1: Tangible Steps to a Culture that Empowers</strong> <strong>Leadership sets the tone at the top</strong></p>



<p class="wp-block-paragraph">To succeed in sport, a coach must develop a high-performance team. They must first have a clear goal to aim at before developing the right culture to achieve it.</p>



<p class="wp-block-paragraph">Simon Sinek in “Find your Why” emphasises the importance of defining your “Why” and each public service needs to ask itself that question. Is it to keep us safe, provide a specific service or provide a safety net to the neediest in society?&nbsp; This may sound obvious, but mission creep is endemic, with distracting competing priorities. Armed with this clarity, the next step is to understand the customer requirements. One CEO confessed at a Board meeting that he had never considered the users of his service as customers. This informs the mindset, the priorities and the culture of the organization.</p>



<p class="wp-block-paragraph">All teams need to bring in the best talent, in this case from both the private and public sector. This can be through direct executive recruitment but other routes include private sector leaders acting as mentors for senior leaders or appointing Non-Executive Directors from the private sector.&nbsp;</p>



<p class="wp-block-paragraph">By focusing on building high performance with clear goals and a continuous improvement “can do” culture then leaders can address the twin dangers of the defeatism of paper pushers waiting to draw their final salary pension, and activists who are using the civil service to achieve their own ends.&nbsp;</p>



<p class="wp-block-paragraph"><strong>Cultural enablers of a continuous improvement mindset</strong></p>



<p class="wp-block-paragraph">Many industries are adept at using continuous improvement methodologies, from high hazard industries to competitive supply chains. Quick win examples include real time displays with performance data visible in situ. Departmental newsletters could be focused on stories of delivery, efficiency wins and success in outcomes for end users / customers. High performance role models from outside the civil service could be invited to regular training events and internal meetings.</p>



<p class="wp-block-paragraph"><strong>Training Managers in Performance management&nbsp;</strong></p>



<p class="wp-block-paragraph">Dame Antonia Romeo, the Cabinet Secretary, recently caused a stir when she published her official performance objectives which was a welcome step forward in performance management. However, this is far from the norm and has yet to be cascaded throughout the Public Sector. A leader recently confessed to me that most of their department didn’t have any targets set for the year.&nbsp; Quick win examples include:</p>



<ul class="wp-block-list">
<li>Providing short training modules for first time managers and refresher courses for all managers outlining their responsibilities and providing easy to use tools and templates</li>



<li>Annual tasks &amp; targets setting for all, followed by periodic performance conversations and an annual appraisal rewarding delivery and a “can-do” attitude&nbsp;</li>



<li>All managers having development conversations with staff, preparing an annual training plan</li>
</ul>



<p class="wp-block-paragraph"><strong>Medium Term: potentially requiring legislation&nbsp;</strong></p>



<p class="wp-block-paragraph">Medium term actions require working with other stakeholders such as Legislators, Regulators, Unions and the Treasury to find common ground to build the case for change.</p>



<p class="wp-block-paragraph">In the private sector, contractual incentives such as performance related pay tied to the delivery of annual targets is common at managerial levels.&nbsp; This should be considered as it is a key enabler of cultural change whilst balancing this with the complexity of amending existing contracts. Similarly, modernisation of working practices whilst enhancing workforce skills thus improving employability and future job security should be an integral part of collective bargaining negotiations.</p>



<p class="wp-block-paragraph">Government should consider restructuring and headcount reductions both in Whitehall and arm’s-length bodies, ALBs and review the internal processes which enable this, including managing poor performance.&nbsp; Currently if an ALB wants to launch a voluntary redundancy scheme, it must obtain formal approval from its parent department and the Treasury (above a threshold) which can be time consuming.&nbsp; This is in addition to formal staff engagement and due process.</p>



<p class="wp-block-paragraph">Lastly, in order to reduce multiple layers of regulation and governance, a review of legislation will be required, For example the Care Quality Commission (CQC) was established by primary legislation under the Health and Social Care Act 2008 but the Secretary of State is able to issue statutory instruments and secondary legislation to update or refine the scope of the Act.&nbsp; Where multiple layers of governance exist, simplification is essential, which leads on to the second key area, ecosystem.</p>



<ol start="2" class="wp-block-list">
<li><strong>Ecosystem</strong></li>
</ol>



<p class="wp-block-paragraph">The machinery of government &#8211; its processes, governance frameworks, digital systems, and infrastructure &#8211; too often feels like wading through treacle. Bureaucracy and duplication sap energy and slow delivery. The private sector has long embraced simplification and standardisation to drive efficiency. This is the essential foundation that determines whether an organisation can deliver services smoothly, affordably, and at scale.&nbsp; This has the twin advantages of reducing embedded costs <em>and</em> making it easier to “get stuff done”.</p>



<p class="wp-block-paragraph">Why is this relevant? We need only to look at failures in day-to-day service delivery such as waiting times on government helplines or spiralling costs of projects such as High Speed 2 and even Parliament’s own renovation project to see some of the issues first hand.&nbsp;</p>



<p class="wp-block-paragraph"><strong>Day 1: Tangible steps to an ecosystem that enables rather than frustrates.</strong></p>



<p class="wp-block-paragraph"><strong>Simplification &amp; standardisation&nbsp;</strong></p>



<p class="wp-block-paragraph">Standardisation and simplification<strong> </strong>is the essential first step, cutting unnecessary process steps, freeing up staff from box ticking and releasing them to customer/mission focused activities. There are many processes which lend themselves to simplification, from investment decisions to project assurance and day-to-day processes which needlessly slow the process of getting the main job done.&nbsp; Benchmarking plays an important role here so we know what “good” looks like and can set targets accordingly.</p>



<p class="wp-block-paragraph"><strong>Digital Structures</strong></p>



<p class="wp-block-paragraph">Day-to-day processes lend themselves to standardisation and digitisation, and potentially, as in the private sector, outsourcing. For example: accounting transactions, and payroll provision can be moved to a shared service centre with the benefit of economies of scale. The NHS Shared Business Services provides an example of this and a similar entity could be set up for other quangos. Shared services should be the presumption, rather than the exception.&nbsp;</p>



<p class="wp-block-paragraph">Other processes might remain inhouse but have the potential to be digitised. For example, following induction training I was given a proof of training printed onto paper, which then had to be cut, laminated as a card and carried at all times to be shown on demand.&nbsp;&nbsp;</p>



<p class="wp-block-paragraph">Shadow IT is a major issue in the public sector. The National Cyber Security Centre explains that Shadow IT is any software, hardware, cloud services or AI tools used by employees for business purposes without the knowledge, approval, or oversight of a company’s central IT department. Shadow IT may include legacy systems, or software procured as a “work around” as following the process is too difficult/time consuming. The organization may have a partial list of Shadow IT but lack the resources (financial and people) to replace it. Shadow IT can pose major risks which must be managed and investment should be prioritised by a future Government.</p>



<p class="wp-block-paragraph"><strong>Risk Management</strong></p>



<p class="wp-block-paragraph">According to “The Orange Book” published by the Government, risk is defined as the effect of uncertainty on achieving objectives, encompassing both negative threats and positive opportunities. Many organisations focus only on risk management rather than looking at opportunities. For those focusing on risk management, it can be limited in scope and focused on regulatory requirements.</p>



<p class="wp-block-paragraph">In my experience, it is important to revisit the risk management<strong> </strong>approach to consider a wider sphere of influence. For example, decisions made due to risk aversion can have unintended consequences of slowing down processes and increasing risks elsewhere. For example, approaches to reduce risk in medical procedures may have improved patient outcomes (a good thing) but may also have slowed the rate of treating patients, increasing the length of the waiting list (not so good). This has the net effect of increasing the risk for those patients waiting (e.g. suffering further deterioration/ requiring more acute care when they reach hospital). Given the millions of patients waiting for treatment, this is significant. Has this approach reduced risk overall or just moved it out of sight?&nbsp;&nbsp;&nbsp;</p>



<p class="wp-block-paragraph"><strong>Medium Term: Update the Green Book Revisit Treasury technical guidance</strong></p>



<p class="wp-block-paragraph">Readers may be familiar with the Treasury’s Green Book which determines how the Government appraises policies and projects. This was updated earlier this year to reduce the regional investment disparities. In my view, it requires further updating to enable cost saving decisions and accommodate necessary IT spend. Even if an investment pays back within the year, it cannot be made if the departmental capital expenditure limits (or CDEL as it is known) has been reached. We need an “invest to save” category.</p>



<p class="wp-block-paragraph">As technical guidance, The Green Book does not require an Act of Parliament to update it, but given the nature of consultation required between departments and multi-year spending settlements, this requires diligent up-front work prior to a Spending Review.</p>



<p class="wp-block-paragraph">A second area of concern is how decision makers are often incentivised to delay a decision rather than take a decision. The rules need to recognise that delaying decisions and expenditure is not cost neutral. For example, project cost increases over time due to inflation and there are unavoidable costs associated with mobilising a project team only to then stand it down before re-mobilising it again. This cycle can be repeated on infrastructure projects where the final investment decision is unpalatable, so a review is seen as a face-saving way forward.</p>



<ol start="3" class="wp-block-list">
<li><strong>Accountability</strong></li>
</ol>



<p class="wp-block-paragraph">Finally, clarity over who is responsible for what remains elusive. Politicians often feel accountable without authority, while officials may hold authority without true accountability. As the debate over Mandelson’s security vetting showed, there is even a lack of clarity in responsibility between government departments and Arm’s Length Bodies (ALBs).&nbsp;</p>



<p class="wp-block-paragraph">Without a sharper line of sight between accountability, responsibility and delivery, reform efforts will continue to falter.&nbsp;&nbsp;&nbsp;</p>



<p class="wp-block-paragraph"><strong>Day 1: Tangible steps to an accountability structure that rewards delivery</strong>&nbsp;</p>



<p class="wp-block-paragraph"><strong>Simplified Single Point Accountabilities</strong></p>



<p class="wp-block-paragraph">I’ve already discussed changes needed in the leadership culture and simplified ecosystem of processes that also contribute to improving accountability.&nbsp;</p>



<p class="wp-block-paragraph">For example, at times, decision-making disperses into endless committees and gatekeepers. As I have experienced, if an investment decision has to go through over ten levels of approval then each committee begins to question the value added at their level. Does the scrutiny really add value or does it simply delay the decision-making process, ultimately adding unnecessary cost and process inertia. If there is a simplified process with clear accountabilities that reward delivery, this will be a significant step forward with a sharper line of sight between accountability, responsibility and delivery.</p>



<p class="wp-block-paragraph"><strong>Independent Non-Executive Directors from the Private Sector&nbsp;</strong></p>



<p class="wp-block-paragraph">The role of the&nbsp;Non-Executive Director (NED)&nbsp;has evolved alongside the growing importance of&nbsp;corporate governance. Introduced in the&nbsp;1980s&nbsp;to bring independence and external insight to company boards, NEDs were designed to complement the work of Executive Directors and strengthen decision-making. In the&nbsp;public sector, the introduction of NEDs gained real momentum in&nbsp;2010, when&nbsp;Lord Francis Maude&nbsp;established Departmental Boards.&nbsp;The Cabinet Office expanded this and sets out clear expectations for NEDs to contribute&nbsp;independent judgment, impartiality, and broad professional experience&nbsp;to the governance of public bodies. This provides an opportunity to bring in external expertise and challenge from the private sector at the highest level.</p>



<p class="wp-block-paragraph"><strong>Medium Term: potentially requiring legislation&nbsp;</strong></p>



<p class="wp-block-paragraph">A review of ALBs or “quangos” is needed to reduce complexity and simplify remit including:</p>



<ul class="wp-block-list">
<li>Bringing policy focused work back into government departments&nbsp;</li>



<li>Adding sunset clauses for new quangos to make efficient use of Parliamentary time</li>



<li>Empowering delivery based ALBs to deliver their core remit and remove all non-core activities such as those required under the Public Sector Equality Duty, restoring clarity of purpose.</li>



<li>Reducing the number of ALBs to delivery focused ALBs and removing the “middle men”</li>
</ul>



<p class="wp-block-paragraph">The NHS provides a salutary example of the impact of this complexity with multiple governance structures, regulatory requirements and conflicting purposes which illustrates these suggestions. There are multiple layers from the Secretary of State, Department for Health and Social Care, NHS England (soon to be abolished), NHSE Regional Teams, Integrated Care Boards (ICBs), NHS Trusts, Trust Boards, Management etc and in addition there are multiple Regulators. There is also the complexity of core purpose with a plethora of reporting indicators required by these various bodies, pressures to comply with the Public Sector Equality Duty, the requirement of the Health and Social Care Act 2012 to reduce health inequality outcomes and statutory climate change duties. From an NHS Trust Board perspective all of this must be monitored with processes and IT systems which were not set up for this purpose. If an acute hospital must reduce health inequality outcomes how is it practically to deliver this?&nbsp; For example, it is recognised that obesity is a driver of health outcomes.&nbsp; Should reducing obesity be a primary role of the hospital or would the public prefer they focus on reducing waiting lists?</p>



<p class="wp-block-paragraph"><strong>In Conclusion</strong></p>



<p class="wp-block-paragraph">Turning around the public sector is harder than turning around a business &#8211; but not impossible. With the right leadership, vision, and tools, even large organisations can transform. The state can too. Imagine a system that does fewer things but does them well. Imagine a culture that empowers rather than obstructs, an ecosystem that enables rather than frustrates, and an accountability structure that rewards delivery rather than delay. The outcome would be customer-focused services, a slimmed down State, and highly effective and motivated Public Sector.</p>



<p class="wp-block-paragraph">The question is not whether change is possible, but whether we as a nation are ready to embark on this difficult journey. The prize is nothing less than a state that works better, costs less, and serves us all. A State that works for us.</p>



<p class="wp-block-paragraph">Alison Rodwell</p>



<p class="wp-block-paragraph"><em><a href="https://www.linkedin.com/in/alisonrodwell/">Alison Rodwell </a>is the founder of Impact the Future which equips business leaders to play an active role in transforming the Public Sector.  </em></p>



<p class="wp-block-paragraph">23<sup>th</sup> September 2026</p>
<p>The post <a href="https://ukonward.com/onward-corner/a-state-that-works-for-us/">A State that works for us</a> appeared first on <a href="https://ukonward.com">Onward</a>.</p>
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		<title>The Hidden Benefits Bill: How Universal Credit claimants get £10 billion in extra benefits</title>
		<link>https://ukonward.com/reports/the-hidden-benefits-bill-how-universal-credit-claimants-get-10-billion-in-extra-benefits/</link>
		
		<dc:creator><![CDATA[Joanna Marchong]]></dc:creator>
		<pubDate>Sun, 01 Feb 2026 18:00:00 +0000</pubDate>
				<category><![CDATA[Reshaping the State]]></category>
		<category><![CDATA[Devolution and Local Government]]></category>
		<category><![CDATA[Education]]></category>
		<category><![CDATA[Health and Social Care]]></category>
		<category><![CDATA[Public Spending and Personal Tax]]></category>
		<category><![CDATA[Welfare]]></category>
		<guid isPermaLink="false">https://ukonward.com/?post_type=reports&#038;p=41382</guid>

					<description><![CDATA[<p>Executive Summary The eyewatering cost of Britain’s benefits bill is often discussed, but a key part of the conversation is usually missing. The additional payments that claimants can receive because of their eligibility for their regular benefits, known as passported benefits, are rarely included in analyses of how and why spending on working-age welfare has [&#8230;]</p>
<p>The post <a href="https://ukonward.com/reports/the-hidden-benefits-bill-how-universal-credit-claimants-get-10-billion-in-extra-benefits/">The Hidden Benefits Bill: How Universal Credit claimants get £10 billion in extra benefits</a> appeared first on <a href="https://ukonward.com">Onward</a>.</p>
]]></description>
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<h3 class="wp-block-heading">Executive Summary</h3>



<p class="wp-block-paragraph">The eyewatering cost of Britain’s benefits bill is often discussed, but a key part of the conversation is usually missing. The additional payments that claimants can receive because of their eligibility for their regular benefits, known as passported benefits, are rarely included in analyses of how and why spending on working-age welfare has become so out of control. This paper reveals the true scale of bonus benefits worth billions that are pushing against the intended incentives for claimants to move into work and towards full financial independence.</p>



<p class="wp-block-paragraph">Universal Credit payments were always meant to consolidate passported benefits. But the protracted rollout of Universal Credit has left these schemes running in parallel, fragmented across Whitehall, growing in scope and cost beyond the main levers of the welfare system. With rollout finally due to complete this parliament, now is the time to consider how to return to the original policy intent.</p>



<p class="wp-block-paragraph">Poverty metrics have underestimated the effective benefit income provided through passported benefits, distorting how support is targeted without allowing adequate evaluation of outcomes. Some are left missing out on thousands while others receive so much that they have little incentive to seek work or come off benefits altogether. Paternalism is destroying aspiration.</p>



<p class="wp-block-paragraph">Over £10 billion is estimated to be spent on working-age claimants alone through passported and discretionary schemes run by Government and utilities companies. Despite the price tag, they are too often failing to deliver the better outcomes for all:&nbsp;</p>



<ul class="wp-block-list">
<li><em>Free school meals expansion which is set to cause chaos for school funding.&nbsp;</em></li>



<li><em>Taxis to school for families already getting Motability cars.</em></li>



<li><em>Free holiday club places squeezing fee-paying parents.</em></li>



<li><em>Bursary cash for teenagers that may be damaging their earnings potential.</em></li>



<li><em>Free childcare for parents to stay at home, paid for by working parents.</em></li>



<li><em>Prescription charge exemptions for 96% of all prescription costs.&nbsp;</em></li>



<li><em>Dentistry, sight tests, health travel costs through archaic claims systems.&nbsp;</em></li>



<li><em>Pregnancy grants likely failing to improve outcomes for mum or baby.&nbsp;</em></li>



<li><em>Healthy food cards reportedly used for alcohol, tobacco and Playstations.&nbsp;</em></li>



<li><em>Energy bill and cold weather rebates for already energy efficient homes.</em></li>



<li><em>Heating and insulation upgrades worth almost £20,000 per household.&nbsp;</em></li>



<li><em>Water bill caps and special rates raising already surging water bills.</em></li>



<li><em>Special broadband tariffs giving claimants worse deals than switching.</em></li>



<li><em>Mismatched legal aid and court fee reforms set to bring in new cliff edges.</em></li>



<li><em>Funeral expense payment rules leaving grieving relatives without support.&nbsp;</em></li>



<li><em>Savings top-up accounts driving claimants to accrue more debt.</em></li>



<li><em>Council tax discounts double-taxing working claimants.&nbsp;</em></li>



<li><em>Local schemes being used for mini-golf, spa facility use and cinema tickets.</em></li>



<li><em>Discretionary housing funds working against national welfare policy.</em></li>
</ul>



<p class="wp-block-paragraph">Radical rationalisation of schemes into Universal Credit is necessary to deliver the simpler, more consistent and more certain system originally intended. Claimants should face the same basic budgeting dynamics as others in return for greater control over their cashflow. Alongside this, better data can give a more complete picture of the sufficiency of different benefit components within a single payment.&nbsp;</p>



<p class="wp-block-paragraph">Implementing a common framework for unforeseen or unavoidable costs would help simplify how those in crisis can access support. A more coherent set of rules and thresholds should govern routes for those on low incomes to receive one-off support for specific unexpected and unavoidable costs, including those beyond benefit eligibility.&nbsp;</p>



<p class="wp-block-paragraph">Lowering the Universal Credit taper to 50% is the final step in resetting the balance in favour of working, working more hours and increasing earnings without facing arbitrary penalties. Together these measures can improve the system for claimants and taxpayers alike.&nbsp;</p>



<h3 class="wp-block-heading"><strong>Introduction</strong></h3>



<p class="wp-block-paragraph">An expansive menu of extra payments and freebies for those already receiving benefits is weakening work incentives at a staggering cost of £10 billion. Working age benefit claimants negotiating this sprawling system are met with incoherent rules fragmented across over a dozen different schemes. This paper is the first systematic review of the costs of all benefits passported through receipt of Universal Credit and their average value to those claiming them. Alongside discretionary local schemes, this paper reveals how they collectively total over £10 billion in additional working-age welfare on top of Universal Credit payments.</p>



<p class="wp-block-paragraph">From its inception, the purpose of Universal Credit was to create a simplified benefits system where people were always better off starting work, taking on more hours, and progressing in their careers, rather than staying on benefits. It promised to consolidate payments into a simpler single award, smoothing out the cliff edges that saw support sharply withdrawn once you worked a certain number of hours or earned a certain amount. It was meant to save taxpayers’ money too.</p>



<p class="wp-block-paragraph">But, thirteen years on since the rollout of Universal Credit began, it has become anything but a single, universal payment. The benefits system for those of working age has ballooned in size, scope and cost. Reform that was meant to streamline multiple income-replacement legacy benefits has instead carried over and expanded multiple sub-schemes that are accessed by virtue of already being a claimant. These are collectively known as “passported benefits”: benefits for which eligibility is conferred via another benefit for which eligibility requirements have already been met.</p>



<p class="wp-block-paragraph">A two-tier benefits system has been created: one in which savvy claimants can gain thousands of extra pounds a year, but those with the least awareness or capacity still miss out on support. Jagged cliff edges have been carved, whereby being on benefits grants access to a wide array of top-ups, but reaching certain earnings levels risks suddenly losing these too. For everything from children’s meals to energy bills, there is an associated concession largely or exclusively for benefit claimants, almost half of whom are not required to look for work at all. In turn, passported benefits have created a deeply unfair two-tier state, where many of those just beyond benefit eligibility are fundamentally worse off than many claimants.</p>



<p class="wp-block-paragraph">To avoid political fights, successive governments have ended up double-handling certain living costs through passported work-arounds. Policy failures have been mitigated with more bureaucracy, rather than addressing the drivers of the high prices that affect everyone. Worse still, pervasive passporting has made it more rational to remain a client of the state rather than struggle through the jobs market, risking losing bonus entitlements once in work. Paternalism has triumphed over aspiration, undermining the core purpose of working-age welfare reform.</p>



<p class="wp-block-paragraph">This paper exposes the value of these schemes to claimants, the cost to taxpayers and consumers, and the cumulative effect on incentives for claimants to work at all and to progress in work. It proposes a radical reshaping of this area of state support, creating a welfare system with greater certainty, consistency and simplicity for claimants, and better value for the taxpayer.</p>



<h3 class="wp-block-heading"><a></a><strong>Background</strong></h3>



<p class="wp-block-paragraph">In the Welfare Reform Act 2012, Universal Credit (UC) set out to streamline a series of income-related legacy benefits into a single, integrated award to meet all essential living costs. This single payment was meant to slowly taper away benefit income while people transitioned into work, avoiding the previous cliff edges at 16 and 30 hours of work that would trigger sudden losses of income. As part of this simpler, fairer system, UC’s creators posited that it would be possible to do away with a plethora of schemes that had previously sat alongside legacy benefits. The foundational <em>Welfare that Works</em> policy document on UC stated the following:</p>



<figure class="wp-block-pullquote"><blockquote><p><em>“The current benefit dependent thresholds for access to a range of passported benefits (for example, free school meals and health benefits) will no longer exist. We will replace the current rules with an income or earnings-related system that gradually withdraws entitlements to prevent all passported benefits being withdrawn at the same time.”<a href="#_edn1" id="_ednref1"><sup><strong><sup>[1]</sup></strong></sup></a></em></p></blockquote></figure>



<p class="wp-block-paragraph">It was originally estimated that it would take from 2013 to 2017 to move all existing legacy benefit claimants onto the new system. However, today in 2026, managed migration of claimants is still not complete. The latest estimates suggest that migrating some of the most complex claims will take until 2029.<a href="#_edn2" id="_ednref2"><sup>[2]</sup></a> Alongside this protracted rollout period, many of the passported schemes available to legacy claimants continued to be passported on the same basis to UC claimants too to avoid disincentives to migrate and legal challenge, even if it would be technically possible to roll these into UC payments.</p>



<p class="wp-block-paragraph">During the Covid-19 pandemic and the global energy price spike, surging inflation gave rise to renewed focus on the cost of living and the ability of those on low incomes to afford the basics. In addition to a temporary £20 uplift in UC payments, this period saw the rapid creation, expansion or uprating of multiple passported benefits schemes that, unlike the uplift, have not all been scaled back since. Rather than phasing out passporting, schemes like free school meals and the Warm Home Discount are expanding to all UC claimants in the coming year, but still remaining separate from UC itself.</p>



<p class="wp-block-paragraph">Despite the Secretary of State for Work and Pensions having formal responsibility for the benefits system, control over passported benefits has become diffuse across government. Now, almost every domestic policy department administers or regulates at least one passported benefit or discretionary scheme, as shown in Figure 1. Each scheme has its own rules, caps and thresholds that layer on top of UC-enabled eligibility, many of which are not adjusted for years at a time to reflect real-world prices. Having billions of additional welfare beyond the Department for Work and Pensions’ (DWP) borders makes the already alarming trajectory of the benefits bill all the more acute, with serious but underrated consequences for efforts to decrease the budget deficit.&nbsp;</p>



<p class="wp-block-paragraph"><strong>Figure 1 &#8211; Scheme by relative size of expenditure on working-age claimants</strong></p>



<p class="wp-block-paragraph"><em>Source: Onward analysis</em></p>



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<h4 class="wp-block-heading"><strong>Eligibility checks</strong></h4>



<p class="wp-block-paragraph">Checking eligibility for passported benefits relies on multiple parts of the state being able to confirm existing benefit receipt. Unlike PAYE data which is shared on a real-time basis between HMRC and DWP, the onward sharing of benefit receipt data has no seamless flow to the other departments or companies involved in passported schemes. Instead, for most passported benefits, manual bulk data extracts are shared on a daily or weekly basis for operational eligibility checks. This is onerous and expensive to administer.</p>



<p class="wp-block-paragraph">According to the DWP’s own careers website, there are over 300 data professionals working in its Data Practice, responsible for how they model, transform and securely use data across DWP and wider government.<a href="#_edn3" id="_ednref3"><sup>[3]</sup></a> There will then be further costs from those in other government departments, public bodies and private companies responsible for processing the data, overlaying additional criteria and delivering the benefits.&nbsp;</p>



<p class="wp-block-paragraph">Given that eligibility for passported benefits is conferred from other benefits claimed, it is easy to assume that take-up would be high across the board. In reality, it is highly uneven. There are a range of different ways in which passported benefits are accessed. Some require the claimant to provide evidence of an existing benefit claim, while others require the institution handing out the benefit to check on the claimants’ behalf.</p>



<p class="wp-block-paragraph">For example, free prescriptions operate on a self-declaration system. Others like free school transport require parents to fill in an application form which is then verified by the local authority using central government data and local information on the distance to the school. The level of friction in the system caused by the need to apply for some passported benefits means that there are widely varying levels of uptake.</p>



<h4 class="wp-block-heading"><strong>Uncounted income</strong></h4>



<p class="wp-block-paragraph">Assessing the appropriate level of financial support for people with different personal means is a difficult task. For those without earned income, this is particularly challenging. The UK’s official poverty measures &#8211; absolute and relative poverty &#8211; use the Households Below Average Income (HBAI) dataset, which relies on self-reporting of income in the annual Family Resources Survey (FRS), which is then combined with administrative data on DWP benefits, HMRC data and price indices. Both official poverty measures are relative measures, setting an arbitrary line at 60% of median household income, with one rebasing this every year and the other looking at how incomes have changed since 2009/10.</p>



<p class="wp-block-paragraph">Neither poverty measure looks at what these households are able to afford in any given year, nor accounts for what they may be provided in-kind, free or at a subsidised rate by virtue of being a benefit recipient. Outside of Covid-related cost of living payments, only free school meals, Healthy Start and the Warm Home Discount are routinely counted.<a href="#_edn4" id="_ednref4"><sup>[4]</sup></a> For most other passported benefits, the HBAI dataset excludes their value in poverty measures, despite them having a direct impact on the daily living costs of many considered below the respective poverty lines.</p>



<p class="wp-block-paragraph">The material deprivation metric, which includes answers from the FRS on the resources and activities that families can afford, does not attach any monetary value to these items. An additional measure of poverty developed by the Social Metrics Commission is currently under consideration by the Government, which would assess whether households have Below Average Resources rather than income, but does not plan to incorporate passported benefits due to lack of reliable data.<a href="#_edn5" id="_ednref5"><sup>[5]</sup></a></p>



<p class="wp-block-paragraph">Difficulty in assessing claimants’ income bleeds through into the design of passported benefits. Schemes use a jumbled assortment of different thresholds, including disposable income, earned income, effective income after certain savings could be liquidated and income with certain specific disregards. Several passported benefit schemes use their own income-related thresholds which typically do not count benefit income, therefore directly penalising those trying to earn enough to come off benefits.</p>



<p class="wp-block-paragraph">Figure 2 below shows different equivalent monthly earnings thresholds for select schemes to show relative generosity. Some schemes count claimants’ income over the whole year, while some take each individual monthly assessment period, meaning eligibility can fluctuate from month to month along with earnings.</p>



<p class="wp-block-paragraph"><strong>Figure 2 &#8211; Equivalent monthly earned income threshold by UC passport or means test</strong></p>



<p class="wp-block-paragraph"><em>Source: Onward analysis</em></p>



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<p class="wp-block-paragraph">Other schemes also use levels of savings thresholds in their eligibility requirement which differ from the standard capital limits in UC. And with schemes for which eligibility applies throughout a UC claim, there is still a cliff-edge at the end where those with a very small UC award go from receiving thousands extra in passported benefits to nothing if they see a minor increase in earned income. While some schemes also have income tests for those not on any benefits to gain eligibility, there is again no consistency in how their income is treated.</p>



<h4 class="wp-block-heading"><strong>Evaluation gaps</strong></h4>



<p class="wp-block-paragraph">The inaccurate reporting of total effective income has critical policy implications. As passported benefits have changed in scope or generosity, there has been no year-on-year total measurable impact on poverty alleviation, despite the extra cash that is given out. Even for individual schemes that are counted, such as free school meals, bold statements about lifting 100,000 children out of poverty by 2030 are taken from a static microsimulation model making a snapshot estimate, which includes assuming 100% take-up, with no adjustment for those already receiving free school meals under transitional protections.<a href="#_edn6" id="_ednref6"><sup>[6]</sup></a></p>



<p class="wp-block-paragraph">Both internally within government and externally for research purposes, the lack of continuous data to evaluate whether any passported benefits have met their modelled poverty reduction goals is highly problematic. While specific policy simulation models for individual schemes are possible, there is no real time information to monitor the direct upsides or unintended consequences of these policies in aggregate. There is both little cross-government tracking of those who may be missing out on multiple passported benefits, nor evaluation of how claiming many can distort work incentives.</p>



<p class="wp-block-paragraph"><strong>Figure 3 &#8211; Estimates of select unclaimed passported benefits in Great Britain 2025/26</strong></p>



<p class="wp-block-paragraph"><em>Source: Policy in Practice</em><a href="#_edn7" id="_ednref7"><sup>[7]</sup></a><em></em></p>



<figure class="wp-block-table"><table class="has-fixed-layout"><tbody><tr><td>&nbsp;</td><td><strong>Missed claims</strong></td><td><strong>Average unclaimed</strong></td><td><strong>Total missed (millions)</strong></td></tr><tr><td>Council tax support</td><td>2,571,000</td><td>£1,286</td><td>£3,306</td></tr><tr><td>Broadband social tariffs</td><td>7,537,000</td><td>£200</td><td>£1,508</td></tr><tr><td>Water social tariffs/WaterSure</td><td>3,847,000</td><td>£194</td><td>£745</td></tr><tr><td>Warm Homes Discount</td><td>4,812,000</td><td>£150</td><td>£722</td></tr><tr><td>Free School Meals</td><td>123,000</td><td>£561</td><td>£69</td></tr><tr><td>Healthy Start/Best Start Foods</td><td>201,000</td><td>£273</td><td>£55</td></tr></tbody></table></figure>



<p class="wp-block-paragraph">Recent analysis by Policy in Practice estimates that over 7.5 million people are missing out on at least one type of passported benefit for which they are eligible.<a href="#_edn8" id="_ednref8"><sup>[8]</sup></a> This is attributed to several factors, principally awareness, complexity, and stigma associated with claiming. This leaves some without thousands of pounds which someone else in near identical circumstances may be receiving. For example, in 2025/26 the value of support missed out on was estimated as more than £3.3 billion in council tax support, £1.5 billion in broadband social tariffs, £745 million in water support and £722 million in the Warm Home Discount.<a href="#_edn9" id="_ednref9"><sup>[9]</sup></a></p>



<p class="wp-block-paragraph">Likewise, recent UK-specific evidence is scant on the relative merits of providing benefits in-kind versus ringfencing cash or labelling cash for a specific purpose. While there has been some analysis of the impact of labelling fully fungible benefits like the Winter Fuel Payment and the Education Maintenance Allowance for their specific purposes, their behavioural impact is mixed, with difficulty tracking by how much the cash had helped manage the intended cost versus improving the claimants overall outcomes.<a href="#_edn10" id="_ednref10"><sup>[10]</sup></a></p>



<p class="wp-block-paragraph">The counterfactual scenario of rolling such benefits into core benefit income is rarely considered for schemes providing non-cash benefits. Behavioural analysis of the upsides of passporting usually focus on whether the cash has been used for its labelled purpose rather than considering whether that was really the best use within that household’s total budget. In essence, it starts from a deeply paternalistic notion that bureaucrats running a government scheme know better than a claimant how they should spend money to support themselves.</p>



<h4 class="wp-block-heading"><strong>The cost of policy crisis</strong></h4>



<p class="wp-block-paragraph">Lack of robust continuous evaluation of individual passported benefit schemes, let alone any tracking of their cumulative impact on effective household income, has meant siloed schemes have proliferated. The pathology of “everythingism”, as recently set out by <em>Re:State’</em>s Joe Hill, has gripped each government department in this regard too.<a href="#_edn11" id="_ednref11"><sup>[11]</sup></a> Wildly different and poorly-defined markers of poverty, inequality and perceived vulnerability have become baked into the design of domestic policy, detracting from the cost-saving potential of simply allowing each area to do one thing well.</p>



<p class="wp-block-paragraph">In the last few decades, the narrative on poverty itself has snowballed into multiple types of poverty: food poverty, fuel poverty, water poverty, digital poverty, clothing poverty, carpet poverty, mattress poverty and more. Each has their own stakeholder ecosystem lobbying different parts of government for specific carve-outs, despite the central issue for all of them being a household’s total ability to afford essentials through their income.</p>



<p class="wp-block-paragraph">Many stakeholders directly benefit from the schemes they have lobbied for, getting government contracts to assist in the delivery of the over-complicated schemes they helped design or receiving research funding to confirm their biases. Their intentions may be well-meaning, often irresistible to ministers seeking a positive news story, but there is a cost.</p>



<p class="wp-block-paragraph">As inflation began to spike in late 2021, discussion of the affordability of daily essentials evolved into discussion of a “cost of living crisis.” Volatile global circumstances certainly contributed considerably to surging prices for some essentials. But as the peak has receded, the Government has continued to wrestle with stubbornly high expenditure on public services. This has exposed an altogether more uncomfortable truth &#8211; that the “cost of living crisis” is, at least in part, a cost of policy crisis.</p>



<p class="wp-block-paragraph">Much of the response to rising prices has focused on bolstering demand side protections by uprating passported benefits rather than supply side measures to address the underlying drivers. For each bespoke scheme to cover the price of goods and services that the rest of the population purchase with their own income, the cost is borne elsewhere. This is not just by the taxpayer picking up the cost of each scheme, but also through the wider distortive impact on market prices when a significant cohort receives a subsidy.</p>



<p class="wp-block-paragraph">If the companies are forced to offer products at a loss or lower profit margin for claimants, they will recoup the revenue from other consumers. For some passported benefits schemes, like those run by utilities companies that are not financially subsidised by the government, the cost is directly passed onto consumers in the form of higher bills. Yet supply side policies like deregulation, enabling competition or corporation tax cuts that could lower consumer costs for everyone, including those just beyond benefit eligibility, are not considered as the primary levers for lowering the cost of living.</p>



<p class="wp-block-paragraph">In a clamour to appear caring, the welfare state has splintered. Each domestic policy department now effectively runs its own poverty programme, with its own inaccurate understanding of what poverty is and using its own bespoke delivery apparatus. There is no common accounting for the total support any household receives, no consistent evaluation of outcomes, and no ministerial line of sight over the cumulative fiscal and market impact. This is an irrational way to spend public money: it duplicates administration, entrenches arbitrary eligibility cliffs, and pushes costs onto non-recipients via cross-subsidy, price effects and higher charges. The net effect harms modest-income working households who receive little or nothing, while obscuring the true level of state support and who ultimately pays for it.</p>



<h4 class="wp-block-heading"><strong>Work incentives</strong></h4>



<p class="wp-block-paragraph">Unlike other benefits, passported benefit awards are usually binary rather than proportional to the amount of UC award or to need. While elements included within a UC claim are tapered away with earnings, most passported benefits have a fixed value: you either get it or you don’t. The impact of passported benefits on work incentives was noted from the inception of UC, yet little assessment of their impact has taken place since.</p>



<p class="wp-block-paragraph">In 2012, the Social Security Advisory Committee independent review of passported benefits highlighted how they “can create an unhelpful cliff edge and reduce the apparent gains to work.”<a href="#_edn12" id="_ednref12"><sup>[12]</sup></a> In accepting the findings of the review, the Coalition Government noted that “the design of passported benefits under UC can have a key impact on incentives to work”, signalling their intention to roll the current suite of passported benefits into UC payments. However, there has been no comprehensive evaluation of the cumulative impact of passported benefits through the entire rollout of UC to date.</p>



<h4 class="wp-block-heading"><a></a><strong>Conditionality</strong></h4>



<p class="wp-block-paragraph">Passported benefits increase incentives on claimants to be classified into different UC conditionality regimes because not working means no risk of losing entitlements at various income thresholds or at the end of the claim. Conditionality regimes determine the different expectations upon claimants to look for work, undertake training, work more hours or not have to undertake any work-seeking activity at all.</p>



<p class="wp-block-paragraph">Since mid-2020, the number of people with no requirements to work or take any steps towards finding a job has ballooned from below a million to 3.7 million.<a href="#_edn13" id="_ednref13"><sup>[13]</sup></a> In part, this is a feature of leaving the most complex legacy cases, usually involving disability, as the last cohort to migrate, but it is also caused by the surge in new health-related claims since the Covid-19 pandemic. As a consequence of this change in case mix, for the vast majority of UC claimants, receipt of passported benefits is effectively unconditional and often permanent, with no expectation that they will work or look for work while they continue to receive free or discounted goods and services paid for by those working.</p>



<p class="wp-block-paragraph"><strong>Figure 4 &#8211; UC claimants by conditionality regimes</strong></p>



<p class="wp-block-paragraph"><em>Source: DWP Stat-Xplore<a href="#_edn14" id="_ednref14"><sup><strong><sup>[14]</sup></strong></sup></a></em></p>



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<h4 class="wp-block-heading"><a></a><strong>Modelling incentives</strong></h4>



<p class="wp-block-paragraph">Financial incentives to start work and then progress in work can be measured by looking at the participation tax rate and the marginal effective tax rate respectively. The participation tax rate (PTR) measures the proportion of earnings deducted through higher tax and lower benefit entitlement at the point of moving into work. The marginal effective tax rate (METR), sometimes known as the marginal deduction rate, is the percentage of each additional £1 in earnings that is lost to tax or benefits reduction. Taking Institute for Fiscal Studies analysis from 2024, just under 60% of working UC claimants have a participation tax rate of 50% or more.<a href="#_edn15" id="_ednref15"><sup>[15]</sup></a> This means that if they earned £10,000 before tax per year in work, they would see their income rise by £5,000 or more if they started working.</p>



<p class="wp-block-paragraph"><strong>Figure 5 &#8211; Participation rates and marginal effective tax rates, among workers eligible for UC or legacy benefits</strong></p>



<p class="wp-block-paragraph"><em>Source: Institute for Fiscal Studies<a href="#_edn16" id="_ednref16"><sup><strong><sup>[16]</sup></strong></sup></a></em></p>



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<p class="wp-block-paragraph">Likewise for those seeking to progress in work while on UC, 80% lose more than 50p for every extra pound they earn.<a href="#_edn17" id="_ednref17"><sup>[17]</sup></a> 63% of those working on UC lose more than 60p for every extra pound. It demonstrates how the majority of those working on UC have well above 55% of their income deducted through the taper and tax.<a href="#_edn18" id="_ednref18"><sup>[18]</sup></a> This is a product of the damaging interaction between the UC system and the tax system that directly works against incentives on claimants to take on more hours or seek higher pay. Neither of these rates typically include the loss of passported benefits as claimants take on more hours.</p>



<p class="wp-block-paragraph">Modelling the interaction between the tax system, which treats people as individuals, and the benefits system, which looks at the whole household, is complicated enough on its own. But adding more than a dozen passported benefit schemes, each affecting different household compositions, becomes almost impossible. There is no comprehensive policy modelling of participation rates or marginal effective tax rates that include the additional effective income provided through passported benefits. In the absence of this modelling, the paper takes the first step: understanding the eligibility routes, quantifying the costs and assessing the interaction with work.</p>



<h3 class="wp-block-heading"><a></a><strong>Scheme-by-scheme analysis</strong></h3>



<p class="wp-block-paragraph">This section gathers the best available published data to quantify how many claims are being made for each passported scheme, the average value of the benefit and total expenditure on those passported via UC or legacy working age benefits that are being replaced by UC. It includes both the costs to taxpayers of government-funded schemes and those that government regulation requires companies to fund, for which they will pass on the costs to other consumers.<a href="#_edn19" id="_ednref19"><sup>[19]</sup></a></p>



<p class="wp-block-paragraph">It also lists discretionary schemes that are available largely or exclusively to claimants that can further top up their income, with best estimates of the proportion of the scheme used by UC or legacy working-age claimants. In addition, we estimate the cost of these policy decisions in terms of the funding that has to be provided to UK nations beyond England as a result of the UK Government’s policy, by using Barnett formula proportion adjustments, the method for which is explained further below.</p>



<p class="wp-block-paragraph">This section then goes through each passported benefit to discuss each passported benefit. If scheme explanations appear overly-technical, arbitrary in nature and difficult to process, that is precisely the point &#8211; their rules are often incomprehensible to claimants and impossible for the Government to manage effectively.</p>



<p class="wp-block-paragraph">The scheme-by-scheme analysis that follows will seek to answer the following questions:</p>



<ul class="wp-block-list">
<li><em>What are the eligibility criteria?</em></li>



<li><em>How many claimants on UC or legacy working-age benefits are eligible?</em></li>



<li><em>How much does each claimant receive on average?</em></li>



<li><em>Is there an alternative non-passported route to access the scheme or service?</em></li>



<li><em>What is the total spending on those eligible via UC or legacy working-age benefits only?</em></li>



<li><em>What evaluation has taken place?</em></li>



<li><em>What impact might the scheme have on incentives to work?</em></li>



<li><em>What changes are announced or expected in the current calendar year?</em></li>
</ul>



<p class="wp-block-paragraph"><strong>Figure 6 &#8211; Claim count, average award, total expenditure and Barnett adjustment by scheme</strong></p>



<p class="wp-block-paragraph"><em>Source: <a href="https://github.com/ukonward/The-Hidden-Benefits-Bill/blob/main/The%20Hidden%20Benefits%20Bill%20VF.xlsx" type="link" id="https://github.com/ukonward/The-Hidden-Benefits-Bill/blob/main/The%20Hidden%20Benefits%20Bill%20VF.xlsx">Onward analysis</a><a href="#_edn20" id="_ednref20"><sup><strong><sup>[20]</sup></strong></sup></a></em></p>



<figure class="wp-block-table"><table class="has-fixed-layout"><tbody><tr><td><strong>&nbsp;</strong></td><td><strong>Claim count</strong></td><td><strong>Average award</strong></td><td><strong>Total expenditure (million)</strong></td><td><strong>Barnett adjustment (million)</strong></td></tr><tr><td>Free School Meals</td><td>2,680,000</td><td>£495</td><td>£1,132</td><td>£1,332</td></tr><tr><td>Free school transport</td><td>36,400</td><td>£1,495</td><td>£52</td><td>£62</td></tr><tr><td>Holiday Activities &amp; Food Prog.</td><td>628,000</td><td>£300</td><td>£214</td><td>£252</td></tr><tr><td>Vulnerable Students Bursary</td><td>23,685</td><td>£720</td><td>£17</td><td>£20</td></tr><tr><td>Extra support childcare</td><td>92,580</td><td>£5,988</td><td>£544</td><td>£640</td></tr><tr><td>Free prescriptions</td><td>7,928,507</td><td>£140</td><td>£1,168</td><td>£1,375</td></tr><tr><td>Free dental treatment</td><td>3,729,426</td><td>£81</td><td>£302</td><td>£355</td></tr><tr><td>Sure Start Maternity Grant</td><td>47,200</td><td>£500</td><td>£24</td><td>£26</td></tr><tr><td>Healthy Start</td><td>354,720</td><td>£269</td><td>£86</td><td>£94</td></tr><tr><td>Warm Home Discount*</td><td>4,448,809</td><td>£150</td><td>£636</td><td>£712</td></tr><tr><td>Energy Company Obligation*</td><td>18,548</td><td>£19,748</td><td>£366</td><td>£379</td></tr><tr><td>Cold Weather Payments</td><td>1,194,000</td><td>£25</td><td>£21</td><td>£23</td></tr><tr><td>WaterSure*</td><td>86,846</td><td>£325</td><td>£28</td><td>£31</td></tr><tr><td>Water social tariffs*</td><td>1,393,560</td><td>£244</td><td>£266</td><td>£298</td></tr><tr><td>Broadband social tariffs*</td><td>506,000</td><td>£200</td><td>£101</td><td>£101</td></tr><tr><td>Legal aid</td><td>144,896</td><td>£3,257</td><td>£472</td><td>£528</td></tr><tr><td>Court fee remission</td><td>122,517</td><td>£661</td><td>£81</td><td>£91</td></tr><tr><td>Funeral Expenses Payment</td><td>19,155</td><td>£1,545</td><td>£40</td><td>£45</td></tr><tr><td>Council tax support</td><td>2,288,079</td><td>£1,200</td><td>£2,746</td><td>£3,232</td></tr><tr><td>Help to Save</td><td>202,200</td><td>£223</td><td>£45</td><td>£45</td></tr><tr><td>Flexible Support Fund**</td><td>&nbsp;</td><td>&nbsp;</td><td>£117</td><td>£128</td></tr><tr><td>Crisis &amp; Resilience Fund**</td><td>&nbsp;</td><td>&nbsp;</td><td>£529</td><td>£623</td></tr><tr><td><strong>TOTAL</strong></td><td>&nbsp;</td><td>&nbsp;</td><td>£8,297</td><td>£10,392</td></tr></tbody></table></figure>



<h4 class="wp-block-heading"><a></a><strong>Limitations</strong></h4>



<h5 class="wp-block-heading"><a></a><strong>Legacy benefits</strong></h5>



<p class="wp-block-paragraph">While the rollout of UC continues, different legacy working age benefits remain listed as eligibility criteria for most passported schemes, with no consistency as to which apply. Most list income-based Jobseekers Allowance (JSA), income-based Employment and Support Allowance (ESA) and Income Support, but exclude contributory JSA and ESA which are remaining outside UC as they are not classed as income-related benefits.<a href="#_edn21" id="_ednref21"><sup>[21]</sup></a></p>



<p class="wp-block-paragraph">Figure 7 below shows schemes which passport via different benefits in England from 2026/27, including changes to eligibility for Free School Meals and the Warm Homes Discount which will passport to all those on UC within this year. Some provide a passport but with specific additional conditions, such as an income or savings cap. For some, like water or broadband social tariffs and council tax reductions, eligibility is heavily caveated as these are not nationally consistent schemes.</p>



<p class="wp-block-paragraph"><strong>Figure 7 &#8211; Eligibility by passporting benefit in England from 2026/27</strong></p>



<p class="wp-block-paragraph"><em>Source: Onward analysis</em></p>



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<p class="wp-block-paragraph">With a reasonable prospect that UC rollout will complete during the current parliament and with legacy benefit caseloads diminishing throughout, this paper discusses passported benefit eligibility via UC while acknowledging that there will still be small numbers eligible via legacy benefits.<a href="#_edn22" id="_ednref22"><sup>[22]</sup></a> Indeed, the end of legacy-related eligibility over the next few years provides the opportunity to radically change how passporting operates, free of the need to retrofit innovation onto legacy systems.</p>



<h5 class="wp-block-heading"><a></a><strong>Pensioner benefits</strong></h5>



<p class="wp-block-paragraph">In addition to legacy benefits, many passported benefit eligibility criteria include those on pensioner benefits, as shown in Figure 7. Pension Credit is the means-tested benefit for those on low incomes above state pension age, with two different elements depending on the level of household savings. Pension Credit Guaranteed Element is usually used as the UC-equivalent passport, but some include Pension Credit Saving Element too.</p>



<p class="wp-block-paragraph">Only some schemes provide specific breakdowns of the numbers claiming by eligibility route or by age to determine how many of those claiming are of working age. Where reasonably possible, those claiming via pensioner benefits are removed from analysis of number of claimant caseload and cost, or else are estimated to be negligible due to the expected age of the claimant.</p>



<h5 class="wp-block-heading"><a></a><strong>Disability benefits</strong></h5>



<p class="wp-block-paragraph">Recent political attention on welfare and work incentives has been dominated by focus on the significant increases of those claiming disability and health-related benefits, both through UC and Personal Independence Payments (PIP). 39% of people on UC are now in receipt of the UC health element, up 41% in just a year.<a href="#_edn23" id="_ednref23"><sup>[23]</sup></a> While over two thirds of this was migration of legacy ESA claimants which are one of the last cohorts to receive migration notices, new claims are rising year-on-year too.<a href="#_edn24" id="_ednref24"><sup>[24]</sup></a></p>



<p class="wp-block-paragraph">While most UC elements were frozen in cash terms from 2016 to 2020, PIP was uprated in line with CPI inflation, making it relatively more attractive to claim alongside UC. To qualify for the enhanced rates, a prospective claimant must be assessed, scoring sufficient difficulty with carrying out activities usually associated with work, such as being able to get out of bed, washed and dressed independently, being able to travel to a workplace or ease of communication with colleagues or customers. While assessments for PIP and the UC health element will remain separate until at least 2029/30, there is still a commonality between scoring sufficient points to gain a high PIP award and proving limited capability for work.<a href="#_edn25" id="_ednref25"><sup>[25]</sup></a></p>



<p class="wp-block-paragraph">This link extends to eligibility for passported benefits too. If a claimant does not want to risk losing access to passported benefits by earning too much from work, having no work requirements through being assessed as having limited capability for work and gaining more income through PIP instead can grant near-permanent entitlement. Reassessments remain mired in a Covid-related backlog, with 110,000 existing claimants awaiting Work Capability Assessments.<a href="#_edn26" id="_ednref26"><sup>[26]</sup></a> The Government’s proposed “Right to Try” guarantee may prevent work in itself being considered a change of circumstances triggering a reassessment, earned income may still result in ineligibility for some passported benefits.<a href="#_edn27" id="_ednref27"><sup>[27]</sup></a> Changes to Work Capability and PIP assessments are sorely needed to bring more claimants into work-seeking conditionality regimes, but beyond the direct scope of this paper.</p>



<p class="wp-block-paragraph">Where health conditions provide a specific eligibility for a passported benefit scheme, these are noted in the scheme-by-scheme analysis. Passporting is also provided directly from some disability benefit claims. The enhanced rate mobility component of PIP grants access to significantly subsidised new vehicles through Motability.<a href="#_edn28" id="_ednref28"><sup>[28]</sup></a> This prompted several tax changes exclusive to Motability at the Autumn Budget and proposals from the Conservatives to tighten eligibility.<a href="#_edn29" id="_ednref29"><sup>[29]</sup></a> As Motability is not passported through UC and has already received significant separate scrutiny, it is not considered in detail in this paper.</p>



<h5 class="wp-block-heading"><a></a><strong>Devolved nations</strong></h5>



<p class="wp-block-paragraph">UC is a UK-wide benefit, but passported benefits have different territorial extents. This analysis of passported benefits primarily focuses on those available in England or England and Wales where relevant depending on devolved powers in different policy areas. Where relevant, alternative schemes operating beyond England are mentioned but excluded from direct costing analysis.</p>



<p class="wp-block-paragraph">The Welsh Assembly has no devolved competence over UC, but does have devolved power over passported benefits like free school meals, free prescriptions, council tax reduction and other discretionary assistance delivered outside the remit of the DWP. The Scottish Parliament has additional powers under the Scotland Act 2016 under which it has chosen to change aspects of UC payment delivery. It has also chosen to provide additional benefits such as the Scottish Child Payment to those with children in receipt of UC or Pension Credit, but this is delivered separately from the UC system.</p>



<p class="wp-block-paragraph">To get an estimate of total policy costs as a result of UK Government policy decisions, Barnett formula percentages are used to estimate funding. These are not the exact amounts that Wales, Scotland and Northern Ireland receive, as these are calculated at the point of changes in policies covered by departmental expenditure limits (DEL) rather than the totals in any given year, with population adjustments revised over time. Demand-led policies funded through annual managed expenditure (AME) only have Barnett applied at the point they are initially transferred into the block grant. Costs to private companies through regulated schemes are also calculated using the same percentages where relevant to reflect population size-based estimates, although these are funded directly by companies rather than Government. Barnett-based estimates of total expenditure are intended to make a general approximation of the scale of cost that UK Government policy decisions incur, rather than assess individual spending on any passporting policies implemented beyond England.</p>



<h3 class="wp-block-heading"><a></a>Education</h3>



<h4 class="wp-block-heading"><a></a><strong>Free School Meals</strong></h4>



<p class="wp-block-paragraph">Provision of free school meals on a nationally-consistent basis was first introduced in the 1960s, having previously been provided at the discretion of the local authority. This set an income cap linked to family size for the first time, which was just above half of gross average earnings for a two child family.<a href="#_edn30" id="_ednref30"><sup>[30]</sup></a> Thatcher’s 1980 Education Act reforms then introduced the first formal “passporting” for free school meals: eligibility became automatic for families receiving Supplementary Benefit (typically for those out of work) or Family Income Supplement (for those in low-paid work). Free school milk, which she had previously limited to children under seven, was also passported on the same basis for those aged five to seven, plus those with certain medical needs.</p>



<p class="wp-block-paragraph">Since then, the passporting of free school meals via low income or out of work benefits has remained. Free school meals for infants in reception, Year 1 and Year 2 were removed from the passported system in 2013 to be provided on a universal basis in all state-funded schools. For those in Year 3 and above, an income cap of £7,400 net earned income for households on UC which was introduced in 2018 and has remained frozen until the next coming academic year.<a href="#_edn31" id="_ednref31"><sup>[31]</sup></a> Each meal is funded with £2.61, or £495 per year across term time.<a href="#_edn32" id="_ednref32"><sup>[32]</sup></a></p>



<p class="wp-block-paragraph">Transitional protection has been in place while UC was being rolled out whereby a child who became eligible for free school meals would remain eligible for the duration of that phase of education (i.e. the whole of primary or secondary school) even if they came off UC. Even families who only experienced a temporary drop in their income while their child was in Year 7 and claimed UC could therefore be entitled to five years of support, or almost £2,500 of effective subsidy. For a single parent with two school-aged children, this means that earning £7,399 and keeping free school meals would be financially preferable to earning up to £9,400 or working an extra four hours at National Living Wage per week if they are due to change phase of education.<a href="#_edn33" id="_ednref33"><sup>[33]</sup></a></p>



<p class="wp-block-paragraph">In April 2022, eligibility for free school meals was also extended to children in all households with a visa condition of “No Recourse to Public Funds” (NRPF), subject to comparative income caps with families with recourse to public funds.<a href="#_edn34" id="_ednref34"><sup>[34]</sup></a> There is currently no data on how many families have an NRPF condition and therefore no way of quantifying the size of this cohort. Likewise, it is also possible to be eligible for free school meals with parents above state pension age through receipt of Pension Credit Guaranteed Element, but there is no breakdown of how many children are passported via this route. Taking into account those small numbers eligible via these other routes, there are 1.6 million children in total currently claiming free school meals from Year 3 onwards.</p>



<p class="wp-block-paragraph">From the next academic year, the income cap for qualifying UC claimants will be lifted, meaning that all families on UC will get free school meals, regardless of their earnings.<a href="#_edn35" id="_ednref35"><sup>[35]</sup></a> The Institute for Fiscal Studies suggests that 1.7 million, or 69% of children whose families are on UC who are above the income threshold, will become eligible, as shown in Figure 8.<a href="#_edn36" id="_ednref36"><sup>[36]</sup></a> The Department for Education estimates that more than 500,000 children would be brought into the scheme from next year.<a href="#_edn37" id="_ednref37"><sup>[37]</sup></a> However, due to transitional protection, some of those children will already be in receipt of free school meals despite their families not being in receipt of UC (and potentially earning much higher than the current income cap) so it will likely initially benefit far fewer families than expected.<a href="#_edn38" id="_ednref38"><sup>[38]</sup></a></p>



<p class="wp-block-paragraph"><strong>Figure 8 &#8211; Free school meals eligibility in 2023/24 by number of children and net family earnings</strong></p>



<p class="wp-block-paragraph"><em>Source: Institute for Fiscal Studies</em><a href="#_edn39" id="_ednref39"><sup>[39]</sup></a><em></em></p>



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<p class="wp-block-paragraph">Transitional protection is also being ended from the next academic year so eligibility for free school meals will be assessed on the basis of current UC receipt only, although guidance has not yet been issued as to whether this will be checked on an annual basis or each assessment period. The Department for Education does not publish data on the number of children currently receiving free school meals through transitional protection in England. However, the proportion in Wales who were transitionally protected last year was 27%.<a href="#_edn40" id="_ednref40"><sup>[40]</sup></a> Over time, this will become a hugely significant change, not just for eligible families, but also for local authorities allocating funding to the schools they are attending.</p>



<p class="wp-block-paragraph">In some local authority areas, eligibility for free school meals already extends beyond those covered by existing UC and income threshold rules. In London, the Mayor has extended free school meals to all primary school children, at a cost of £141 million in the current academic year.<a href="#_edn41" id="_ednref41"><sup>[41]</sup></a> While the unit cost per meal is modelled at a higher rate than the national scheme, as around 13% of parents do not take up the scheme, the effective subsidy per pupil evens out to around the same level. Receipt of universal primary school free school meals in London does not affect eligibility for any national passported benefits usually available via this route, which are instead assessed on the national free school meals criteria.</p>



<p class="wp-block-paragraph">In Wales, free school meals are available on a universal basis to those in primary school, with secondary pupils eligible on the same terms as in England.<a href="#_edn42" id="_ednref42"><sup>[42]</sup></a> They also pay schools more per meal, at a rate of £3.40 rather than £2.61 in England.<a href="#_edn43" id="_ednref43"><sup>[43]</sup></a> The Welsh Assembly will receive Barnett consequentials for England’s extension of free school meals eligibility to all those on UC, but have not yet confirmed whether they will replicate the lifting of the earned income cap for secondary school pupils.</p>



<h4 class="wp-block-heading"><a></a><strong>School funding</strong></h4>



<p class="wp-block-paragraph">The radical change in passported benefit eligibility has far reaching implications for schools as a whole because so many aspects of their funding are calculated based on pupil eligibility for free school meals. School funding is not included in the costings for this analysis, but discussed due to the scale of the expenditure that now needs to be increased to match free school meals eligibility or calculated another way.</p>



<p class="wp-block-paragraph">Pupil Premium funding, which provides an extra £1,480 or £1,050 per primary or secondary school pupil respectively currently on free school meals or any pupil who has received free school meals within the last six years in that phase of education (known as Ever 6 FSM or FSM6). At present, the six year rule means that Pupil Premium funding acts much in the same way as transitional protection, providing the school with the extra funding regardless of whether that pupil’s family has only been very briefly eligible for free school meals.</p>



<p class="wp-block-paragraph">The effect of changes to free school meals eligibility on Pupil Premium funding is estimated to equate to a loss of £1.5 billion to schools.<a href="#_edn44" id="_ednref44"><sup>[44]</sup></a> However, the Department of Education has indicated it will maintain Pupil Premium levels and other related school funding next year (and possibly longer) while they consider changes to funding allocations.<a href="#_edn45" id="_ednref45"><sup>[45]</sup></a> Unless increased in line with inflation which has not happened in recent years, these rates will erode in real terms while the new formula is developed.</p>



<p class="wp-block-paragraph">Schools must use the additional funding that they get via the Pupil Premium to “accelerate disadvantaged pupils’ progress, in order to raise their attainment.”<a href="#_edn46" id="_ednref46"><sup>[46]</sup></a> So while not directly tied to individual pupils in receipt of free school meals, there is a reasonable expectation that this funding should follow the pupils through which the funding was made available. Survey evidence from the Sutton Trust found that around a third of senior leaders and classroom teachers said they were using at least some Pupil Premium funding to plug gaps elsewhere in their school’s budgets.<a href="#_edn47" id="_ednref47"><sup>[47]</sup></a> However, there is no evidence to quantify by how much other pupils were being cross-subsidised.</p>



<p class="wp-block-paragraph">The wider National Funding Formula also uses free school meals numbers as a key deprivation indicator, alongside a neighbourhood level income deprivation score. Children who receive free school meals currently attract £495 and an additional £1,060 or £1,555 at primary or secondary level respectively for FSM6.<a href="#_edn48" id="_ednref48"><sup>[48]</sup></a> Alongside the income deprivation score and with subsequent area cost adjustment, these three rates account for around 10% of schools funding and are the largest single additional needs factor determining how local authorities get to allocate to their schools. From 2027-28, National Funding Formula allocations will go direct to schools rather than going via local authorities, who have tended to weigh more heavily for current free school meals eligibility and less heavily for FSM6 in their final allocations. Again, it has been confirmed that the free school meals eligibility change will not affect the formula from next year, but no timeline or detail has been given on what will replace it as a proxy for deprivation.</p>



<p class="wp-block-paragraph">Further still, free school meal rates are used to target other programmes through Priority Education Investment Areas and Opportunity Funding. Areas in these schemes are chosen on the basis of pupil outcomes and the proportion of pupils eligible for free school meals. Schools in these local authority areas can benefit from teacher retention payments of up to £3,000 per year, funded National Professional Qualifications (NPQs) ranging from around £900 to £4,000 and funded mentor placements to improve attendance costing around £1,500 per pupil.<a href="#_edn49" id="_ednref49"><sup>[49]</sup></a> This means that in some areas, the benefit to pupils in receipt of free school meals (and their classmates) can be even greater via payments to teachers or effective subsidy to pupils via mentoring. The end of the funding system&nbsp; associated with free school meals eligibility hence has funding implications that far outweigh the simple cost of each lunch. It may take years before a new un-passported funding settlement emerges, leaving funding out of step with policy.</p>



<h4 class="wp-block-heading"><a></a><strong>Free school transport</strong></h4>



<p class="wp-block-paragraph">Children eligible for free school meals are passported an extended right to free home-to-school transport. All children are eligible for free school transport if a child’s nearest suitable school is over two miles away for five to seven year olds or three miles away between eight and 16.<a href="#_edn50" id="_ednref50"><sup>[50]</sup></a> For those in receipt of free school meals, the bar is two miles (rather than three) for those aged eight to 11. For those aged 11 to 16, free school transport for those eligible for free school meals is available if the school is two to six miles away if it is one of their nearest three suitable schools or two to 15 miles away if it is a school chosen due to a religion or belief.</p>



<p class="wp-block-paragraph">Free school transport is also provided to children with special educational needs, disabilities or mobility problems that mean they are unable to walk to school, regardless of the distance. Case law has interpreted this to include social, emotional or mental health rather than just difficulty with physical movement if it could be seen as unreasonable or unsafe for them to walk or use public transport. This threshold also does not necessarily require that they are claiming child Disability Living Allowance or have an Education, Health and Care Plan (EHCP), although these can both be used as supporting evidence. Hence, while this route to free school transport is not limited to passporting via benefits, receipt of child disability benefits can provide eligibility.</p>



<p class="wp-block-paragraph">Neither Wales nor Scotland have an equivalent UC-passported extended right for those between two and three miles away from school, despite being more rural and therefore more likely to have a higher proportion travelling longer distances to school. Instead, councils have discretion to give more weight to real world geography, safety and feasibility, rather than use an imaginary radius as the rule. However, both nations have more generous income-subsidies for children of school age which families may use to contribute to transport costs.</p>



<p class="wp-block-paragraph">The home-to-school transport bill for local authorities in England has soared in recent years, rising from just over £1 billion to £2.25 billion over the decade to 2023/24.<a href="#_edn51" id="_ednref51"><sup>[51]</sup></a> Mainstream home-to-school transport costs have risen by around £24 million since 2015/16 after accounting for the impact of inflation. The median cost per year of providing home-to-school transport is around £1,495 for mainstream transport and £8,920 for SEND transport per receiving pupil.<a href="#_edn52" id="_ednref52"><sup>[52]</sup></a> There is wide variation in how these costs affect different areas on a per capita basis across all their pupils, with spending ranging from just £2 in London boroughs to £57 in county council areas.<a href="#_edn53" id="_ednref53"><sup>[53]</sup></a></p>



<p class="wp-block-paragraph">According to a Department for Education snapshot data collection exercise from local authorities in February 2025, 7% of pupils receiving free home-to-school transport were eligible via extended rights conferred via free school meals, equating to 36,400 pupils.<a href="#_edn54" id="_ednref54"><sup>[54]</sup></a> In 2024/25, councils were allocated over £52 million for providing the extended right to free school transport.<a href="#_edn55" id="_ednref55"><sup>[55]</sup></a></p>



<p class="wp-block-paragraph">The total amount allocated has increased by almost 30% in the last four years alone. As with school funding, the Government has not yet decided on a new mechanism for assessing eligibility for the extended right to free school transport with the expansion of free school meals to all those on UC, keeping eligibility to the existing income threshold for this year at least.<a href="#_edn56" id="_ednref56"><sup>[56]</sup></a></p>



<p class="wp-block-paragraph">Unless new passporting criteria are implemented in the long term, the expansion of free school meals could add significant extra cost. By the same token, more restricted extended rights could drive more to seek SEND-related eligibility, which could increase costs even more. The original per-pupil amounts allocated for extended rights to different local authorities were based on an Association of Transport Coordinators survey a decade ago and only started being uprated from 2021/22.<a href="#_edn57" id="_ednref57"><sup>[57]</sup></a> Even small changes in eligibility or rebasing of rates could cause significant disruption in funding in some council areas depending on their geography.</p>



<p class="wp-block-paragraph">Eligibility for free home-to-school transport can legally take no account of whether the family could reasonably provide their own transport, including having one or more cars. They also cannot legally take into account whether the state is already paying for that family to have a subsidised Motability car, whether due to a parents’ disability or any child in the household.<a href="#_edn58" id="_ednref58"><sup>[58]</sup></a> 90% of Motability vehicles are leased without any adaptations for the driver or any passengers.<a href="#_edn59" id="_ednref59"><sup>[59]</sup></a></p>



<h4 class="wp-block-heading"><a></a><strong>Holiday Activities and Food Programme</strong></h4>



<p class="wp-block-paragraph">Free school meals-eligible children are also able to access free holiday clubs during the school holidays via the Holiday Activities and Food Programme (HAF).&nbsp; This programme, funded by the Department for Education, provides activities and meals at holiday clubs, administered via local authorities. Guidance from the Department for Education encourages local authorities to spend up to 15% of their funding on free or subsidised places for children who are not in receipt of benefits related to free school meals but whom the local authority believe could benefit from the HAF, such as those with low school attendance rates. Pupils in year groups covered by universal infant free school meals are covered by standard free school meals eligibility rules instead.<a href="#_edn60" id="_ednref60"><sup>[60]</sup></a>&nbsp;</p>



<p class="wp-block-paragraph">The programme was at pilot stage when the Covid-19 pandemic commenced, and during this time, it was expanded across all of England and into multiple school holidays, with some areas now providing half term schemes in addition to the longer school holidays. The expectation for the HAF is that providers operate on a 4x4x4 model &#8211; that is, that they offer places for a minimum of four hours a day, four days per week and for four weeks during the summer holidays. Across the 2023 to 2024 academic year, almost five million HAF days were provided with funding of approximately £200 million per year.<a href="#_edn61" id="_ednref61"><sup>[61]</sup></a> During the summer holidays of 2024, 624,000 children took up HAF places.<a href="#_edn62" id="_ednref62"><sup>[62]</sup></a> The Department for Education estimates that HAF helps parents to save over £300 per year.<a href="#_edn63" id="_ednref63"><sup>[63]</sup></a></p>



<p class="wp-block-paragraph">Evaluation of the early rollout of HAF found that 58% of clubs with HAF places were also open to children whose families were paying for their place, with 44% citing paid places as an additional source of funding.<a href="#_edn64" id="_ednref64"><sup>[64]</sup></a> Therefore, fee-paying families will often be further cross-subsidising government-funded places, in addition to funding the scheme through their taxes. According to the Coram Holiday Childcare Survey, holiday clubs cost parents an average of £179 per week (for a five day holiday club).<a href="#_edn65" id="_ednref65"><sup>[65]</sup></a> This puts the value of the effective subsidy to parents higher than the DfE estimate of £300 on a pro rata basis. Separately, wholly private holiday clubs have been estimated to cost 21% more than those run by councils.<a href="#_edn66" id="_ednref66"><sup>[66]</sup></a> So in practice, if families taking up HAF-funded places were looking for equivalents on the open market, they would likely pay higher fees than the equivalent HAF subsidy.</p>



<p class="wp-block-paragraph">When the HAF first became a national scheme in 2021, it was funded with £220 million.<a href="#_edn67" id="_ednref67"><sup>[67]</sup></a> However, in the most recent round of funding announced this August, only £600 million has been earmarked to last three years.<a href="#_edn68" id="_ednref68"><sup>[68]</sup></a> Almost £214 million is already expected to be allocated in 2026/27, meaning that allocations will diminish further in future years unless the total is topped-up.<a href="#_edn69" id="_ednref69"><sup>[69]</sup></a> Growing participation, high food inflation and increasing labour costs will continue to erode funding per place. Given how recently the scheme has been rolled out on a national basis, there are no long term outcomes evaluations yet.</p>



<p class="wp-block-paragraph">As with other schemes passported through free school meals, the Government has confirmed that those newly eligible once the earnings threshold is removed will not become eligible in the next school year.<a href="#_edn70" id="_ednref70"><sup>[70]</sup></a> This discrepancy will both create confusion from parents seeking to use the scheme and operational complexity for clubs and councils in verifying who is eligible. Beyond next year, funding is likely to stretch even less far over more children, which may further increase cost displacement to fee-paying families.</p>



<h4 class="wp-block-heading"><a></a><strong>Vulnerable Students Bursary</strong></h4>



<p class="wp-block-paragraph">For those beyond compulsory school age but still in non-advanced education in England, the 16-19 Bursary Fund provides cash under the Vulnerable Student Bursary to young people in care, care leavers, young parents and those with a UC claim in their own name who are financially supporting themselves or being supported through DLA or PIP. Those under the age of 18 are not usually able to claim UC at all except in the circumstances described above, instead receiving the under 25s rate of standard allowance. The 16-19 Bursary Fund also provides funds to education providers for discretionary bursaries that are usually assessed based on income, cost and need.</p>



<p class="wp-block-paragraph">Up to £1,200 is available to eligible students under the Vulnerable Students Bursary, with guidance requiring that receipts are provided to show costs or benefits in kind for at least a partial period which can then be multiplied by expected attendance. In 2024/25, awards averaging £720 each went to 23,700 students, costing just over £17 million.<a href="#_edn71" id="_ednref71"><sup>[71]</sup></a> Separately, a Special Support Loan is available to those qualifying for the housing element of UC or certain legacy benefits as part of their maintenance loan for those in higher education.<a href="#_edn72" id="_ednref72"><sup>[72]</sup></a></p>



<p class="wp-block-paragraph">The £1,200 maximum was carried over from the Education Maintenance Allowance (EMA) scheme which it replaced in 2011, but it has not been uprated since. EMA provided £10 to £30 per week on the basis of parental income for those earning under £30,000 per year (£53,000 in today’s prices).<a href="#_edn73" id="_ednref73"><sup>[73]</sup></a> Recent longitudinal analysis of EMA by the Institute for Fiscal Studies found no evidence that receiving EMA improved recipients long term outcomes, including their qualification or attendance levels in sixth form or university.<a href="#_edn74" id="_ednref74"><sup>[74]</sup></a> Worse still, EMA recipients had reduced earnings of 1% each year into their late 20s and higher rates of benefit claims. In total, for every pound spent on EMA, only 40p of benefit was derived in the long term, as shown in Figure 9 below.</p>



<p class="wp-block-paragraph">This analysis provides a rare evaluation of the long term impact of passported benefits on incentives to work that goes directly against early evaluations while it was in its pilot phase. The research indicates that the financial support diverted some young people away from part-time work and work-based training, meaning they missed out on vital skills and experience to set them up for the long term.</p>



<p class="wp-block-paragraph"><strong>Figure 9 &#8211; Effect of EMA on earnings and benefit receipt</strong></p>



<p class="wp-block-paragraph"><em>Source: Institute for Fiscal Studies<a href="#_edn75" id="_ednref75"><sup><strong><sup>[75]</sup></strong></sup></a></em></p>



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<p class="wp-block-paragraph">Analysis of the EMA further shows how inaccurate early pilot findings can be when initiating new passported benefits versus how politically difficult they are to reduce or take away even if they are found to be ineffective. Even though the maximum value of the assistance was maintained at the point of the switch from the EMA to the Bursary Fund in England, there were nationwide walkouts from pupils in schools and colleges against its removal, compounding protests against concurrent tuition fees rises. It also serves as a warning to Scotland, Wales and Northern Ireland where EMA still operates that well-intentioned passported benefits can harm the long term life chances of the very people they are meant to support.</p>



<p class="wp-block-paragraph">There are specific exceptions determining whether and how much UC is awarded as a full-time student. UC for students under 21 is already limited to those in non-advanced education who have no parental support.<a href="#_edn76" id="_ednref76"><sup>[76]</sup></a> The 16-19 Bursary Fund is available beyond 19 if the course was started before age 19. Having a separate bureaucratic process for administering the bursary to such a similar cohort is questionable, especially if it replicates some of the poor long term outcomes seen with EMA.</p>



<h4 class="wp-block-heading"><a></a><strong>Extra support childcare</strong></h4>



<p class="wp-block-paragraph">As part of the Government’s childcare hours offers in England, there is an additional 15 hours for parents of two year olds in receipt of UC who have earned income of less than £15,400.<a href="#_edn77" id="_ednref77"><sup>[77]</sup></a> This therefore includes parents who are not working while using the offer. It was recently renamed to the “two year olds receiving support” offer rather than referring to them as “disadvantaged”. It is also available to other two year olds without an income cap if they are in care, have an EHCP or receiving Disability Living Allowance.</p>



<p class="wp-block-paragraph">This scheme can be used in addition to other childcare offers depending on whether the parents also meet their separate eligibility requirements. This includes being able to claim back 85% of childcare costs through the UC childcare element, up to a cap. As with all hours-based offers, the 15 hours per week is a term time only based offer, so does not equate to 15 hours per week across the whole year, but it does not have to be used exclusively during the school term.</p>



<p class="wp-block-paragraph">In 2025, there were just under 93,000 families on UC or legacy benefits receiving the additional support hours for two year olds.<a href="#_edn78" id="_ednref78"><sup>[78]</sup></a> Just under half of those pupils also attracted the Early Years Pupil Premium, which means that the childcare provider is paid a higher rate for the free hours used.</p>



<p class="wp-block-paragraph">Responding to pressure from the sector to increase the rates paid for different age groups, the Government increased the core funding rate for two year olds by over a third.<a href="#_edn79" id="_ednref79"><sup>[79]</sup></a> This gives an average subsidy of just under £6,000 per year per pupil.</p>



<p class="wp-block-paragraph">Take-up of the offer is around 65% of eligible families, which is lower than the proportions for other childcare hours offers. A study by Nesta in 2023 found that attendance rates among those taking up a place were also six percentage points lower than for their fee-paying peers.<a href="#_edn80" id="_ednref80"><sup>[80]</sup></a>&nbsp; They were also twice as likely to have very low attendance, with almost a quarter attending for less than 70% of their scheduled hours.<a href="#_edn81" id="_ednref81"><sup>[81]</sup></a></p>



<h3 class="wp-block-heading"><a></a>Health</h3>



<h4 class="wp-block-heading"><a></a><strong>NHS Help with Health Costs</strong></h4>



<p class="wp-block-paragraph">There are several different routes to eligibility for free NHS prescriptions, dentistry and other medical costs. These include receipt of certain benefits, medical conditions, age, pregnancy or maternity, stage of education, and veteranship. There are several passported benefit routes. For low-income working-age adults, the two main ways to qualify for help with health costs are through an automatic exemption from benefit status if earning below certain thresholds, or the separate NHS Low Income Scheme (HC2/HC3). UC claimants with earned income under £435 per week in their most recent assessment period, or £935 if they are in receipt of the child element or health element, are passported. These are roughly equivalent to a £6,700 or £15,500 gross annual salary, so only UC claimants working less than full time on the minimum wage typically qualify for help with health costs via this route, even at the higher threshold.</p>



<p class="wp-block-paragraph">The income threshold has a direct impact on work incentives, with only 32% of single working households on UC having consistent earnings below the £435 threshold. Almost 55% of households on UC will lose passported eligibility for help with health costs at least once a year because their earnings go above the £435 threshold, making them liable for a £100 fine if they falsely claim.<a href="#_edn82" id="_ednref82"><sup>[82]</sup></a> Similarly, but less acutely, around 66% of working couples have consistent earnings below the £935 threshold, with 34% losing eligibility at least once a year due to their earnings going above the threshold in at least one assessment period.<a href="#_edn83" id="_ednref83"><sup>[83]</sup></a></p>



<p class="wp-block-paragraph">Separate to passported eligibility with income thresholds, it is possible for working age adults to get free prescriptions and other medical items if they meet an income assessment and have limited savings. They can apply for an HC2 or HC3 certificate through the NHS Low Income Scheme to have their prescriptions full or partially covered. An HC2 certificate is available to anyone who has savings below £16,000, or below £23,250 if they live permanently in a care home. An income assessment is made to check whether it is less than that household’s living requirements, up to half the cost of a prescription in England, which is currently £9.90. Those who do not meet the full threshold can get partial help under an HC3 certificate.</p>



<p class="wp-block-paragraph">There will be UC claimants above the income threshold or with variable earnings who use the Low Income Scheme rather than the automatic passport to get help with health costs, but this is not possible to quantify. NHS Business Services Authority (NHSBSA) do not publish a formal list of thresholds so it can be difficult for applicants to check how much support they will likely receive prior to applying to the NHS Low Income Scheme. However, unlike the UC exemption, if successful, HC2 and HC3 certificates last for a year, whereas the UC exemption only applies if they are under the income threshold in their last monthly assessment period. The National Audit Office raised concern that this can be particularly confusing for UC claimants with variable earnings whose eligibility may vary from month to month.<a href="#_edn84" id="_ednref84"><sup>[84]</sup></a></p>



<p class="wp-block-paragraph">In 2024/25, 154,000 HC2 certificates were issued and 87,900 HC3 certificates were issued under the NHS Low Income Scheme.<a href="#_edn85" id="_ednref85"><sup>[85]</sup></a> Over a third of these HC2 certificates were issued to those aged 15-19 or over 60, which are likely to be for items other than free prescriptions given that those cohorts are likely to qualify by age.<a href="#_edn86" id="_ednref86"><sup>[86]</sup></a> There is no published breakdown of how much NHSBSA spends just on administering prescriptions or other medical exemptions and discounts. An investigation by the National Audit Office estimated that between 2014/15 and 2018/19, there was £246 million in outstanding debt to the government through unpaid penalty charge notices for invalid exemption claims, with only £133 million recovered over the same period.<a href="#_edn87" id="_ednref87"><sup>[87]</sup></a></p>



<p class="wp-block-paragraph">The interaction between UC and NHS exemptions is therefore especially complex. The UC route is automatic for those with low or no earnings, but it is assessed on the most recent monthly assessment period and can switch off after a single month of higher earnings. The Low Income Scheme is more stable, but requires a separate application to determine whether someone is reasonably able to pay after accounting for their other living costs. For the purposes of the costs analysis, only those going via the pure passported route are counted.</p>



<h4 class="wp-block-heading"><a></a><strong>Free prescriptions</strong></h4>



<p class="wp-block-paragraph">Most prescriptions dispensed from community pharmacies in England are exempt from the £9.90 charge. In spending terms, 96% of the total cost of prescribed items are exempted.<a href="#_edn88" id="_ednref88"><sup>[88]</sup></a> That is £10.7 billion exempted versus less than £500 million charged. Hence, prescription charges are really the exception, not the rule. Around 6% of prescribed items are marked as exempted on prescription forms but paid for separately via pre-payment certificates, which offer a fixed rate for three or twelve months. This means those on a 12 month pre-payment certificate pay £114.50 for the year regardless of the number of items prescribed, rather than the estimated average of £267.79 per patient for those prescribed items.<a href="#_edn89" id="_ednref89"><sup>[89]</sup></a></p>



<p class="wp-block-paragraph">In 2024/25, just under 123 million prescription items were picked up under a UC exemption, costing £947 million.<a href="#_edn90" id="_ednref90"><sup>[90]</sup></a> When factoring in those on legacy benefits too, this rises to £1.2 billion. There is no breakdown of the average number of prescribed items per person for the UC exemption categories, but the average number of prescribed items per person for those with a legacy NHS Tax Credit Exemption Certificate is 14.<a href="#_edn91" id="_ednref91"><sup>[91]</sup></a> Assuming the same number of prescribed items per person under UC, this would make claimants exempt from approximately £140 of prescriptions charges per year. Prescriptions have been free to everyone in Wales and Scotland from 2007 and 2011 respectively.</p>



<p class="wp-block-paragraph">There is some indication that prescription charges may be preventing those on low incomes who may be just outside eligibility for income-based prescription charge exemptions from collecting their prescriptions. Analysis by the Pharmaceutical Journal shows that, by decile, areas with the second highest proportion of people on income-related support are not being dispensed items they are prescribed.<a href="#_edn92" id="_ednref92"><sup>[92]</sup></a> This indicates that those likely to be in UC but have higher incomes above the threshold are choosing not to pick up their prescriptions due to the cost of paying. This has changed in recent years since charges ticked above £9, meaning that items not dispensed no longer stack consecutively by decile.</p>



<p class="wp-block-paragraph"><strong>Figure 10 &#8211; Number of items marked as &#8216;not dispensed&#8217; from community pharmacies in each income deprivation decile in England</strong></p>



<p class="wp-block-paragraph"><em>Source: The Pharmaceutical Journal<a href="#_edn93" id="_ednref93"><sup><strong><sup>[93]</sup></strong></sup></a></em></p>



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<h4 class="wp-block-heading"><a></a><strong>Free dentistry</strong></h4>



<p class="wp-block-paragraph">In addition to prescription costs, UC claimants are eligible for free NHS dentistry on the same basis as free prescriptions or an HC2 certificate. Free and discounted dentistry carries a much higher subsidy than prescription charge exemptions. A “course of treatment” is the NHS billing unit, with patients charged at Band 1–3 rates (£26.80 for Band 1 up to £319.10 for Band 3). Dentists are paid via local contracts using Units of Dental Activity (UDAs), typically around £25–£35 per UDA, and a course of treatment can attract up to 12 UDAs, with the balance of cost met through public funding. Non-exempt NHS patients pay £26.80 for Band 1 treatment, up to £319.10 for Band 3. This is topped up by the taxpayer by more than double the price for each Band.</p>



<p class="wp-block-paragraph">In total, those exempt via UC or legacy benefits received 3.7 million courses of dental treatment in 2024/25.<a href="#_edn94" id="_ednref94"><sup>[94]</sup></a> In total, this cost £302 million, averaging £81 per course of treatment. Again, there will likely be additional UC claimants claiming free dental treatment via an HC2 certificate due to the income thresholds, but this is hard to quantify.</p>



<h4 class="wp-block-heading"><a></a><strong>Help with other health costs</strong></h4>



<p class="wp-block-paragraph">On the same basis as free prescriptions and dentistry, it is possible to claim back other healthcare costs as a UC claimant or an HC2 certificate holder. These include free or discounted sight tests, glasses, contact lenses, wigs, certain travel costs and other medical items. Applying for these involve an array of multi-page paper forms in addition to any HC2 or HC3 certificate application or with manual sign off from the Jobcentre Plus to verify claimant status before going to the NHS BSA. The Help with Health Costs schemes (including prescription and dental exemptions) are so complex even its accompanying plain English guide for patients is 37 pages long of dense text.<a href="#_edn95" id="_ednref95"><sup>[95]</sup></a></p>



<p class="wp-block-paragraph">For example, a review of the Help with Travel Costs Scheme, which reimburses transport costs for those referred for specialist NHS treatment or tests, estimated in 2021 that it cost £5-10 million per year, with 500-700,000 claims.<a href="#_edn96" id="_ednref96"><sup>[96]</sup></a>&nbsp; It highlighted the significant variation across the country in how costs could be claimed back, with some hospitals having cashier desks that could pay on the spot if claimants came with all the relevant documents, but these often had limited opening hours. Claims by post could take 90 days to process, sometimes just for a few pounds of reimbursement. As there is so little published information on take-up or effectiveness of these schemes specifically for those eligible via claimant status, they are not possible to cost in this analysis.</p>



<p class="wp-block-paragraph">There is no published data on how many claims are made for this assortment of other health-related items, what proportion have their full costs remitted or how many are eligible via the passported route versus a HC2 or HC3 certificate. There are some other isolated data points available, like the total number of vouchers issued for NHS ophthalmic services like sight tests and glasses, but insufficient breakdowns to calculate average or total costs with any certainty.<a href="#_edn97" id="_ednref97"><sup>[97]</sup></a> These other Help with Health Costs items are therefore excluded from the total costs analysis.</p>



<h4 class="wp-block-heading"><a></a><strong>Sure Start Maternity Grant</strong></h4>



<p class="wp-block-paragraph">The Sure Start Maternity Grant is a one-off payment of £500 for the first child or for those expecting a multiple birth with existing children.<a href="#_edn98" id="_ednref98"><sup>[98]</sup></a> It is available in England and Wales to those on UC and in certain other limited circumstances. It can be claimed any time from 11 weeks before the due date until six months after the baby is born. It is still administered via a paper form, including evidence of pregnancy or childbirth from a health professional. Paper-based claiming and third-party evidence requirements create avoidable friction and are likely to depress take-up among eligible households, while increasing administrative cost relative to the size of the award.</p>



<p class="wp-block-paragraph">There were 47,200 grants issued in England and Wales in 2023/24 (the last year for which information is available) at a cost of £23.6 million.<a href="#_edn99" id="_ednref99"><sup>[99]</sup></a> There is no breakdown to show how many people receive the grant for the complex set of criteria listed outside of UC, such as having refugee status or humanitarian protection and claiming for a pregnant teenage family member, though these numbers are likely to be small in comparison to those eligible via UC.</p>



<p class="wp-block-paragraph">Once part of the much wider Sure Start programme, there has been very little evaluation of the effectiveness of the grant since it was restricted to the first child in 2011. The value of the award has remained frozen since 2002 as one of the Social Fund policies that remained after the Welfare Reform Act 2013.<a href="#_edn100" id="_ednref100"><sup>[100]</sup></a> Its predecessor scheme &#8211; the Health in Pregnancy grant &#8211; gave women across the UK a £190 cash sum at their 25th week of pregnancy if they had been in contact with a doctor or midwife. In real terms, this means the grant now covers a much smaller share of the typical upfront costs associated with a new baby than it did when introduced. A study of its impact in Scotland found no evidence that it changed birthweight, reduced premature birth or improved maternal outcomes.<a href="#_edn101" id="_ednref101"><sup>[101]</sup></a> It was discontinued in 2011 after just two years.</p>



<p class="wp-block-paragraph">In Scotland, the more generous Best Start Grant Pregnancy and Baby Payment was introduced after the Sure Start Maternity Grant was restricted to the first child in 2011, which became part of a suite of Five Family Payments at different early years stages. It provides £767.50 for a first child and £383.75 for subsequent children available from 24 weeks of pregnancy.<a href="#_edn102" id="_ednref102"><sup>[102]</sup></a> While there has been some limited evaluation of the collective Five Family Payments in Scotland, there is no consideration of alternative mechanisms for delivering support or their long term impact on outcomes.<a href="#_edn103" id="_ednref103"><sup>[103]</sup></a></p>



<p class="wp-block-paragraph">Separate from the Sure Start Maternity Grant, all expectant mothers who have their pregnancy confirmed by a healthcare professional can also get a maternity exemption certificate, which provides them with free prescriptions and dental treatment while they are pregnant and for 12 months after they give birth.</p>



<h4 class="wp-block-heading"><a></a><strong>Healthy Start</strong></h4>



<p class="wp-block-paragraph">Healthy Start pre-paid payment cards are available for UC claimants in England, Wales and Northern Ireland with earned income below £408 per month (equivalent to £4,896 per year) from 10 weeks of pregnancy and up to when a child is aged four.<a href="#_edn104" id="_ednref104"><sup>[104]</sup></a> This is a lower income ceiling than the £435 for free prescriptions, free dentistry and other medical items, originally linked to Child Tax Credit thresholds in the legacy benefit system. In May 2021, the scheme was extended on a non-statutory basis to British children in families with No Recourse to Public Funds using only the earned income threshold. The Government is currently considering consultation responses extending this to non-British children too.<a href="#_edn105" id="_ednref105"><sup>[105]</sup></a></p>



<p class="wp-block-paragraph">The cards are loaded with £4.25 per week from 10 weeks of pregnancy and for children between the ages of 1 and four.<a href="#_edn106" id="_ednref106"><sup>[106]</sup></a> While the child is under one, the rate is doubled to £8.50. This is equivalent to £221 and £442 per year respectively and unspent balances are allowed to accumulate. In addition, recipients can get free Healthy Start vitamins from certain NHS or local authority providers, such as health visitors, pharmacies and Family Hubs. In Scotland, the Best Start Foods payment, as part of the Five Family Payments, pays the equivalent of £5.40 per week during pregnancy and for each child between one and three years old, and £10.80 during the child’s first year.<a href="#_edn107" id="_ednref107"><sup>[107]</sup></a></p>



<p class="wp-block-paragraph">Healthy Start cards are intended to be spent on cow’s milk, infant formula based on cow’s milk, fruit, vegetables and pulses. However, they are simply pre-paid Mastercards that can be tapped like any other card, with the only restrictions being whether the retailer has an accepted Merchant Category Code for the type of shop. Accepted shop types cover supermarkets, convenience stores, pharmacies, markets, petrol stations and more. Guidance to retailers is clear that they are not required to check what someone purchases and that this is entirely the responsibility of the cardholder.<a href="#_edn108" id="_ednref108"><sup>[108]</sup></a> Online forums discuss being able to purchase alcohol, vapes and even Playstations when cards have accumulated sufficient funds.<a href="#_edn109" id="_ednref109"><sup>[109]</sup></a> This is plainly not the intention of the policy.</p>



<p class="wp-block-paragraph">The scheme currently costs £86 million per year.<a href="#_edn110" id="_ednref110"><sup>[110]</sup></a> In December 2025, there were 354,720 claimants on the Healthy Start scheme in England, Wales and Northern Ireland.<a href="#_edn111" id="_ednref111"><sup>[111]</sup></a> Due to an issue with the data since January 2023, there has been an error in the uptake statistics published, meaning there are no current figures for the proportion of those eligible who are taking up the scheme.<a href="#_edn112" id="_ednref112"><sup>[112]</sup></a> In the last month for which reliable data is available, uptake was 62%, which was well below the Government’s 75% target.<a href="#_edn113" id="_ednref113"><sup>[113]</sup></a></p>



<p class="wp-block-paragraph">Evaluation of Healthy Start by the National Institute for Health and Care Research (NIHR) using individual data-linking methods found that take up was low during pregnancy, with an inconclusive impact on birth outcomes among those on the scheme.<a href="#_edn114" id="_ednref114"><sup>[114]</sup></a> Likewise, there was little difference in vitamin intake for those on the scheme when compared with those eligible, but not claiming, or those just outside eligibility. It should be noted that while the study was published in 2023, the fieldwork largely took place before Healthy Start was moved from a paper voucher scheme to a pre-paid card scheme and while the value of the vouchers were £3.10 and £6.20 for the relevant cohorts.</p>



<p class="wp-block-paragraph">Quite apart from obvious avenues for abuse and lack of tangible health outcome improvement, the earnings threshold has a damaging interaction with incentives to work: 56% of working households on UC with children have consistent earnings below the £408 eligibility threshold.<a href="#_edn115" id="_ednref115"><sup>[115]</sup></a> However, 43% of working households will lose eligibility for Healthy Start at least once a year because their earnings go above the threshold in at least one assessment period. While there is an eight week grace period in which eligibility continues after earnings rise above the threshold, those with sustained or seasonal fluctuations in their income would have to reapply each time.<a href="#_edn116" id="_ednref116"><sup>[116]</sup></a></p>



<h3 class="wp-block-heading"><a></a>Energy</h3>



<h4 class="wp-block-heading"><a></a><strong>Warm Home Discount</strong></h4>



<p class="wp-block-paragraph">The Warm Home Discount is a mandatory scheme that requires energy suppliers in Great Britain to provide an annual, automatic rebate of £150 to certain households. In England and Wales, eligible households are currently split into two groups.<a href="#_edn117" id="_ednref117"><sup>[117]</sup></a> Core Group 1 consists of households on the Pension Credit Guaranteed Element who are automatically eligible. In 2024/25, Core Group 2 predominately consisted of households in receipt of UC who are also living in a property with a high energy costs score. For 2025/26, the high energy costs score will no longer apply, so all households on UC will be eligible for the rebate from energy suppliers with more than 1,000 customers.<a href="#_edn118" id="_ednref118"><sup>[118]</sup></a></p>



<p class="wp-block-paragraph">The changes this winter move away from the previous energy cost scoring system which was determined by Valuation Office data on property type, property age and floor area. No regard was given to Energy Performance Certificate (EPC) ratings, which looks at factors like the building fabric and heating system. This meant that older houses with significant heat retention retrofitting would still qualify, even though they may have low energy costs. Suppliers are also able to spend part of their Warm Home Discount obligation on “Industry Initiatives&#8221; outside of the rebates, such as debt assistance, energy efficiency advice or devices and helping claimants access other passported benefits.</p>



<p class="wp-block-paragraph">Scotland still uses the pre-2022 Border Group criteria instead of Core Group 2, which assesses households on certain benefits including UC according to whether they are deemed to be in or at risk of “fuel poverty”. The assessment of fuel poverty risk is based on the characteristics of the household members rather than the physical house, including whether there are children under the age of five or disabled people living there. Scottish households still have to apply to their supplier to receive the rebate rather than this being automatic.</p>



<p class="wp-block-paragraph">While the Warm Home Discount is a statutory scheme, unlike most other passported benefits, it does not involve direct government subsidy. Instead, energy suppliers fund the scheme directly by recouping the cost from other bill payers. In 2024/25, £483 million was spent in England, Wales and Scotland.<a href="#_edn119" id="_ednref119"><sup>[119]</sup></a> £340 million of the spend in England and Wales went to almost 2.2 million Core Group 2 households on working age benefits.<a href="#_edn120" id="_ednref120"><sup>[120]</sup></a>&nbsp;</p>



<p class="wp-block-paragraph">In the Government’s impact assessment for removing the high cost to heat threshold estimates the total levy will increase costs to energy suppliers by around £400 million to £1 billion.<a href="#_edn121" id="_ednref121"><sup>[121]</sup></a> This was estimated to pass on a cost of £37 to the average dual-fuel billpayer, up from £22 before the change.<a href="#_edn122" id="_ednref122"><sup>[122]</sup></a> This indicates that the cost of UC claimants in receipt of the Warm Home Discount will top £800 million when combining the proportion of existing claimants in Core Group 2 with the estimated cost increase.</p>



<p class="wp-block-paragraph">Breaking the link to households that are more likely to face higher energy costs, means it is now effectively just an income top-up, paid for by everyone else in higher bills. It is difficult to justify a system in which households who receive no support are required to pay higher energy bills to fund a blanket rebate for everyone who receives benefits, regardless of those households’ actual energy needs. Involving each energy supplier in individually delivering £1 billion of blanket welfare in this way is a hugely convoluted way of effectively taxing suppliers. Meanwhile, the Industry Initiates part of the scheme, which helps households to permanently reduce their bills through measures like energy efficiency improvements, boiler replacements and debt write-offs, is not planned to be expanded.</p>



<h4 class="wp-block-heading"><a></a><strong>Energy Company Obligation</strong></h4>



<p class="wp-block-paragraph">Separate from the Industry Initiatives Scheme under the Warm Home Discount, there has been an additional scheme called the Energy Company Obligation (ECO) focused on home heating cost reduction for those in receipt of certain benefits. It is currently in its final phase due to end in December 2026 and is open to those on UC, Pension Credit, Child Benefit (up to an income cap based on the number of adults and children) and those not on benefits in some other circumstances. For home owners, the house’s EPC rating must be below D to be eligible or below E for private and social renters.</p>



<p class="wp-block-paragraph">Energy efficiency measures include various types of insulation, heat pumps and solar panels, with gas boiler upgrades being taken out of the scheme in its latest phase. Like the Warm Home Discount, it is funded directly by suppliers, requiring them to achieve a total of £224.3 million in annual bill savings for domestic premises.<a href="#_edn123" id="_ednref123"><sup>[123]</sup></a> The average cost of delivery under the fourth phase of ECO is around £22.36 per £1 annual bill savings.<a href="#_edn124" id="_ednref124"><sup>[124]</sup></a></p>



<p class="wp-block-paragraph">The scheme has been widely criticised for a range of issues, including suspected fraud, poor quality installations and poor targeting, with a higher than expected number of claims from homeowners.<a href="#_edn125" id="_ednref125"><sup>[125]</sup></a> It has recently been extended from the expected close date of March 2026 to December 2026 as the Government had not yet published its Warm Homes Plan in time.<a href="#_edn126" id="_ednref126"><sup>[126]</sup></a> This has now been published, but with no information about how low-income households will qualify.<a href="#_edn127" id="_ednref127"><sup>[127]</sup></a> Further detail is expected in the spring. In the latest year of the Energy Company Obligation up to September 2025, installations across 71,000 households have cost £1.15 billion.<a href="#_edn128" id="_ednref128"><sup>[128]</sup></a> Not counting the administrative cost of the scheme, this means an average direct subsidy per household of almost £20,000 in installed measures.</p>



<p class="wp-block-paragraph">A survey of recipients in the third wave of the Energy Company Obligation showed that 16% were in receipt of UC, plus a further 10% on at least one income-based working-age legacy benefit.<a href="#_edn129" id="_ednref129"><sup>[129]</sup></a> An income eligibility cap of £31,000 was introduced for the final wave, but other flexibilities were introduced that could be used to bypass the cap. Using wave 3 claimant proportions as a proxy for the proportion of UC or legacy working age claimants in the latest year of the scheme too, the scheme is estimated to spend £366 million on UC or legacy claimants.<a href="#_edn130" id="_ednref130"><sup>[130]</sup></a></p>



<p class="wp-block-paragraph">Separately, the Warm Homes Social Housing Fund (previously the Social Homes Decarbonisation Fund) provides energy efficiency-related retrofitting to social homes, but is not passported via claimants themselves but goes to their landlords. In its current phase from 2025-2028, it has so far allocated £1.2 billion to almost 140 social landlords.<a href="#_edn131" id="_ednref131"><sup>[131]</sup></a> This will fold into the Warm Homes Plan too, but detail on who will be eligible has not been released on this element either yet.<a href="#_edn132" id="_ednref132"><sup>[132]</sup></a></p>



<h4 class="wp-block-heading"><a></a><strong>Cold Weather Payments</strong></h4>



<p class="wp-block-paragraph">If the average temperature falls below or is forecast to be below 0°C for seven consecutive days in a postcode district, eligible households are granted £25 retrospectively through the Cold Weather Payment scheme. Households on UC, and those receiving legacy benefits, Support for Mortgage Interest or Pension Credit, are eligible for these payments under certain conditions. Households must have either a disabled child, or be claiming UC for a disabled adult or a child under five to qualify.</p>



<p class="wp-block-paragraph">Like the Sure Start Maternity Grant, Cold Weather Payments are another hangover from the Social Fund that ran alongside the legacy benefit system. It is explicit in barring those on UC who are working except if they have a disabled child. The amount of payment may be modest and unpredictable so the actual impact on the incentive to work is unlikely to be significant. Nevertheless, it still adds to the list of bonuses that some claimants get, without any consideration of their property type or whether they have taken any steps to protect their home from the cold.</p>



<p class="wp-block-paragraph">In the winter of 2024/25, there were 33 cold weather triggers, with just over a million payments made to those on working age benefits.<a href="#_edn133" id="_ednref133"><sup>[133]</sup></a> Due to payments triggers being entirely weather dependent, the cost of the scheme varies wildly from year to year. For the last two milder winters, it has cost £30-35 million, compared to £140 million in the winter of 2022/23.<a href="#_edn134" id="_ednref134"><sup>[134]</sup></a> Averaging across these three years, that gives an annual cost of £68 million. 74% of recipients qualified via UC, therefore costing just over £50 million per year on average for each of the last three years.<a href="#_edn135" id="_ednref135"><sup>[135]</sup></a></p>



<h3 class="wp-block-heading"><a></a>Water</h3>



<h4 class="wp-block-heading"><a></a><strong>WaterSure</strong></h4>



<p class="wp-block-paragraph">WaterSure is a scheme which reduces water and sewerage bills for metered households on UC or other means-tested benefits if they have a medical need for high water use or three or more dependent children. This final eligibility has sat particularly absurdly alongside the UC two-child limit, which will now be abolished in April 2026. WaterSure usually takes the form of a percentage cap or a set capped value, as set by each water provider.</p>



<p class="wp-block-paragraph">Since 2015, it has been a statutory duty for water companies in England to provide a WaterSure scheme, with both major Welsh water suppliers also running WaterSure schemes on a voluntary basis.<a href="#_edn136" id="_ednref136"><sup>[136]</sup></a> In Scotland, where Scottish Water is nationalised, there is no WaterSure-style scheme but instead a bill reduction is applied at the same proportion as any council tax reduction the household may be eligible for.</p>



<p class="wp-block-paragraph">According to the Consumer Council for Water, 260,800 households received an average bill reduction of £325 in 2024/25.<a href="#_edn137" id="_ednref137"><sup>[137]</sup></a> In the same year, it cost suppliers almost £85 million, over double the amount provided in 2017/18.<a href="#_edn138" id="_ednref138"><sup>[138]</sup></a> Customers pay £2-£3 per year extra on their water bills to fund the scheme.<a href="#_edn139" id="_ednref139"><sup>[139]</sup></a> WaterSure is only available to metered customers, meaning that some of those living in flats with a shared supply who may otherwise be eligible cannot be capped. Recent estimates from the Consumer Council for Water suggest that 2 million households are estimated to be in “water poverty” – that is, spending 5% or more of their disposable income on water bills.<a href="#_edn140" id="_ednref140"><sup>[140]</sup></a> SMF analysis of the Living Costs and Food Survey puts this number at around 1.75 million.<a href="#_edn141" id="_ednref141"><sup>[141]</sup></a></p>



<p class="wp-block-paragraph">A series of conditions of the skin and bowel typically provide qualification for WaterSure, plus those with renal failure requiring at-home dialysis if not already reimbursed by the NHS.<a href="#_edn142" id="_ednref142"><sup>[142]</sup></a> Reimbursement for one type of at-home dialysis is outlined in the NHS England service specification, although there is no nationally consistent practice for how this is delivered and no auditing of renal unit schemes. England is the only nation in the UK without an nationally consistent health reimbursement scheme across different types of at home dialysis.<a href="#_edn143" id="_ednref143"><sup>[143]</sup></a> This can result in gaps of weeks or sometimes months where a patient starting home dialysis has not had an assessment completed by the hospital and therefore are able to apply to WaterSure, which then lasts for the whole year.</p>



<p class="wp-block-paragraph">The Government is currently processing responses to the consultation on reforming the WaterSure scheme.<a href="#_edn144" id="_ednref144"><sup>[144]</sup></a> Proposals include extending the list of qualifying benefits to include non-means tested disability benefits for those claiming through a qualifying medical condition (possibly up to an income cap). Together the measures could add significant cost and complexity to the scheme, which is hard to quantify before decisions within the options have been made.</p>



<p class="wp-block-paragraph">There is no breakdown of the proportion of those claiming WaterSure that are above state pension age claiming via Pension Credit. The Consumer Council for Water states that roughly two thirds of WaterSure claims qualify via the medical route.<a href="#_edn145" id="_ednref145"><sup>[145]</sup></a> Given that the number of claiming households above state pension age with three or more dependent children is likely to be negligible, it is reasonably safe to assume that at least a third of spending on WaterSure is going to those qualifying via UC or legacy working age benefits.</p>



<h4 class="wp-block-heading"><a></a><strong>Water social tariffs</strong></h4>



<p class="wp-block-paragraph">Water social tariffs were first introduced in 2009, requiring every water company in the UK to provide a discounted tariff for vulnerable customers, but with broad discretion over how this is delivered. As with WaterSure, eligible customers usually have to apply to their provider rather than receipt being automatic and some exclude those already receiving assistance from WaterSure. South West Water, United Utilities, Dwr Cymru and Affinity Water use benefit receipt as a passport to a water social tariff alongside other criteria.<a href="#_edn146" id="_ednref146"><sup>[146]</sup></a> Assistance is broadly either a proportional bill reduction ranging from 15% to 90%, or a bill cap varying from £66 to £450, depending on the water company.<a href="#_edn147" id="_ednref147"><sup>[147]</sup></a> In 2024/25, almost 2 million customers had their bills reduced by an average of £190.<a href="#_edn148" id="_ednref148"><sup>[148]</sup></a> This cost suppliers a total of £374 million in the same year and is projected to rise to £640 million a year by 2030.<a href="#_edn149" id="_ednref149"><sup>[149]</sup></a></p>



<p class="wp-block-paragraph"><strong>Figure 11 &#8211; Average social tariff savings by type of social tariff</strong></p>



<p class="wp-block-paragraph"><em>Source: Onward analysis of Ofwat and Social Market Foundation<a href="#_edn150" id="_ednref150"><sup><strong><sup>[150]</sup></strong></sup></a></em></p>



<div class="flourish-embed flourish-chart" data-src="visualisation/27207234"><script src="https://public.flourish.studio/resources/embed.js"></script><noscript><img decoding="async" src="https://public.flourish.studio/visualisation/27207234/thumbnail" width="100%" alt="chart visualization" /></noscript></div>



<p class="wp-block-paragraph">Due to the differing structure of social tariff schemes across suppliers and their regional monopolies, there is a postcode lottery as to how much support is provided and how much cross-subsidy other customers pay. Ofwat estimates that by 2030, Thames Water customers will be subsidising social tariffs by an average of £55 per customer, compared to just £13 per customer for United Utilities (the lowest subsidy amount among water and sewerage companies rather than water only companies).<a href="#_edn151" id="_ednref151"><sup>[151]</sup></a> However, United Utilities is also the company with the greatest projected increase in the proportion of customers on a social tariff in the next five years, increasing by 10%, due to their tariff being tied to benefit receipt and applied without customers having to individually apply.<a href="#_edn152" id="_ednref152"><sup>[152]</sup></a></p>



<p class="wp-block-paragraph">Limiting just to the providers that tie eligibility directly to UC, legacy or Pension Credit receipt, rather than a separate income and expenditure or bills-to-income assessment, water social tariffs provide £78 million in financial assistance reaching approximately 300,000 properties in 2024/25.<a href="#_edn153" id="_ednref153"><sup>[153]</sup></a> The average bill reduction that households from these providers received last year was £244.<a href="#_edn154" id="_ednref154"><sup>[154]</sup></a> There are no published statistics on what proportion of those in receipt of these social tariffs are on working age benefits versus pensioner benefits.&nbsp;</p>



<p class="wp-block-paragraph">There have been widespread calls from charities to move to a single social tariff, including calls for an auto-enrolment scheme on a bills-to-income ratio. The Social Market Foundation modelled three different ways in which this could operate, costing between £460 and £790 million, or between £18.45 to £31.30 per customer.<a href="#_edn155" id="_ednref155"><sup>[155]</sup></a> Bills-to-income schemes would all require significant changes to data sharing with water companies and may require changes to the Digital Economy Act.<a href="#_edn156" id="_ednref156"><sup>[156]</sup></a>&nbsp;</p>



<p class="wp-block-paragraph">However, any change of this nature, especially an increase in the amount that customers are cross-subsidising social tariffs, is likely to be unpopular against a backdrop of rising water bills. In recent research by the Consumer Council for Water, over half (52%) of respondents said that it was unacceptable for social tariffs to be funded through other customers’ water and sewerage bills, with less than a third (32%) responding that it was acceptable.<a href="#_edn157" id="_ednref157"><sup>[157]</sup></a></p>



<p class="wp-block-paragraph">The cost displacement challenge will become all the more acute given the need to invest in water infrastructure. In the 2025-2030 price review period, water companies are set to spend £104 billion to reduce leakage of both fresh and wastewater, and improve overall water supply.<a href="#_edn158" id="_ednref158"><sup>[158]</sup></a> This amounts to a £31 average bill rise for customers before inflation. Around 40% of customers thought that water bills would be difficult to afford for them after they were shown their company’s proposed bill increases for 2025-26 to 2029-30, based on Ofwat’s draft determinations.<a href="#_edn159" id="_ednref159"><sup>[159]</sup></a></p>



<h3 class="wp-block-heading">Telecoms</h3>



<h4 class="wp-block-heading"><a></a><strong>Broadband social tariffs</strong></h4>



<p class="wp-block-paragraph">Broadband social tariffs are a more recent development than other utilities. BT first offered a social tariff in 2011, before the Government more widely encouraged their provision on a voluntary basis in 2022. All major providers now offer a form of discounted social tariff rate, usually available to at least those on UC and Pension Credit.<a href="#_edn160" id="_ednref160"><sup>[160]</sup></a> There are no mandatory price, speed or availability rules, but most packages are above an average speed of 30 megabits per second considered “superfast”.<a href="#_edn161" id="_ednref161"><sup>[161]</sup></a> By June 2024, social tariff uptake had reached 506,000 customers, up a third on the previous year.<a href="#_edn162" id="_ednref162"><sup>[162]</sup></a> Some telecoms companies also now offer social tariffs on 5G mobile phone contracts too, though SIM-only deals from smaller providers are likely to be cheaper.</p>



<p class="wp-block-paragraph">Available broadband or 5G social tariffs currently range from £10 to £24 per month, with an average annual subsidy of £200 for those notionally available across all of England and Wales (although some may have local limitations).<a href="#_edn163" id="_ednref163"><sup>[163]</sup></a> This is roughly half the price of the annual yearly spend on fixed broadband with the same provider on the closest commercial tariff.<a href="#_edn164" id="_ednref164"><sup>[164]</sup></a> Ofcom does not publish figures on how much providers spend in total on broadband social tariffs or how much cost they pass on to other consumers. There is also no breakdown of take-up by passporting benefit, but Ofcom uses UC as a proxy for all eligibility in their yearly pricing trends analysis.<a href="#_edn165" id="_ednref165"><sup>[165]</sup></a></p>



<p class="wp-block-paragraph">Despite the increases in those claiming, Ofcom indicates that just 9.6% of those eligible were claiming a social tariff in 2024.<a href="#_edn166" id="_ednref166"><sup>[166]</sup></a> According to analysis by Policy in Practice, broadband social tariffs were the most under-claimed passported benefit, with over 7.5 million eligible claimants estimated to be missing out on broadband social tariffs, with a total value of £1.5 billion.<a href="#_edn167" id="_ednref167"><sup>[167]</sup></a> Given the relative recency of social tariffs entering the broadband market, awareness and lack of obvious advertising appear to be holding back uptake. Research from the Citizens Advice Bureau indicates that high exit fees from existing contracts are also a factor preventing people from switching.<a href="#_edn168" id="_ednref168"><sup>[168]</sup></a> It is likely this impact may lessen over time as those now aware of social tariffs naturally come to the end of higher price contracts and are able to switch without penalty.</p>



<p class="wp-block-paragraph">BT dominates the social tariff market with over 60% of take up. This is despite the fact that its lowest cost plan only for those on UC with no earned income is £16 per month is higher than other social tariff providers, including some of those available nationally. Coupled with the fact that social tariffs are often poorly marketed by other providers, it appears that claimants are not aware that they should still shop around for the best rate, whether it is a social tariff or not.</p>



<h3 class="wp-block-heading"><a></a>Legal &amp; financial</h3>



<h4 class="wp-block-heading"><a></a><strong>Legal aid</strong></h4>



<p class="wp-block-paragraph">Civil non-contributory legal aid is passported to those in receipt of UC, Pension Credit Guaranteed Element and legacy working age benefits, avoiding the usual income means test.<a href="#_edn169" id="_ednref169"><sup>[169]</sup></a> Those not in receipt of benefits need a gross household income of less than £31,884 per year (unless they have less than four dependent children, which then raises the threshold).<a href="#_edn170" id="_ednref170"><sup>[170]</sup></a> If their income is below that threshold, only then do they progress to a disposable income test, with a sliding scale between £315 to £733 which determines how much they may be required to pay towards their costs. The threshold has not been changed since 2009 and therefore those eligible outside of benefit-related passporting has significantly declined as wages have inflated. All civil legal aid applicants, including those on UC also have to pass a means test of their disposable capital, usually up to £8,000.<a href="#_edn171" id="_ednref171"><sup>[171]</sup></a></p>



<p class="wp-block-paragraph">As with all routes to legal aid, only particular types of cases are within scope and cases must also meet merits-based criteria. UC passporting therefore means that some higher-earning UC claimants are eligible for full civil legal aid while lower-earning non-UC claimants are ineligible or would have to contribute to their costs.</p>



<p class="wp-block-paragraph">For criminal legal aid, there are different eligibility assessments depending on where the case is being heard. At Magistrates’ Court, advice and representation for those earning less than £12,475 automatically attracts legal aid, and those earning up to £22,352 have their disposable income assessed. For Crown Court criminal legal aid, income does not determine access to legal aid, but does determine how much contribution defendants have to pay if they are convicted.</p>



<p class="wp-block-paragraph">While there is no formal disregard of benefit income for criminal legal aid income assessments, defendants on UC are usually treated as having insufficient disposable income to pay contributions. This means that, for example, someone working 40 hours per week at the minimum wage earns too much to be eligible for criminal legal aid unless they were claiming UC too.<a href="#_edn172" id="_ednref172"><sup>[172]</sup></a> As legal aid is almost always granted in the Crown Court, some defendants who do not qualify for legal aid in the Magistrates’ Court choose trial in the Crown Court, because otherwise they would not be able to afford legal representation.<a href="#_edn173" id="_ednref173"><sup>[173]</sup></a></p>



<p class="wp-block-paragraph">In 2019, the Government launched the Legal Aid Means Test which aimed to re-base thresholds that had not been uprated in line with inflation and expand access for vulnerable groups.<a href="#_edn174" id="_ednref174"><sup>[174]</sup></a> It consulted on a series of changes, including making households on UC with more than £500 per month earned income undergo an income assessment. In the accompanying Impact Assessment, it is estimated that this threshold would result in only 73% of currently passported individuals being in receipt of non-contributory civil legal aid. It proposed continuing to passport all recipients of UC through the income assessment for criminal legal aid.<a href="#_edn175" id="_ednref175"><sup>[175]</sup></a> While these recommendations from the review were accepted in 2023, the secondary legislation required to bring them into force has not yet been laid, but is expected this year.<a href="#_edn176" id="_ednref176"><sup>[176]</sup></a></p>



<p class="wp-block-paragraph">In England and Wales, 20% of the adult population in 2022 were estimated to be eligible for non-contributory civil legal aid under a scenario of full UC rollout with no income assessment for claimants.<a href="#_edn177" id="_ednref177"><sup>[177]</sup></a> There is no further publicly available breakdown to show how many of those eligible received legal aid and whether this was passported through UC or via an income assessment. In 2024/25, the Legal Aid Agency spent £2.1 billion, just over half of which was on criminal legal aid and the rest civil legal aid.<a href="#_edn178" id="_ednref178"><sup>[178]</sup></a> In the same year, the Legal Aid Agency processed 380,000 applications for legal aid.<a href="#_edn179" id="_ednref179"><sup>[179]</sup></a> Some costs counted as legal aid are not borne via income assessed routes, such as free advice available to all from the duty solicitor at police stations, but it is difficult to separate these costs.<a href="#_edn180" id="_ednref180"><sup>[180]</sup></a></p>



<p class="wp-block-paragraph">There are no published breakdowns of the current proportions of each type of legal aid that are passported versus income-assessed. According to an independent review of criminal legal aid in 2021, around 45% of applications are automatically passported for legal aid since the defendant is receiving UC.<a href="#_edn181" id="_ednref181"><sup>[181]</sup></a> Using this proportion as a proxy for civil legal aid too, approximately 145,000 claims a year via the passported route, costing £472 million per year.<a href="#_edn182" id="_ednref182"><sup>[182]</sup></a></p>



<h4 class="wp-block-heading"><a></a><strong>Court fee remission</strong></h4>



<p class="wp-block-paragraph">In addition to legal aid, for cases that typically incur court, hearing, appeal or some tribunal fees, UC claimants are automatically eligible for full fee remission. It has been provided through the “Help with Fees” scheme through HM Courts and Tribunals Service since 2013. Those not in receipt of UC or Pension Credit Guaranteed Element have to pass an income test, but this is based on gross household income rather than the disposable income measure which applies for legal aid. For a single person, the monthly income limit is £1,420, rising to £2,130 for a couple and then an extra £425 for each dependent child under age 13 or £710 for those 14 and over.<a href="#_edn183" id="_ednref183"><sup>[183]</sup></a> Again, it is perfectly possible for an eligible household on UC to receive well over the income limits in their UC payment once factoring in housing, health and other elements.</p>



<p class="wp-block-paragraph">In 2022-23, the Government consulted on a range of changes to the Help with Fees scheme, including measures that would have seen eligibility more closely aligned with legal aid means testing, which was under review at the same time.<a href="#_edn184" id="_ednref184"><sup>[184]</sup></a> This included abolishing the previous earned income test for UC claimants which removed passporting for those who earned more than £6,000 per year.</p>



<p class="wp-block-paragraph">A capital test applies to all fee remission, which is different to the legal aid capital test. There are limits of £4,250 for fees under £1,420 up to £16,000 for fees over £7,000.<a href="#_edn185" id="_ednref185"><sup>[185]</sup></a> Most fees are well under £1,420, with the highest common fee being £612 for divorce.<a href="#_edn186" id="_ednref186"><sup>[186]</sup></a> Alongside a range of options, proposals to bring the capital limits in line with legal aid were rejected, leaving the capital limits at the same level as they were at the introduction of the scheme in 2013.<a href="#_edn187" id="_ednref187"><sup>[187]</sup></a></p>



<p class="wp-block-paragraph">There is no routine publication of the amount of revenue lost to fee remission each year. In 2021-22 (prior to eligibility changes in 2023), remission was equivalent to £81 million, which was 11% of the total value of fees charged.<a href="#_edn188" id="_ednref188"><sup>[188]</sup></a> There were just over 122,500 recipients of partial or full remission in that year, giving an average remission value of £661 per recipient.<a href="#_edn189" id="_ednref189"><sup>[189]</sup></a> Since then, the removal of the £6,000 earned income test for UC recipients has widened this route for passported eligibility, taking the proportion eligible for full fee remission from 93% to 99% of passported recipients.<a href="#_edn190" id="_ednref190"><sup>[190]</sup></a></p>



<h4 class="wp-block-heading"><a></a><strong>Funeral Expenses Payment</strong></h4>



<p class="wp-block-paragraph">A Funeral Expenses Payment is available in England and Wales to those on UC to cover necessary burial or cremation costs, reasonable travel costs plus up to £1,000 for other funeral-related expenses. Applicants must be the nearest responsible relative for the deceased and on UC or Pension Credit to qualify. The amount available for burial and cremation costs is uncapped, as are reasonable travel costs that the claimant may incur to arrange the funeral or travel to the funeral itself. Costs are then recovered in full or in part if there is an estate of the deceased from which to recover them.</p>



<p class="wp-block-paragraph">The rules on the nearest responsible relative are set out in Social Fund regulations, which assess which relative is closest in a hierarchy from spouse through to close friend. If there is more than one relative with the same relational closeness but not on UC, they are deemed responsible for paying unless specific evidence of estrangement, abuse or incapacity can be provided. This can leave a UC claimant with the closest interpersonal relationship with the deceased making the arrangements and ineligible for a payment even if the other relation deemed responsible for paying refuses to cover the costs of the funeral. As Funeral Expenses Payment claims are usually lodged retrospectively up to three months after the funeral has taken place, some claimants unexpectedly find their claim has been denied even if they were the primary carer for the deceased.<a href="#_edn191" id="_ednref191"><sup>[191]</sup></a> In 2024/25, 1,000 applications for Funeral Expenses Payments were refused due to not being deemed the closest family member.<a href="#_edn192" id="_ednref192"><sup>[192]</sup></a></p>



<p class="wp-block-paragraph">For those who die with no arrangements or anyone willing to pay, public health funerals are provided by the local authority. Close family or friend attendance can be requested alongside a brief service but this is granted at the council’s discretion. Again, costs are recouped from any significant estate. Around 2% of all funerals are paid for at least in part by some form of Government grant.<a href="#_edn193" id="_ednref193"><sup>[193]</sup></a></p>



<p class="wp-block-paragraph">In 2024-25, £52 million was spent on Funeral Expenses Payments, with just £700,000 being recovered from estates.<a href="#_edn194" id="_ednref194"><sup>[194]</sup></a> According to SunLife’s annual <em>Cost of Dying </em>report, of those who receive a Funeral Expenses Payment, it covered only around 46% of total simple funeral costs in 2025.<a href="#_edn195" id="_ednref195"><sup>[195]</sup></a> There has been no routine publishing of application and award statistics for the Funeral Expenses Payment since the Social Fund Annual Report was discontinued after 2020/21. A written answer to a parliamentary question in February 2022 indicated that around a third of the 3,400 applications submitted on average per month in the previous year were rejected.<a href="#_edn196" id="_ednref196"><sup>[196]</sup></a></p>



<p class="wp-block-paragraph">In September 2020, Scotland diverged from England in Wales, replacing the Funeral Expenses Payment with a more generous Funeral Support Payment. While eligibility is still passported via UC, there is greater discretion over the nearest responsible relative tests if the claimant is the <em>de facto</em> funeral organiser. Burial, cremation and travel costs are paid separately at cost as they are in England and Wales, but a higher contribution is required if the deceased had a funeral plan.<a href="#_edn197" id="_ednref197"><sup>[197]</sup></a> These rates are uprated by CPI each year, while Funeral Expenses Payments only increased to £1,000 in 2020 as a one-off increase and the first time rates had increased since 2003.<a href="#_edn198" id="_ednref198"><sup>[198]</sup></a> According to Scottish Government evaluation of Funeral Support Payments from 2019-21, 77% of recipients were below state pension age, therefore likely qualifying via UC or legacy working age benefits.<a href="#_edn199" id="_ednref199"><sup>[199]</sup></a></p>



<p class="wp-block-paragraph">In addition to Funeral Expenses Payments, the DWP also administers Bereavement Support Payments UK-wide to working age spouses of the deceased or cohabiting partners with dependent children, so long as they had paid National Insurance contributions for at least 25 weeks in any one tax year before they died.<a href="#_edn200" id="_ednref200"><sup>[200]</sup></a> This is intended as income replacement for lost household income rather than cost reimbursement and is not contingent on benefit status. It starts with a lump sum of £2,500 for those without dependent children, or £3,500 for those with dependent children, with monthly payments of £100 or £350 continuing for 18 months.<a href="#_edn201" id="_ednref201"><sup>[201]</sup></a></p>



<p class="wp-block-paragraph">While Bereavement Support Payments and Funeral Expenses Payments serve different cohorts, it is worth noting that some UC claimants paying for funeral arrangements for a loved one will receive both, while others may receive neither. Many will be unaware of their eligibility and the total value of support they will get until well after immediate costs have been incurred.</p>



<h4 class="wp-block-heading"><a></a><strong>Help to Save</strong></h4>



<p class="wp-block-paragraph">Help to Save is a UK-wide savings scheme run by the government which allows working UC claimants to receive a 50p tax-free bonus from the government for every £1 they save over four years. Until April last year, the bonus was paid in two installments according to the highest balance saved at any point at the first two and the last two years each, even if withdrawals have reduced the balance by the point of bonus payment.<a href="#_edn202" id="_ednref202"><sup>[202]</sup></a> The maximum amount that can be deposited each month is £50, meaning that the maximum bonus possible over the four years is £1,200. Accounts remain open and pay bonuses for the full four years regardless of whether claimants come off UC during that time.</p>



<p class="wp-block-paragraph">Help to Save cost £45 million in 2024/25, with just under 200,000 claimants due to receive a bonus from accounts opened two and four years prior.<a href="#_edn203" id="_ednref203"><sup>[203]</sup></a> The average deposit paid in each month of 2024/25 was £48 per month, showing the intention of claimants to maximise their payout.<a href="#_edn204" id="_ednref204"><sup>[204]</sup></a> However, the average bonus paid out for those who opened accounts that reached year two or year four in 2024/25 was just £227. This figure is likely to be depressed by the high number of claimants who open an account but never pay any money in, who total 36,000 since the scheme began in 2018.</p>



<p class="wp-block-paragraph">In April 2025, an earnings floor which stipulated that claimants had to have at least £793 earned income in their last monthly assessment period was reduced to £1, so the scheme is now open to all those working on UC.<a href="#_edn205" id="_ednref205"><sup>[205]</sup></a> Rather than paying out every two years, Help to Save will now pay out every six months and will be based on net contribution rather than the highest balance.</p>



<p class="wp-block-paragraph">There is only one month of data available since the change, which saw account opening almost double month on month, although there have been other spikes coinciding with communications campaigns.<a href="#_edn206" id="_ednref206"><sup>[206]</sup></a> While those with lower earnings may be less likely to pay in the maximum amount, the total eligible population has increased by 16%.<a href="#_edn207" id="_ednref207"><sup>[207]</sup></a></p>



<p class="wp-block-paragraph">A government-commissioned evaluation of Help to Save published in November 2025 (assessing the period before the change in scheme design) shows mixed results about whether savings habits were likely to be sustained long term, as per the scheme’s stated purpose.<a href="#_edn208" id="_ednref208"><sup>[208]</sup></a> On the one hand, 84% of those who had come to the end of their four years on Help to Save reported that they were more confident that they would be able to continue their savings habit for 12 months or more. At the same time, around a third of previous scheme beneficiaries also reported that they would either save less money (33%) or less frequently (30%) than before Help to Save.</p>



<p class="wp-block-paragraph">More concerningly, the same report indicated that when those who had received Help to Save bonuses were asked what they did with the money, the most common response was that they used it to pay off debts or bills, with over a third (35%) reporting this use.<a href="#_edn209" id="_ednref209"><sup>[209]</sup></a> It suggests that rather than using their disposable funds to incrementally pay off debt or arrears, they may have been letting interest accrue while waiting for the generous biennial payout. This is perfectly rational behaviour within a scheme with such a generous subsidy while also protected from the full burden of their debts by cap on deductions taken while on UC. However, it may be embedding distorted behaviour that is unsustainable outside of UC, with no savings accounts on the private market offering anywhere near the same returns and a far more punitive debt collection regime.</p>



<h3 class="wp-block-heading"><a></a>Local</h3>



<h4 class="wp-block-heading"><a></a><strong>Council tax support</strong></h4>



<p class="wp-block-paragraph">Since 2013/14, local authorities have been required to set up their own council tax support schemes detailing eligibility and reduction amounts. Only reductions for certain types of pensioners are mandatory. For most schemes, UC claimant status forms part of the eligibility route for council tax reduction. This typically includes full or higher reduction for those in the limited capability for work conditionally group, or with no or low earned income.</p>



<p class="wp-block-paragraph">The default model for council tax support involves tapering support above a set threshold, usually at a 20% taper rate, with three quarters of council tax support schemes in England structured in this way.<a href="#_edn210" id="_ednref210"><sup>[210]</sup></a> The other quarter set income bands within which there is no change in support. As council tax support is delivered outside UC taper, this additional taper can lead to very high marginal effective tax rates, especially for those earning above the personal allowance. These disincentives to work are magnified for those with fluctuating earnings, with 1.4 million households estimated to be impacted by in-year changes in council tax support in councils using the default model.<a href="#_edn211" id="_ednref211"><sup>[211]</sup></a></p>



<p class="wp-block-paragraph">Local council tax support was previously provided through Council Tax Benefit which operated under a single national set of eligibility and award criteria, sharing means-testing rules with Housing Benefit. Until 2013, councils were fully reimbursed by central government for the reductions, regardless of local council tax rates. After an initial 10% cut in funding when local council tax support was introduced, central government funding for these schemes has eroded significantly as local government finance settlements have been squeezed.</p>



<p class="wp-block-paragraph">From UC’s inception, there was a clear intention to roll council tax support into UC payments. The Local Government Finance Act 2012 even required there to be an independent review into the council tax reduction schemes provided by councils, including recommendations on whether such schemes should be brought within UC.<a href="#_edn212" id="_ednref212"><sup>[212]</sup></a> However, by the time of the review’s publication and government’s response to it, there had been a wider policy shift towards localism which favoured local fiscal responsibility over a centrally set system.<a href="#_edn213" id="_ednref213"><sup>[213]</sup></a> Alongside the migration to UC simply being too slow to consider a new workstream on merging with council tax support at the time, plans to roll the two together were formally dropped in 2018.<a href="#_edn214" id="_ednref214"><sup>[214]</sup></a></p>



<p class="wp-block-paragraph">Local council tax support schemes vary widely, with most introducing minimum council tax payments for those receiving a reduction. Analysis by the IFS in 2019 found that the average minimum payment was 19%.<a href="#_edn215" id="_ednref215"><sup>[215]</sup></a> Welfare reforms implemented at a national level during the last Government have also been incorporated in scheme design by many councils, such as introducing a two-child limit, a freeze in benefit rates and the minimum income floor for the self-employed.<a href="#_edn216" id="_ednref216"><sup>[216]</sup></a></p>



<p class="wp-block-paragraph">There is also significant variation between UK nations. In the average local authority in England, a family with an average council tax liability receiving maximum council tax reduction would have to pay £248 per year, compared to zero in Scotland and Wales.<a href="#_edn217" id="_ednref217"><sup>[217]</sup></a></p>



<p class="wp-block-paragraph">To add to the confusion claimants’ face, council tax bills are calculated on an annual basis, while eligibility for council tax reduction can change from month to month. Research by the University of Bath interviewing claimants in receipt of council tax reduction found that councils using HMRC real time earnings data to determine eligibility could put claimants on full reduction one month and into arrears in the next.<a href="#_edn218" id="_ednref218"><sup>[218]</sup></a></p>



<p class="wp-block-paragraph">The postage cost alone of issuing new bills due to fluctuations in income that trigger different support rates is estimated to be up to £16 million per year.<a href="#_edn219" id="_ednref219"><sup>[219]</sup></a> In the last quarter for which local council tax support statistics are available, there were 2,288,079 working age local council tax support claimants.<a href="#_edn220" id="_ednref220"><sup>[220]</sup></a> Policy in Practice estimates that the average yearly claim for council tax support from those on UC is £1,200 in England, with a take-up rate of 62%.<a href="#_edn221" id="_ednref221"><sup>[221]</sup></a></p>



<h4 class="wp-block-heading"><a></a><strong>Flexible Support Fund</strong></h4>



<p class="wp-block-paragraph">The Flexible Support Fund is a discretionary scheme accessed through the Jobcentre Plus which allows work coaches to grant cash to help UC claimants pay for the costs of finding or starting work. This includes expenses like travel to interviews, interview clothing, training and upfront childcare costs. There is very little publicly available information about how it is spent. According to DWP’s projection of spending for 2024/25, it was due to cost £117 million.<a href="#_edn222" id="_ednref222"><sup>[222]</sup></a></p>



<h4 class="wp-block-heading"><a></a><strong>Crisis and Resilience Fund</strong></h4>



<p class="wp-block-paragraph">From April this year, major consolidation of discretionary support is coming through the new £1 billion Crisis and Resilience Fund, which rolls together Discretionary Housing Payments and the Household Support Fund. It will provide local authorities in England with funding to support low-income households who “encounter a financial shock and to support activity that builds individual and community financial resilience.”<a href="#_edn223" id="_ednref223"><sup>[223]</sup></a></p>



<p class="wp-block-paragraph">Guidance on the new Crisis and Resilience Fund sets out a largely narrative account of problems that a potential recipient could have and general commentary on what support could look like.<a href="#_edn224" id="_ednref224"><sup>[224]</sup></a> The new guidance replicates failures in its predecessor schemes that do not properly distinguish between whether the crisis is an unforeseen one-off event versus the result of a structural deficit in that household’s income and outgoings. There is no defined framework for assessing whether a circumstance demands a temporary cashflow bridge to avoid falling into deficit rather than up-front assistance to move the household to a more sustainable financial footing in the long term.</p>



<h4 class="wp-block-heading"><a></a><strong>Discretionary Housing Payments</strong></h4>



<p class="wp-block-paragraph">Previously, the Discretionary Housing Payment was a scheme which expanded rapidly after welfare reforms were implemented in 2013. Claimants had to be in receipt of housing benefit or the UC housing element to be eligible. In the new Crisis and Resilience Fund guidance, it is not specified whether this will remain a scheme passported only to those on housing-related benefits. It also mentions mortgages as a priority debt, which could blur whether it can be used instead of a Support for Mortgage Interest loan.<a href="#_edn225" id="_ednref225"><sup>[225]</sup></a> In 2024/25, £106 million was spent on just under 150,000 Discretionary Housing Payment payments.<a href="#_edn226" id="_ednref226"><sup>[226]</sup></a> Based on evaluation of the scheme published in 2024, roughly 93% of which are estimated to have been received by recipients of working age.<a href="#_edn227" id="_ednref227"><sup>[227]</sup></a></p>



<p class="wp-block-paragraph">Receiving Discretionary Housing Payments directly distorts the intentional incentives of the 2013 welfare reforms to make sure that claimants are renting properties of an appropriate size that they can afford within their benefit award &#8211; and to move if this is unaffordable. In the last year, 61% of support provided through the scheme was dispensed to claimants for the express purpose of mitigating the impact of welfare reforms, such as the removal of the spare room subsidy, Local Housing Allowance shortfalls caused by a freeze in rates and the benefit cap.<a href="#_edn228" id="_ednref228"><sup>[228]</sup></a> Less than a third was used by recipients to help secure alternative accommodation through rental deposits or cover short term rental costs while waiting to move. By dampening the incentive to move, the payments are causing long-term dependence on discretionary support. In the 2024 evaluation of the scheme, 83% of those who were receiving a Discretionary Housing Payment had received more than one in the last two years.<a href="#_edn229" id="_ednref229"><sup>[229]</sup></a></p>



<h4 class="wp-block-heading"><a></a><strong>Household Support Fund</strong></h4>



<p class="wp-block-paragraph">The Household Support Fund was established in 2021 during the Covid-19 pandemic as an emergency measure to get support to household costs during a time of uncertainty and inflation. As it evolved from the Covid Winter Grant Scheme, it was deliberately vague in design so that councils could use it flexibly to relieve rapidly increasing demand. It was originally meant to last for six months, but was steadily extended and became effectively permanent.<a href="#_edn230" id="_ednref230"><sup>[230]</sup></a></p>



<p class="wp-block-paragraph">The Household Support Fund was allocated £742 million in 2025/26, but there is no data on what proportion goes to UC claimants as councils are not required to share this in their management information.<a href="#_edn231" id="_ednref231"><sup>[231]</sup></a> Evaluation of the previous phase of the scheme showed that 60% of respondents surveyed about use of the Households Support Fund were in receipt of UC.<a href="#_edn232" id="_ednref232"><sup>[232]</sup></a></p>



<h4 class="wp-block-heading"><a></a><strong>Local schemes</strong></h4>



<p class="wp-block-paragraph">In addition to council tax support, many local councils offer their own passported schemes for UC and other benefit claimants on a wide array of leisure, cultural, transport or other service discounts. These are provided at the discretion of each council but outside of statutory local welfare which councils administer, such as the Household Support Fund and Discretionary Housing Payments. A significant proportion of UC claimants in some areas may therefore be receiving multiple non-essential free or reduced cost services while paying no or little council tax to the council providing these concessions.</p>



<p class="wp-block-paragraph">Following Freedom of Information requests submitted to every council in England and Wales, Onward analysis found that the most common type of passported scheme offered were leisure centre concessions, often in the form of a discounted membership card scheme.<a href="#_edn233" id="_ednref233"><sup>[233]</sup></a> Some offered free or discounted access to spa facilities, mini-golf, theatre workshops, cinema tickets and beach hut hire. While some of these were provided by Local Authority Trading Companies, for which the council may recoup costs from increased use of facilities, others were provided through paid partnerships with external companies where councils are paying the difference.</p>



<p class="wp-block-paragraph">It was clear from the many partial or non-responses that the same issues of diffuse responsibility seen with multiple central government departments involved in administering passported benefits was replicated at a local level. Even with the volumes far lower than national schemes, some councils were not coordinating their offers in a way that would flag who was missing out on extra support or who may be drawing a significant amount of council funds.</p>



<h4 class="wp-block-heading"><a></a><strong>Example claimants</strong></h4>



<p class="wp-block-paragraph">Below are two illustrative examples of claimants and the passported benefits they would receive. They are intended to show how much those with different household compositions can claim. As explained above, many claimants do not access all of the schemes to which they are eligible for a wide variety of reasons.</p>



<p class="wp-block-paragraph">These fictional but realistic examples are intended not to cast judgement on those who claim or to give the most extreme possible cases, but to demonstrate how irrational it can be for claimants in specific but normal circumstances to come of UC entirely due to the scale of the additional benefits they would likely lose. Costs are based on the average or specific values relating to their circumstances of these awards as outlined above.</p>



<blockquote class="wp-block-quote is-layout-flow wp-block-quote-is-layout-flow">
<p class="wp-block-paragraph"><strong>Example 1: Single parent family with three children</strong> &nbsp; </p>



<p class="wp-block-paragraph"><em>Jenny is 38 and lives with her three children aged 2, 8 and 11. She has been on UC since her husband left her and works one day a week around looking after her children. She earns the minimum wage and wants to increase her hours as her youngest has settled into a nursery.</em> <em>&nbsp;</em> </p>



<p class="wp-block-paragraph"><em>Because she claims UC, two older children receive free school meals and go to a club funded by the Holiday Activities and Food Programme in the school holidays. As they live 2.8 miles from her oldest child&#8217;s secondary school, they get picked up by a free school bus. </em></p>



<p class="wp-block-paragraph"><em>She has a Healthy Start card for her youngest and uses the offer of 15 hours of free childcare for children aged two with extra support. During Jenny’s divorce earlier this year, her court fees were remitted.</em> <em>&nbsp;</em> </p>



<p class="wp-block-paragraph"><em>As Jenny has three children, she gets her water bill capped by WaterSure. In the winter, she got a Warm Home Discount rebate and she&#8217;s also recently switched to a broadband social tariff. She receives full council tax reduction.</em> <em>&nbsp;</em> </p>



<p class="wp-block-paragraph"><em>This year, she received £11,781 in additional benefits and benefits in-kind outside of her UC claim. If she worked enough to come off UC, she is unlikely to be able to claim any of these benefits, losing £11,169 in effective income per year (not including her one-off court fee remission).</em></p>
</blockquote>



<figure class="wp-block-table"><table class="has-fixed-layout"><tbody><tr><td>&nbsp;<strong>Passported benefits</strong></td><td><strong>Value</strong></td></tr><tr><td>Free School Meals</td><td>£990</td></tr><tr><td>Free school transport</td><td>£1,495</td></tr><tr><td>Holiday Activities and Food Programme</td><td>£600</td></tr><tr><td>Extra Support Childcare</td><td>£5,988</td></tr><tr><td>Healthy Start</td><td>£221</td></tr><tr><td>WaterSure</td><td>£325</td></tr><tr><td>Warm Home Discount</td><td>£150</td></tr><tr><td>Broadband social tariff</td><td>£200</td></tr><tr><td>Court fee remission</td><td>£612</td></tr><tr><td>Council tax reduction</td><td>£1,200</td></tr><tr><td><strong>Total</strong></td><td><strong>£11,781</strong></td></tr></tbody></table></figure>



<blockquote class="wp-block-quote is-layout-flow wp-block-quote-is-layout-flow">
<p class="wp-block-paragraph"><strong>Example 2: Single man with no children</strong> </p>



<p class="wp-block-paragraph"><em>Ben is 44 and has been claiming UC since struggling to find sustained employment while suffering some ill-health.</em> </p>



<p class="wp-block-paragraph"><em>He lives in a privately-rented property that has an Energy Performance Certificate rating of E, so he recently had a series of energy efficiency measures installed through the Energy Company Obligation scheme. </em></p>



<p class="wp-block-paragraph"><em>He received a Warm Home Discount rebate and a Cold Weather Payment, following a week of especially low temperatures.</em> <em>Ben had some routine dental work done earlier in the year. He is also on a water social tariff and a broadband social tariff.</em> </p>



<p class="wp-block-paragraph"><em>This year, he received £20,588 in additional benefits and benefits in-kind outside of his UC claim. If he worked enough to come off UC, he is unlikely to be able to claim any of these benefits, losing £734 in effective income per year (not including his one-off energy efficiency upgrades and Cold Weather Payment).</em> </p>
</blockquote>



<figure class="wp-block-table"><table class="has-fixed-layout"><tbody><tr><td>&nbsp;<strong>Passported benefits</strong></td><td><strong>Value</strong></td></tr><tr><td>Free prescriptions</td><td>£140</td></tr><tr><td>Free dental treatment</td><td>£81</td></tr><tr><td>Energy Company Obligation</td><td>£19,748</td></tr><tr><td>Warm Home Discount</td><td>£150</td></tr><tr><td>Cold Weather Payment</td><td>£25</td></tr><tr><td>Water social tariff</td><td>£244</td></tr><tr><td>Broadband social tariff</td><td>£200</td></tr><tr><td><strong>Total</strong></td><td><strong>£20,588</strong></td></tr></tbody></table></figure>



<h3 class="wp-block-heading"><strong>Recommendations</strong></h3>



<p class="wp-block-paragraph">This section sets out a principles-based foundation for reform of passported and discretionary welfare. It goes scheme-by-scheme to recommend how each could be consolidated, altered or abolished, alongside internal changes to help the Government regain a grip over the system as a whole. There will be significant winners and losers, just as there are under present fragmented passporting schemes. This radical rationalisation makes these trade-offs as active decisions, rather than leaving them as passive series of unintended consequences.</p>



<h4 class="wp-block-heading"><strong>Principles for reform</strong></h4>



<ol start="1" class="wp-block-list">
<li><strong>Certainty &#8211; claimants should know they will be better off in work and working more.</strong> This is not a new principle, but a return to the original intent behind UC. The path from welfare to work should be as smooth as possible, with a clear net benefit felt from every extra pound earnt. There should neither be hidden cliff edges along the claimant journey, nor a precipitous fall in effective income when coming off UC altogether. The calculation needed for claimants to see they will be better off should be as easy to understand as possible. It should reward applying for jobs and progressing, not applying to every arm of the state for an extra handout.</li>
</ol>



<ol start="2" class="wp-block-list">
<li><strong>Consistency &#8211; claimants should face the same household budgeting dynamics as others. </strong>While the first principle regards income, this principle considers costs. The current system creates two separate worlds &#8211; one in which claimant households face daily living costs that are dictated by bureaucrat-created schemes, while other households have costs displaced onto them to pay for such schemes. Across a period of significant price changes, many legacy thresholds have remained and uprating decisions have been sporadic at best. Giving claimants an entirely different set of basic living costs to those just beyond benefit eligibility makes that transition into financial independence much more difficult. The budgeting dynamics that claimants experience should as closely resemble those they will face outside the benefit system as possible, allowing them to gradually adjust their outgoings to reflect their circumstances.</li>
</ol>



<ol start="3" class="wp-block-list">
<li><strong>Simplicity &#8211; only support not possible to target within UC should be delivered elsewhere. </strong>Tying the first two principles together, an award-first approach should be adopted to all government support for this cohort. Additional income replacement deemed necessary for all should be delivered through the standard allowance, that for families with children through the child element or childcare element and so on. If it is not an income-replacement measure, it should not be tied to UC receipt at all. Only exceptional one-off costs should be dealt with separately, but still with a set of rules that interfere with the first two principles as little as possible and encourage claimants to build their own financial resilience through work. By rolling more into UC, support will reach more of those currently missing out rather than prizing those able to navigate the bureaucracy.<br></li>
</ol>



<h4 class="wp-block-heading"><strong>Policy recommendations</strong></h4>



<p class="wp-block-paragraph"></p>



<h5 class="wp-block-heading"><strong>1.</strong> <strong>Measure income and outgoings in the same dataset. </strong></h5>



<p class="wp-block-paragraph">What gets measured gets managed. The lack of accurate data to show a total net view of household income and costs has warped policy decisions for decades. The fact that the vast majority of passported benefits are not included anywhere in the Family Resources Survey &#8211; whose very title indicates that it is meant to give a complete picture of all the resources families have at their disposal &#8211; means that resultant poverty metrics give a distorted view of relative need across the income distribution, and distorts the distribution itself. It is imperative that the government holds accurate, up-to-date information on both household income versus expenditure as well contribution versus receipt in a single dataset.</p>



<h6 class="wp-block-heading"><strong>a.</strong> <strong>Rationalise duplication across government-funded income and costs surveys.</strong> </h6>



<p class="wp-block-paragraph">Having so many different passported benefit schemes makes it virtually impossible for those responding to the Family Resources Survey to accurately state their total income even if they were asked for this information. The survey is already experiencing falling response rates, which are at least in part due to length and complexity, now taking over an hour to complete the survey on average.<a href="#_edn234" id="_ednref234"><sup>[234]</sup></a> Therefore it is not desirable to seek better data on passported schemes by simply adding more questions; existing questions need to be substituted or removed. For starters, the extensive section on food security should be removed, not least as the National Diet and Nutrition Survey already asks more granular questions about food consumption by income and household composition.</p>



<h6 class="wp-block-heading"><strong>b. Link data from the Family Resources Survey and the Living Costs and Food Survey.&nbsp;</strong></h6>



<p class="wp-block-paragraph">The Living Costs and Food Survey collects diary-based data on household spending patterns, but no information on claimant status or costs met through benefits in-kind. It too falls victim to a disproportionate focus on food at the expense of drilling into other living costs that drive the ability to afford it. The Family Resources Survey and the Living Costs and Food Survey responses do not directly link, meaning there is no complete picture of income versus outgoings.&nbsp;&nbsp;</p>



<p class="wp-block-paragraph">While still gathering information on essentials that households may go without, questions should principally seek to uncover the causes rather than fixating on the symptoms of particular missing resources. A detailed review of both surveys in tandem should be conducted, aimed at harmonising responses into a single dataset on household income and expenditure. This should reveal richer data about the budgeting, cashflow and structural deficits that lead to decisions to economise on or not consume some essentials. In turn, more accurate metrics for measuring resources, deprivation and poverty can be developed with this information, and policy adjusted accordingly.</p>



<h5 class="wp-block-heading"><strong>2.</strong> <strong>Improve internal data collection, sharing and systems.</strong> </h5>



<p class="wp-block-paragraph">Modernisation of the data architecture underlying Government departments is long overdue. Claimants spend vital marginal effort that could be used seeking work filling in endless forms to provide the government with information that it already holds, just not in an accessible place. Bureaucrats fill the void between datasets, existing at the expense of taxpayers simply to pass information to each other. More still is wasted correcting errors, investigating fraud and developing duplicative policy.</p>



<p class="has-text-align-left wp-block-paragraph">It is perverse that the government is most efficient with sharing personal data across public services after death. The “Tell Us Once” service cascades information through a notification system across DWP, HMRC, local authorities, the Passport Office, the DVLA and more from a single trigger. This approach should be the rule, not the exception, for all changes in circumstance which alter the level of support someone is eligible for.</p>



<p class="wp-block-paragraph">The complexity of data collection for this paper’s scheme-by-scheme analysis and the assumptions that needed to be made point to the dearth of easily comparable information on billions of Government spending. Without this data, evaluation of passporting policies will remain limited and ministers will continue to make well-intentioned, but suboptimal decisions. A multi stage solution is proposed</p>



<h6 class="wp-block-heading"><strong>a.</strong> <strong>Use a standard format for collecting management information from schemes.</strong> </h6>



<p class="wp-block-paragraph">This should include claimant characteristics, eligible populations, the range of award values and total expenditure. It will help track who is benefitting from different schemes, whether they are competing against each other or incentives to work, if they need re-basing or uprating and the total burden on taxpayers. Where possible, this should be cross checked against external datasets too, like that gathered by credit reference agencies.</p>



<h6 class="wp-block-heading"><strong>b. Mandate a consumer costs review on departments with passported benefits. </strong></h6>



<p class="wp-block-paragraph">Just as the sufficiency review seeks to uncover downstream costs, this looks at what can be done upstream. Every Government department responsible for administering or owning regulation for a passported scheme must produce a consumer cost reduction plan. This should set out all of the policies that contribute to essential household costs. Each department must identify supply side measures to reduce households costs up to the equivalent of the average cost of the passported subsidy.</p>



<p class="wp-block-paragraph">There can be some horse-trading between departments as to who bears the responsibility for costs, such as the Department for Education asking the Department for the Environment, Food and Rural Affairs to address food to meet the requirement for free school meals. But the key is that measures identified are specific, costs are realistic and changes are deliverable.</p>



<p class="wp-block-paragraph">It sets out a clear deregulation-first, business tax-reduction approach to reducing living costs for everyone. The higher the subsidy, the harder officials will have to work to peel back layers of bureaucracy they have created that are causing living costs to be so expensive. The department will only cease to be subject to the review once changes that deliver household savings equivalent to the average value of the subsidy to claimants have been identified.</p>



<h6 class="wp-block-heading"><strong>c.</strong> <strong>Implement a federated data system across public services. </strong></h6>



<p class="wp-block-paragraph">In the longer term, the only sensible way to manage data from schemes is to develop a proper federated data system across public service policy departments. Systems like this have started to be used in the NHS and in some local authorities, but their true potential can only be reached through wider adoption to link data across services. This will both give the Government better visibility over its policy decision as well as a wider range of policy choices. At once, it allows micro-targeting to specific cohorts and reduces the need for additional schemes at all by getting more help to all those intended in the first instance.</p>



<p class="wp-block-paragraph">A cross-government public service federated data platform could take this a step further, bridging the gap to those who are most in need of support but have the least capacity to seek help and therefore fall through the cracks of fragmented passported schemes. In an instant, information about households and individuals can be retrieved, need isolated and support delivered as appropriate. It would revolutionise the way that policy is designed, starting from a point of maximised reach rather than duplicating for the same essential purpose.</p>



<h6 class="wp-block-heading"><strong>d. Develop a benefit calculator that shows participation and marginal effective tax rates including passported benefits. </strong></h6>



<p class="wp-block-paragraph">It is a sign of just how fragmented passported benefits schemes are that the Government does not maintain its own public-facing benefits calculator showing all passported benefits on GOV.UK. Bizarrely, the Money and Pensions Service, which is a government-funded non-departmental public body sponsored by the DWP, does have a reasonably comprehensive benefits calculator including several passported benefits schemes on its MoneyHelper site, but this is not embedded or signposted on the relevant GOV.UK benefits calculators page.<a href="#_edn235" id="_ednref235"><sup>[235]</sup></a></p>



<p class="wp-block-paragraph">External benefits calculators integrate some passported benefits and show whether claimants are better off working more, but none are exhaustive, showing income thresholds at which eligibility is withdrawn. It is the Government’s responsibility to make the consequences of its policy decisions clear so that claimants can make informed decisions about their lives. Claimants should not effectively have to carry out their own econometric modelling to understand what the best choice is.</p>



<h5 class="wp-block-heading"><strong>3.</strong> <strong>Roll regular passported benefits into UC awards.</strong>&nbsp; </h5>



<p class="wp-block-paragraph">Any passported benefit scheme that provides regular effective income-replacement to subsidise living costs should be consolidated into the relevant UC element. Known as the cashing-up approach, it provides far more flexibility for households to make their own decisions about where to spend or save rather than artificially skewing them towards decisions that may not be in their particular best interests. This delivers on the original intent behind UC: to make it a payment that covers all essential daily living costs. With the final end of migration from legacy benefits to UC within reach, now is the opportune moment to prepare a redesign within UC.</p>



<p class="wp-block-paragraph">Radical consolidation would put levers determining all regular income replacement in the hands of the Secretary of State for Work and Pensions so that rates can be varied to reflect labour market and fiscal conditions in a single stroke rather than waiting years for individual policies to be reviewed while suffering the unintended consequences in DWP budgets. It also smoothes the path into employment by removing the arbitrary, lagging income thresholds at which support is suddenly withdrawn and avoids a large cliff-edge at the end of UC entitlement by tapering off proportionally.</p>



<p class="wp-block-paragraph">Likewise, the government should review how the impact of adding to any elements affects those hitting the benefit cap. There are widespread exemptions to the cap which need separate attention and there will be changes this year in numbers reaching the cap after the&nbsp; lifting the two child limit. The government should review these policies in the round alongside the sufficiency review to assess additional incentives there should be for those with high awards to seek work or move to less expensive areas.</p>



<h6 class="wp-block-heading"><strong>a. Review the sufficiency of UC elements. </strong></h6>



<p class="wp-block-paragraph">When UC rates were first set, there was no process to determine at what level they should be set and why. They largely carried over the nearest equivalent legacy benefit rate. Since then, there have been various calls to implement a form of Minimum Income Standard which sets out the minimum socially acceptable standard of living which benefit rates should reflect. However, due to the lack of proper accounting for what claimants actually pay for at the moment when passported benefits are included, these standards have set the wrong baseline for effective income.</p>



<p class="wp-block-paragraph">With the new dataset proposed, the government can make a comprehensive assessment of the sufficiency of UC payments, passported benefits, earned income and discretionary support. This can provide the basis of where any scheme funding may need to be distributed if passported benefits are consolidated into core benefit payments. To make this credible, the Government first needs to understand what rates currently cover that would need to be paid out of pocket by claimants if passported schemes no longer existed.</p>



<p class="wp-block-paragraph"><strong>Figure 12 &#8211; Consolidation of passported benefits into UC elements</strong></p>



<p class="wp-block-paragraph"><em>Source: Onward analysis</em></p>



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<p class="wp-block-paragraph"></p>



<h6 class="wp-block-heading"><strong>b. Consolidate free school meals and the food component of the Holiday Activities and Food Programme into the UC child element, and abolish the extended right to free home-school-transport. </strong></h6>



<p class="wp-block-paragraph">These two separate schemes create an uneven effective subsidy through the year, with periods where parents are able to access neither during parts of the school holidays. By consolidating into the child element as cash rather than an in-kind benefit, parents will have consistent income through the year to cover this cost.</p>



<p class="wp-block-paragraph">Typical per day funding for HAF commissioned by local authorities is £5-7 across six weeks, so evening this out over the full 13 week school holiday is not dissimilar to the free school meals implied per-meal value of £2.61. As there is no up to date data on what proportion of eligible children are attending HAF and for how many days per school holiday, it is not possible to quantify the amount that would be needed to effectively cover full free school meals taken-up during the holidays. Funding for the activities element is dealt with below.</p>



<p class="wp-block-paragraph">Given the Universal Infant Free School Meals policy, short of bringing this into means-testing too, the rate should simply be varied by age of child to apply a lower rate for infants equivalent to the HAF value only. Evaluation of the policy in England suggests that spending on food fell by about £230 a year, compared with a cost of £437 for a year’s worth of meals.<a href="#_edn236" id="_ednref236"><sup>[236]</sup></a> This indicates that families were likely able to increase the quantity or quality of food at home, but it could also point to not all the free school food being consumed. With the same value in cash, parents could have instead chosen food their infant would eat, nutritionally balanced against other meals in the day. Non-passported benefits were beyond the scope of this review, but this and the new free school breakfasts policy should urgently be evaluated to compare against a means-tested, fully fungible system as outlined here.</p>



<p class="wp-block-paragraph">With the expansion of free school meals to all children in families on UC next year, there is an opportunity to rethink the necessity of passporting free home-to-school transport to this cohort at all. The total cost of home-to-school transport is already bankrupting councils, while taking little account of widely variable real-world routes to and from school. There is an urgent need to address eligibility for SEND transport and costs, which may come in the wider review of SEND provision this year, but this is beyond the scope of this paper.</p>



<p class="wp-block-paragraph">The UC child element is already designed to cover costs associated with raising children. With neither Scotland nor Wales implementing an equivalent policy, despite longer average journeys to school, there is no inherent justification to keep this policy in England. The general duty to provide the extended right should be removed in favour of discretionary assistance by exception for this cohort. The universal rules providing free school transport from three miles and above would remain.</p>



<p class="wp-block-paragraph">Non-claimant families make difficult compromises about where to live to get their children to school, many of whom may be working much longer hours and therefore less able to take their children themselves. Claimant families should face the same set of basic choices, moving if they cannot reasonably afford their travel costs or want to choose a school that is not in the top three closest.</p>



<h6 class="wp-block-heading"><strong>c. Consolidate the Sure Start Maternity Grant and Healthy Start into the UC child element for 0-4 year olds</strong>. </h6>



<p class="wp-block-paragraph">The Sure Start Maternity Grant and Healthy Start are both effectively fully fungible income top-ups with no evidence of health-based benefits. Parents are already using Healthy Start cards to more generally cover food and supplies for their children outside the rules of the scheme. It is possible to tie both these policies into the child element if desired, adding existing rates to age and number of children or more generally frontloading awards by age.</p>



<p class="wp-block-paragraph">Additional awards pre-birth could even be included, for example, by a valid Maternity Exemption certificate confirming pregnancy triggering payment of the UC child element in the final one or two assessment periods before birth if there are no other children in the household. While Maternity Exemption certificates do not currently state whether a multiple birth is expected, this simple field could be added and confirmed at the 12-week scan. First, there is a need to properly evaluate whether either scheme is delivering better outcomes for parents and children alike to understand the right level of support at different early years stages.</p>



<h6 class="wp-block-heading"><strong>d. Consolidate the activities component of the Holiday Activities and Food Programme and the childcare hours for extra support offer two year olds into the UC childcare element</strong>. </h6>



<p class="wp-block-paragraph">Given how low HAF take-up is, especially among secondary school age pupils, it is clear that the present offer is not appealing or readily available enough to eligible children. The activities element of the programme is effectively childcare by another name. UC claimants already have a reimbursement mechanism to claim back up to 85% of childcare costs from registered providers.</p>



<p class="wp-block-paragraph">Only holiday childcare clubs for those under eight years old currently have to be Ofsted registered. The Department for Education should review the regulations determining what type of providers can become registered childcare providers to provide flexibility for more holiday clubs to be included up to the usual caps to avoid abuse from claims for excessively expensive activities. Claimants can pay for consumables like meals in the same way as other families, paying with the cash provided in their child element.</p>



<p class="wp-block-paragraph">Likewise, take-up and attendance from those receiving the extra support offer at age two is low. To capture the disadvantaged two year olds offer within UC, the government should consider expanding eligibility for the UC childcare element to those in the conditionality regime of “Preparing for Work”. This could be limited to those in that regime who have a child aged two in their household to prevent those in the regime for other reasons using the offer. Parents on UC with children aged two are automatically placed in this conditionality regime and only required to undertake minimal work-related activities, such as writing a CV or undertake some training.</p>



<p class="wp-block-paragraph">This change helps to tie receipt of subsidised childcare to at least some form of work-related activity. Parental worklessness in the long term is widely acknowledged as one of the most significant factors in long term life chances.<a href="#_edn237" id="_ednref237"><sup>[237]</sup></a> Asking parents to meet a small proportion of the cost through the UC childcare element like other working families and take minor steps towards working is a reasonable expectation. In addition, there being at least some financial cost to parents may help to reduce non-attendance rates and make it less confusing having to separate out which hours are billed for which purpose.</p>



<h6 class="wp-block-heading"><strong>e. Consolidate the Vulnerable Students Bursary into the Discretionary Bursary part of the 16-19 Bursary Fund.</strong> </h6>



<p class="wp-block-paragraph">While it may be better in terms of direct tie to education based-costs that the EMA predecessor scheme, the passported Vulnerable Students Bursary still does not fundamentally change the incentive to claim rather find part time work or work-based training while in non-advanced education, which has been proven to damage long-term outcomes.</p>



<p class="wp-block-paragraph">Those between 16 and 17 who are unable to live with their parents are already given special dispensation to claim UC, paid at the under 25s rate of standard allowance. The standard allowance is designed to pay for essential living costs, with care leavers already paid the over 25s adult rate of UC and other normal elements available to those with children or health conditions. There is no substantive reason to expect that living expenses are considerably higher for those learning rather than working in that age bracket, with those working expected to pay for their own travel, work clothing, food and so on.</p>



<p class="wp-block-paragraph">Education providers can still provide support on a case-by-case basis to those on low incomes through the Discretionary Bursary. Crucially providers are allowed to apply conditions to these bursaries, such as attendance, meaningful engagement and behaviour standards. This means that unlike for the Vulnerable Students Bursary, claimants cannot apply for funding based on the first few weeks’ expenses, receive the bursary and then disengage from learning.&nbsp;</p>



<h6 class="wp-block-heading"><strong>f. Abolish the Warm Home Discount, with any necessary income-replacement met by UC. </strong></h6>



<p class="wp-block-paragraph">The radical potential of removing policy-imposed costs from energy bills is being seen this April with the annual average energy bill expected to drop considerably. Measures to remove any link to property or household composition from this year now make the Warm Home Discount rebate a blunt income-replacement measure, delivered at an arbitrary one-off point each year, usually well into winter.</p>



<p class="wp-block-paragraph">If the Government deems that energy bills as part of daily living costs are not sufficiently accounted for in UC then it should change the rates accordingly (principally through the standard allowance or through the child element if it wanted to account for likely larger properties). If it wants energy suppliers to contribute to this cost, then it should make the conscious choice to levy them and be upfront about the consequences for bills.</p>



<p class="wp-block-paragraph">Any necessary income replacement would provide a smoother effective bill reduction, meaning that there is less incentive to avoid turning on the heating when it might be necessary or else falling into debt in the run up to Christmas while waiting for the rebate to appear. If companies wish to offer lower energy rates to avoid customer arrears, these should be offered on the open market, encouraging competition which all can benefit from.</p>



<h6 class="wp-block-heading"><strong>g. Abolish income-related WaterSure and mandatory water social tariffs, with specific medical needs met by PIP and any necessary income-replacement by UC. </strong></h6>



<p class="wp-block-paragraph">WaterSure has been directly working against the two-child limit, unchecked for years. With the limit lifting this April, there is even less rationale for keeping this policy in place at the expense of other bill-payers. With water bills due to soar over the next few years due to Government-imposed changes, it is all the more imperative that as many extra costs as possible are removed in the interests of all consumers.</p>



<p class="wp-block-paragraph">PIP is explicitly supposed to cover the extra day-to-day costs associated with long term health conditions. If severe enough to affect washing, bathing, managing the toilet or other functions, all of the medical conditions listed under WaterSure would qualify. If PIP descriptors are not adequately reflecting these costs, then that is a matter for PIP reform, rather than a duty that should be imposed on water companies.</p>



<p class="wp-block-paragraph">If current or expected rises in water bills are deemed to have a sufficient impact on essential living costs for those on UC, then this should be reflected in UC awards, not elsewhere (in the standard allowance for adults in the household and the child element for children). And if the Government wants water companies to meet some of this cost despite the current state of the market then it should levy them accordingly rather than involve them in benefit delivery in such a piecemeal way. Suppliers could still target their own schemes at specific customers if they wished and would still need to provide Ofwat regulated debt support.</p>



<h6 class="wp-block-heading"><strong>h. End shadow-regulation for broadband social tariffs, with any necessary income-replacement met by UC. </strong></h6>



<p class="wp-block-paragraph">Passported broadband social tariffs may not be formally regulated in the same way as water or energy companies, but there has long been a veiled threat to suppliers that if they did not boost their social tariff offer, they would face intervention from Ofcom.<a href="#_edn238" id="_ednref238"><sup>[238]</sup></a> However, it is clear that social tariffs are lulling claimants into the false perception that they do not need to switch tariffs to get the best deals like everyone else. It also encourages purchasing packages beyond what smaller households may need, for whom a 4g or 5g hotspot may be adequate.</p>



<p class="wp-block-paragraph">In the same way as for the other utilities where regulation for social tariffs is proposed to be abolished, there should be an explicit shift away from this effective mandation, instead meeting any necessary additional income-replacement through UC.</p>



<h6 class="wp-block-heading"><strong>i. Abolish local council tax reduction schemes and create an additional Council Tax element in UC</strong>.</h6>



<p class="wp-block-paragraph"> Council tax is widely regarded as one of most regressive taxes in the UK, drawing on property values from 35 years ago.<a href="#_edn239" id="_ednref239"><sup>[239]</sup></a> Wider options for reforming council tax itself are beyond the scope of this analysis, but it should be noted that a significant restructure of local government is currently underway, including merging councils into unitary authorities and imposing full council tax grant equalisation which will hit councils with historically low council tax the hardest.</p>



<p class="wp-block-paragraph">As with the other household bills in this proposal, council tax reduction should likewise be consolidated into UC awards to avoid the present double-taper effect. The Institute for Fiscal Studies estimates that integrating council tax support into UC would mean that practically no workers faced marginal effective tax rates of over 75%. While this modelling does not account for other passported benefits, it still shows that consolidation would be a hugely significant step forward for work incentives.<a href="#_edn240" id="_ednref240"><sup>[240]</sup></a></p>



<p class="wp-block-paragraph">As the archaic banding system for setting council tax is not reflected in any existing UC elements, a new element is proposed, which could be capped at Band B or C properties in each council area. A Band C cap would usually include modest two to three bedroom family homes, a Band B cap would typically cover one to two bedroom properties, but there is wide variation across the country. The latter would have a stronger effect on those in more expensive properties moving to other areas if they could not afford the total rent and council tax liability, but could also tip some councils in mass arrears. To lessen any initial income shock for those suddenly outside of support, a Band C may be preferable during current reorganisations, with a view to overhauling council tax in the round.&nbsp;&nbsp;</p>



<h6 class="wp-block-heading"><strong>j. Abolish Help to Save and add a sidecar savings deduction to the UC deductions mechanism.</strong></h6>



<p class="wp-block-paragraph"><strong> </strong>Building up financial resilience through savings is vital to avoiding the need for crisis support, but Help to Save is creating perverse incentives. UC is meant to cover essential living costs, not enable a significantly more generous financial booster than any savings account in the private market. Incentivising claimants not to pay down their debts in the first instance to avoid interest accruing is potentially embedding damaging habits that will lessen their resilience in the long term.</p>



<p class="wp-block-paragraph">Instead, the government should allow working UC claimants to have part of their claim deducted into a sidecar savings account. Similar to credit unions still run by some large employers, sidecar savings schemes (also known as rainy-day or “jars” schemes) are savings accounts where small deductions are taken each month from payroll or bank accounts to be set aside into a liquid and a long-term jar. Contributions first go into the liquid jar up to a cap, before rolling over into the long term jar. The liquid jar is easily accessible without penalty for unexpected expenses, whereas the long-term jar has more friction and penalties for withdrawing early, like loss of interest.</p>



<p class="wp-block-paragraph">The Department for Work and Pensions has already sponsored work on this type of scheme, including through NEST Insight, which ran several trials exploring payroll-based deductions&nbsp; and tested opt-out versus opt-in mechanisms.<a href="#_edn241" id="_ednref241"><sup>[241]</sup></a> Employers including Timpson, BT, ITV, StepChange and the Co-op took part.</p>



<p class="wp-block-paragraph">To make sure that those in unstable work or not in work also build up savings habits are included in a scheme, while not encouraging debt, sidecar savings should be added to the UC deductions priority order. The deduction priority order determines in what order deductions can be taken from a UC award to pay off debts, including UC advance payments, bill arrears, child maintenance payments and fines. The amount is capped at 15% of the standard allowance for those going to third parties and no more than three separate deductions are made at the same time.<a href="#_edn242" id="_ednref242"><sup>[242]</sup></a></p>



<p class="wp-block-paragraph">A sidecar savings deduction should be added to the bottom of the deductions priority order, so that those with low or no debts have a small portion of their award automatically put into jars for a rainy day. By embedding this within the existing deductions regime, those who have existing debts will effectively not be eligible, so there is no artificial reward for delaying repayments. It far better simulates real-world savings habits while not leaving it up to chance as to whether a claimant’s employer runs a scheme.&nbsp;</p>



<h5 class="wp-block-heading"><strong>4. Consolidate or harmonise schemes for unforeseen or unavoidable costs.</strong> </h5>



<p class="wp-block-paragraph">Eligibility for help with isolated costs for those on low incomes should follow a basic set of rules controlled by the Secretary of State for Work &amp; Pensions. It is not possible to roll these all together in the same way as for UC as they have complex additional eligibility criteria, but there are ways to rationalise how support is allocated, taking a household budget and cashflow approach rather than treating a single symptom of financial distress.</p>



<p class="wp-block-paragraph">There should be a common framework for determining when a household’s disposable income or gross income is considered insufficient to meet an unexpected cost, rather than multiple different ways to test this. Assessments of income should always look at the total income including benefits, not just earned income. It should also include whether someone could reasonably have been expected to take their own steps to avoid incurring an expense they cannot meet in the first place or expect that they reduce their outgoings to meet the expense in the longer term through a loan or advance.&nbsp;</p>



<p class="wp-block-paragraph"><img decoding="async" width="464" height="0" src=""><img decoding="async" width="302" height="0" src=""><strong>Figure 13 &#8211; Consolidation of passported benefits and discretionary schemes into the Crisis and Resilience Fund</strong></p>



<div class="flourish-embed flourish-network" data-src="visualisation/27339724"><script src="https://public.flourish.studio/resources/embed.js"></script><noscript><img decoding="async" src="https://public.flourish.studio/visualisation/27339724/thumbnail" width="100%" alt="network visualization" /></noscript></div>



<h6 class="wp-block-heading"><strong>a. Consolidate the Flexible Support Fund and other local welfare schemes into the Crisis and Resilience Fund. </strong></h6>



<p class="wp-block-paragraph">With the merger of Discretionary Housing Payments and the Household support fund, the Flexible Support Fund has been left an outlier. Funding for work-seeking purposes that someone would otherwise be unable to meet has a clear link to promoting long term financial resilience. Rolling this type of expense in will help put focus on work as a way of avoiding crisis for all those seeking to draw from the Crisis and Resilience Fund. It could still be used by Jobcentres too, through a partnership arrangement with councils.</p>



<p class="wp-block-paragraph">More generally with the discretionary schemes, there will always be an efficiency case for retaining some ability to quickly give out petty cash in certain circumstances without needing to undertake a full assessment of means to pay, but this should not be unlimited. To give a sense of fairness to council taxpayers, an annual household cap could be set at the annual council tax rate for an average Band D property in the area. This should incentivise using funds to avoid recurring claims, focussing on helping those claiming become financially independent. Councils would still be allowed to assess income for lower payment amounts as appropriate depending on the claim.</p>



<p class="wp-block-paragraph">Councils should also rationalise other local welfare-based offers into the Crisis and Resilience Fund for items like school uniform or bulky waste collection charges. For leisure and other activities, they should only automatically passport eligibility to services that are net-neutral or -negative in cost to council taxpayers. For example, if half price swimming pool access is offered to claimants and this still meets the unit cost of providing the service or it drives up use of the pool sufficiently to cover costs, this would be net-neutral. In some areas, this may require renegotiating concessions structures with Local Authority Trading Companies.</p>



<p class="wp-block-paragraph">Private companies can use their own discretion to passport eligibility to claimants and these can be listed on the council’s website, but they should offset the cost to other customers themselves rather than be subsidised by council taxpayers.</p>



<h6 class="wp-block-heading"><strong>b. Consolidate the Funeral Expenses Payment and Court Fee Remission into the Crisis and Resilience Fund. </strong></h6>



<p class="wp-block-paragraph">Alongside their duties to provide Public Health funerals, Funeral Expense Payments should move back to local level, with accompanying regulation to mandate the current minimum standards of provision. The average cost of a Public Health funeral is almost identical to the average cost of the Funeral Expense Payment.<a href="#_edn243" id="_ednref243"><sup>[243]</sup></a></p>



<p class="wp-block-paragraph">If fewer people default into needing a Public Health funeral due to being ineligible for the Funeral Expense Payment from the rigid relationship hierarchy, then a more dignified send off could be provided to some at no inherent additional cost. Routing this support through the Crisis and Resilience Fund could help to ensure that those experiencing a sudden change in circumstances due to the loss are better signposted to local support and discretionary funding if they need it.</p>



<h6 class="wp-block-heading"><strong>c. Abolish the Warm Home Discount “Industry Initiatives&#8221; and the Energy Company Obligation, and consolidate the Warm Homes offer and the Cold Weather Payment into the Crisis and Resilience Fund. </strong></h6>



<p class="wp-block-paragraph">The awkward “Industry Initiatives&#8221; part of the Warm Home Discount is largely needless duplication of other energy efficiency-focussed schemes, including the Energy Company Obligation. Rather than replace the Energy Company Obligation with another supplier-funded scheme, it should be consolidated into the Crisis and Resilience Fund.</p>



<p class="wp-block-paragraph">Installing energy efficiency measures meets the aim of providing longer term financial resilience to claimants by permanently lowering their bills. The low-income scheme within the Warm Homes Plan should be folded into this fund too, creating a single scheme for applying for energy efficiency improvement funding. This means that when people present to the Crisis and Resilience Fund due to problems paying their energy bills, rather than just offer a temporary cash solution, they can immediately be offered a more sustainable solution. Likewise, Cold Weather Payments should also be added to this pot, incentivising those in areas with repeated triggers to take permanent steps to keep their homes warmer.</p>



<h6 class="wp-block-heading"><strong>d. Use the same income test for Legal Aid and court fee remission as for other one-off costs. </strong></h6>



<p class="wp-block-paragraph">It has been over five years since the legal aid means test review commenced, but some measures have still not been implemented. There are a number of reasons why it is necessary to keep Legal Aid separate from other one-off cost support schemes like the Crisis and Resilience Fund, not least because a significant number of cases brought by claimants are likely to be against the local authority itself, causing a conflict of interest. However, income testing could still use the same assessment of disposable and total income as for other one-off costs in the Crisis and Resilience Fund.</p>



<h6 class="wp-block-heading"><strong>e. Consider abolishing prescription charges.</strong> </h6>



<p class="wp-block-paragraph">Prescription charge exemptions are near universal. Any policy for which 96% of the time it does not apply is not the policy at all &#8211; it is the exception. The income threshold leaves those on UC trying to work while managing health conditions but who fall outside medical exemption categories facing some months with and some months without charges.</p>



<p class="wp-block-paragraph">Unlike other passporting benefits, there is no obvious UC gateway for including these costs in awards when the cost falls so unevenly on different claimants. Consolidating it into the UC health element would not be desirable when a claimant may face a limited period of high prescription incidence but this does not affect their capability for work.</p>



<p class="wp-block-paragraph">Rather than seek to tinker further with the exemptions list, the Government should consider simply abolishing prescription charges altogether, as is the policy in Wales and Scotland. This comes with a high notional cost of around £500 million. However, evidence from organisations including the Royal Pharmaceutical Society, the Nuffield Trust and the Kings Fund all point to this cost being at least partially offset by lower downstream health costs. It could also be used to spur wider behavioural change in how the NHS is used if coupled with other systems shifts like greater use of prescribing pharmacists rather than taking up GP appointments. This will need attention beyond the scope of this paper, alongside the rest of the Help with Health Costs schemes.</p>



<h5 class="wp-block-heading"><strong>5. Lower the UC taper to 50%. </strong></h5>



<p class="wp-block-paragraph">The high proportion of people on UC with no work requirements is a sign of both how relatively more generous incapacity benefits and PIP are, but also how punitive UC is for those in work. When factoring in the passported benefits that people then lose as they earn more, it becomes very difficult to calculate from month to month whether claimants are better off working more. The conclusion for many is that it is simply not worth the risk trying to work if the path to progression is unclear at best, even if in reality there may be income tests to retain support for those not on benefits.</p>



<p class="wp-block-paragraph">The lower the taper, the lower the marginal effective tax rate and the stronger the incentive to steadily increase hours or seek higher pay, slowly moving off benefits. The tax system, which treats people as individuals rather than households like the benefits system, will always be difficult to harmonise entirely with benefits in order to totally smooth incentives once the income tax and National Insurance threshold kicks in at £12,500. Lowering the taper rate is nevertheless the best lever to set the baseline from which any additional deductions are then made.</p>



<p class="wp-block-paragraph">Lowering the taper is expensive, as it takes longer for benefit awards to reduce to £0. When the work allowance was raised to £500 and the taper was cut from 63% to 55% following the autumn Budget in 2021, it was estimated to cost just under £3 billion by 2026/27.<a href="#_edn244" id="_ednref244"><sup>[244]</sup></a> Previous analysis by the Centre for Policy Studies in 2018 estimated a cost of £362 million per 1p reduction in the taper alone, giving a cost of £1.8 billion for a 5p cut.<a href="#_edn245" id="_ednref245"><sup>[245]</sup></a> The caseload, case mix and rates of UC have changed considerably since then, but this is still a desirable policy to pursue.&nbsp;</p>



<p class="wp-block-paragraph">Given the scale of the other changes proposed, there is no current model that can simulate the impact of these changes taken together. As this report sets out, those coming off the taper have always faced a hidden cliff-edge from passported benefits withdrawal at the end of their claim or midway along the taper, making it far riskier to increase working hours or pay.</p>



<p class="wp-block-paragraph">Claimants earning above the income tax and National Insurance personal allowance will still face marginal effective tax rates of more than 50%. Short of redesigning the tax system to treat people as households rather than individuals for tax purposes or hugely raising the personal allowance, there is no easy way to reconcile this. Cutting the taper at least lessens the impact of the deductions stacking. If the fiscal position allows after the sufficiency and policy costs review, then this is a cost worth bearing to fundamentally reset incentives.</p>



<h3 class="wp-block-heading"><strong>Conclusion</strong></h3>



<p class="wp-block-paragraph">Universal Credit was intended to reshape the relationship between the individual and the welfare system. It was built on the right principles, to streamline support into a smooth path in which work would always pay. Since then, the vision has been pulled off course by paternalism and perverse incentives. Schemes are continuing to expand and fragment further away from the main levers of control over welfare spending. A strategy to tackle poverty and end worklessness is impossible to deliver when policy implementation has become so diffuse.</p>



<p class="wp-block-paragraph">Most people will be familiar with at least a couple flagship passported benefit schemes outlined in this paper. They are popular with the public and irresistible to politicians looking for positive news. Few will have been aware of their full extent. While on their own, schemes look well-meaning and harmless, together they push against the human instinct to work hard for a better life. When the cumulative result is that claimants cannot trust that working more will make them better off or are left unaware of support at all, this is not compassion, it is a trap.</p>



<p class="wp-block-paragraph">Exposing a welfare system that effectively spends £10 billion more than headline figures suggest should be a wake-up call to those running it. With the end of legacy benefits in sight, the moment to start preparing for a hard reset must not be missed. The radical rationalisation set out in this paper offers a route back to the original promise: a single intelligible system in which people can see what they are entitled to, understand the gains from work, and plan their own lives without fear of hidden cliff edges.</p>



<p class="wp-block-paragraph">The core recommendation is to regain control over income-replacement by consolidating multiple passported benefits into different parts of UC. It also outlines a more consistent approach to help those in crisis to build back their financial resilience. And the potential savings offer the opportunity to reduce the penalty that working claimants face that undermine progression towards financial independence from benefits. These changes should be matched by stronger work incentives with a lower UC taper to reduce the effective marginal deduction rates.</p>



<p class="wp-block-paragraph">Ultimately, the public can only hold ministers and parliamentarians accountable for a system they can understand. That is why rationalisation must be accompanied by transparency: a single view of cumulative entitlements; routine publication of cross-government impacts; and a new way to measure income and outgoing. It will take courage and discipline to avoid the lure back to obfuscation. The prize is a welfare state that is cheaper to administer, simpler to explain &#8211; and most importantly &#8211; easier for claimants to leave behind.</p>



<p class="wp-block-paragraph"></p>



<h4 class="wp-block-heading">Endnotes</h4>



<hr class="wp-block-separator has-alpha-channel-opacity"/>



<p class="wp-block-paragraph"><a href="#_ednref1" id="_edn1"><sup>[1]</sup></a> Department for Work &amp; Pensions, <em>Universal Credit: Welfare that Works, </em>November 2010<a href="https://assets.publishing.service.gov.uk/media/5a79581640f0b63d72fc4fd9/universal-credit-full-document.pdf">link</a>.</p>



<p class="wp-block-paragraph"><a href="#_ednref2" id="_edn2"><sup>[2]</sup></a> Department for Work &amp; Pensions, <em>Latest update: Move to UC, LA Welfare Direct 9/2023, </em>December 2023<a href="https://www.gov.uk/government/publications/la-welfare-direct-bulletins-2023/la-welfare-direct-92023#latest-update-move-to-uc">link</a>.</p>



<p class="wp-block-paragraph"><a href="#_ednref3" id="_edn3"><sup>[3]</sup></a> Department for Work &amp; Pensions Careers, <em>Putting data at the heart of the country’s challenges</em>, Retrieved January 2026 <a href="https://careers.dwp.gov.uk/our-teams/dwp-digital-data-science/">link</a>.</p>



<p class="wp-block-paragraph"><a href="#_ednref4" id="_edn4"><sup>[4]</sup></a> Department for Work &amp; Pensions, <em>Households below average income series: quality and methodology information report FYE 2023</em>, March 2025 <a href="https://www.gov.uk/government/statistics/households-below-average-income-for-financial-years-ending-1995-to-2023/households-below-average-income-series-quality-and-methodology-information-report-fye-2023">link</a>; Department for Work &amp; Pensions, <em>Family Resources Survey: Background Information and Methodology</em>, January 2026 <a href="https://www.gov.uk/government/statistics/family-resources-survey-financial-year-2023-to-2024/family-resources-survey-background-information-and-methodology#statistical-presentation">link</a>.</p>



<p class="wp-block-paragraph"><a href="#_ednref5" id="_edn5"><sup>[5]</sup></a> Social Metrics Commission, <em>Measuring Poverty: A New Measure of Poverty for the UK</em>, September 2018 <a href="https://socialmetricscommission.org.uk/wp-content/uploads/2019/07/SMC_measuring-poverty-201809_full-report.pdf">link</a>.</p>



<p class="wp-block-paragraph"><a href="#_ednref6" id="_edn6"><sup>[6]</sup></a> Department for Work &amp; Pensions, <em>Free School Meals: Expansion to All Children on Universal Credit – Impact on Individual and Child Poverty Levels and Number of Children in Households Receiving Universal Credit</em>, June 2025 <a href="https://www.gov.uk/government/publications/free-school-meals-expansion-impact-on-poverty-levels/free-school-meals-expansion-to-all-children-on-universal-credit-impact-on-individual-and-child-poverty-levels-and-number-of-children-in-households-r">link.</a></p>



<p class="wp-block-paragraph"><a href="#_ednref7" id="_edn7"><sup>[7]</sup></a> Torres Cortés, F., Godoy Jalil, T., Hession, M. &amp; Ghelan, D., <em>Missing Out 2025: £24 Billion of Support is Unclaimed</em>, Policy in Practice<em>, </em>September 2025 <a href="https://policyinpractice.co.uk/wp-content/uploads/2025/09/MO25-24bnUnclaimed-PolicyinPractice-Sept25.pdf">link.</a></p>



<p class="wp-block-paragraph"><a href="#_ednref8" id="_edn8"><sup>[8]</sup></a> Ibid, <em>Table 1: Estimated value of unclaimed support, Great Britain 2025/26</em>, page 6 <a href="https://policyinpractice.co.uk/wp-content/uploads/2025/09/MO25-24bnUnclaimed-PolicyinPractice-Sept25.pdf">link.</a></p>



<p class="wp-block-paragraph"><a href="#_ednref9" id="_edn9"><sup>[9]</sup></a> Ibid. <a href="https://policyinpractice.co.uk/wp-content/uploads/2025/09/MO25-24bnUnclaimed-PolicyinPractice-Sept25.pdf">link.</a></p>



<p class="wp-block-paragraph"><a href="#_ednref10" id="_edn10"><sup>[10]</sup></a>&nbsp; Beatty, TKM., Blow, L., Crossley, TF. &amp; O’Dea, C, <em>Cash by any other name? Evidence on labeling from the UK Winter Fuel Payment, </em>Journal of Public Economics. Volume 118, Pages 86-96<em>,</em> October 2014, <a href="https://www.sciencedirect.com/science/article/abs/pii/S0047272714001479">link.</a>; Britton, J., Ridpath, N., Villa, C. &amp; Waltman, B. <em>The short and long-run effects of the Education Maintenance Allowance, </em>Institute for Fiscal Studies, February 2025 <a href="https://ifs.org.uk/publications/short-and-long-run-effects-education-maintenance-allowance">link.</a>&nbsp;</p>



<p class="wp-block-paragraph"><a href="#_ednref11" id="_edn11"><sup>[11]</sup></a> Hill, J., <em>Everythingism: An Essay, The Pathology Holding Back the State, Reform, </em>March 2025 <a href="https://reform.uk/wp-content/uploads/2025/03/Everythingism-an-essay.pdf">link.</a></p>



<p class="wp-block-paragraph"><a href="#_ednref12" id="_edn12"><sup>[12]</sup></a> The Department for Work &amp; Pensions, <em>Universal Credit: The Impact on Passported Benefits: Report by the Social Security Advisory Committee and Response by the Secretary of State for Work and Pensions, </em>March 2012 <a href="https://assets.publishing.service.gov.uk/media/5a74fd8eed915d3c7d5298a3/ssac-rev-of-pass-bens.pdf">link.</a></p>



<p class="wp-block-paragraph"><a href="#_ednref13" id="_edn13"><sup>[13]</sup></a> The Department for Work &amp; Pensions, <em>Universal Credit Statistics, 29 April 2013 to 10 July 2025, </em>December 2025<em>, </em><a href="https://www.gov.uk/government/statistics/universal-credit-statistics-29-april-2013-to-10-july-2025/universal-credit-statistics-29-april-2013-to-10-july-2025#households-on-universal-credit">link.</a><em></em></p>



<p class="wp-block-paragraph"><a href="#_ednref14" id="_edn14"><sup>[14]</sup></a> Ibid. <a href="https://www.gov.uk/government/statistics/universal-credit-statistics-29-april-2013-to-10-july-2025/universal-credit-statistics-29-april-2013-to-10-july-2025#households-on-universal-credit">link.</a></p>



<p class="wp-block-paragraph"><a href="#_ednref15" id="_edn15"><sup>[15]</sup></a> Ray-Chaudari, S. &amp; Waters, T., <em>Universal Credit: Incomes, Incentives and the Remaining Roll-out, </em>Institute for Fiscal Studies, June 2024, <a href="https://ifs.org.uk/publications/universal-credit-incomes-incentives-and-remaining-roll-out">link.</a></p>



<p class="wp-block-paragraph"><a href="#_ednref16" id="_edn16"><sup>[16]</sup></a> Ibid. <a href="https://ifs.org.uk/publications/universal-credit-incomes-incentives-and-remaining-roll-out">link.</a> Sample includes all working individuals in families entitled to legacy benefits or Universal Credit, with an adult aged below SPA. IFS calculations using TAXBEN, the IFS tax and benefit microsimulation model, and Family Resources Survey 2022–23.</p>



<p class="wp-block-paragraph"><a href="#_ednref17" id="_edn17"><sup>[17]</sup></a> Ibid. <a href="https://ifs.org.uk/publications/universal-credit-incomes-incentives-and-remaining-roll-out">link.</a></p>



<p class="wp-block-paragraph"><a href="#_ednref18" id="_edn18"><sup>[18]</sup></a> Ibid. <a href="https://ifs.org.uk/publications/universal-credit-incomes-incentives-and-remaining-roll-out">link.</a></p>



<p class="wp-block-paragraph"><a href="#_ednref19" id="_edn19"><sup>[19]</sup></a> Broadband social tariffs are not formally regulated but providers have been under threat of regulation unless they provide and promote a social tariff, with all major providers now offering one.</p>



<p class="wp-block-paragraph"><a href="#_ednref20" id="_edn20"><sup>[20]</sup></a> Onward analysis, <a href="https://github.com/ukonward/The-Hidden-Benefits-Bill/blob/main/The%20Hidden%20Benefits%20Bill%20VF.xlsx" type="link" id="https://github.com/ukonward/The-Hidden-Benefits-Bill/blob/main/The%20Hidden%20Benefits%20Bill%20VF.xlsx">link</a>. * denotes industry-funded schemes. ** denotes discretionary schemes. Claim count and average award should not be summed as no one household is likely to be eligible for all listed benefits.</p>



<p class="wp-block-paragraph"><a href="#_ednref21" id="_edn21"><sup>[21]</sup></a>&nbsp; Department for Work &amp; Pensions, <em>Pathways to Work: Reforming Benefits and Support to Get Britain Working Green Paper, </em>October 2025 <a href="https://www.gov.uk/government/consultations/pathways-to-work-reforming-benefits-and-support-to-get-britain-working-green-paper/pathways-to-work-reforming-benefits-and-support-to-get-britain-working-green-paper">link.</a> Eligibility for contributory or “new style” JSA and ESA is based on National Insurance contributions, designed to support those who have recently been employed. There are separate proposals to reform these into a new form of unemployment insurance.</p>



<p class="wp-block-paragraph"><a href="#_ednref22" id="_edn22"><sup>[22]</sup></a> Where UC-only eligibility figures are available, these are used. Otherwise, all those eligible via working-age income-related benefits are treated as if eligible via UC as these would likely retain eligibility via migration to UC in the next few years.</p>



<p class="wp-block-paragraph"><a href="#_ednref23" id="_edn23"><sup>[23]</sup></a> The Department for Work &amp; Pensions, <em>Universal Credit Work Capability Assessment statistics, April 2019 to September 2025, </em>December 2025 <a href="https://www.gov.uk/government/statistics/universal-credit-work-capability-assessment-statistics-april-2019-to-september-2025/universal-credit-work-capability-assessment-statistics-april-2019-to-september-2025">link.</a></p>



<p class="wp-block-paragraph"><a href="#_ednref24" id="_edn24"><sup>[24]</sup></a> Ibid. <a href="https://www.gov.uk/government/statistics/universal-credit-work-capability-assessment-statistics-april-2019-to-september-2025/universal-credit-work-capability-assessment-statistics-april-2019-to-september-2025">link.</a></p>



<p class="wp-block-paragraph"><a href="#_ednref25" id="_edn25"><sup>[25]</sup></a> The Department for Work &amp; Pensions, <em>Pathways to Work: Reforming Benefits and Support to Get Britain Working Green Paper</em>, October 2025 <a href="https://www.gov.uk/government/consultations/pathways-to-work-reforming-benefits-and-support-to-get-britain-working-green-paper/pathways-to-work-reforming-benefits-and-support-to-get-britain-working-green-paper">link.</a></p>



<p class="wp-block-paragraph"><a href="#_ednref26" id="_edn26"><sup>[26]</sup></a> UK Parliament, <em>Written questions, answers and statements: Sir Stephen Timms MP in response to a written question from Chris Law MP, </em>September 2025<a href="https://questions-statements.parliament.uk/written-questions/detail/2025-09-08/75648">link.</a></p>



<p class="wp-block-paragraph"><a href="#_ednref27" id="_edn27"><sup>[27]</sup></a> Department for Work &amp; Pensions, <em>Pathways to Work: Reforming Benefits and Support to Get Britain Working Green Paper, Annex A: Summary of Policy Measures and Consultation Questions</em>, October 2025 <a href="https://www.gov.uk/government/consultations/pathways-to-work-reforming-benefits-and-support-to-get-britain-working-green-paper/pathways-to-work-reforming-benefits-and-support-to-get-britain-working-green-paper#annex-a-summary-of-policy-measures-and-consultation-questions">link.</a></p>



<p class="wp-block-paragraph"><a href="#_ednref28" id="_edn28"><sup>[28]</sup></a> For example, Hempsell, L. Motability won&#8217;t give up its lucrative business without a fight, The Spectator, June 2025, <a href="https://spectator.com/article/motability-wont-give-up-its-lucrative-business-without-a-fight/">link.</a>; Ryder, M. &amp; Palmer, M., <em>Reverse Gear: Why Motability is Broken and How to fix it</em>, The Adam Smith Institute, 2025 <a href="https://static1.squarespace.com/static/56eddde762cd9413e151ac92/t/68c1b78edb28793e587820d3/1757525902789/Reverse_Gear-Matt_Ryder_%26_Mitchell_Palmer-Adam_Smith_Institute-September%2B2025.pdf?utm_source=chatgpt.com">link.</a></p>



<p class="wp-block-paragraph"><a href="#_ednref29" id="_edn29"><sup>[29]</sup></a> HM Treasury, <em>Budget 2025</em>, November 2025 <a href="https://www.gov.uk/government/publications/budget-2025-document/budget-2025-html">link.</a>&nbsp;</p>



<p class="wp-block-paragraph"><a href="#_ednref30" id="_edn30"><sup>[30]</sup></a> UK Parliament, <em>Response from Margaret Jackson MP in response to a written question on Free School Meals from Lynda Chalker MP</em>, December 1976 <a href="https://hansard.parliament.uk/commons/1976-12-13/debates/2eaaf4cd-ddb8-4243-ae88-76bc7259864c/SchoolMeals">link.</a>&nbsp;</p>



<p class="wp-block-paragraph"><a href="#_ednref31" id="_edn31"><sup>[31]</sup></a> Department for Education, <em>Free School Meals: Guidance for Schools and Local Authorities</em>, March 2018 (updated June 2025) <a href="https://www.gov.uk/government/publications/free-school-meals-guidance-for-schools-and-local-authorities">link.</a></p>



<p class="wp-block-paragraph"><a href="#_ednref32" id="_edn32"><sup>[32]</sup></a> Department for Education, <em>Expanding Free School Meals: What Parents Need to Know (Blog Post)</em>, June 2025 <a href="https://educationhub.blog.gov.uk/2025/06/expanding-free-school-meals-what-parents-need-to-know/">link.</a>&nbsp;</p>



<p class="wp-block-paragraph"><a href="#_ednref33" id="_edn33"><sup>[33]</sup></a> Cribb, J., Farquharson, C., McKendrick, A. &amp; Waters, T. <em>The Policy Menu for School Lunches: Options and Trade-offs in Expanding Free School Meals in England, </em>Institute for Fiscal Studies, March 2023 <a href="https://ifs.org.uk/publications/policy-menu-school-lunches-options-and-trade-offs-expanding-free-school-meals-england">link.</a></p>



<p class="wp-block-paragraph"><a href="#_ednref34" id="_edn34"><sup>[34]</sup></a> UK Parliament, <em>Update on Children with No Recourse to Public Funds, A Statement to the House of Commons by Will Quince MP</em>, March 2022 <a href="https://questions-statements.parliament.uk/written-statements/detail/2022-03-24/hcws714">link.</a></p>



<p class="wp-block-paragraph"><a href="#_ednref35" id="_edn35"><sup>[35]</sup></a> Department for Education, <em>Press Release: Over Half a Million More Children to Get Free School Meals,</em> June 2025, <a href="https://www.gov.uk/government/news/over-half-a-million-more-children-to-get-free-school-meals">link.</a></p>



<p class="wp-block-paragraph"><a href="#_ednref36" id="_edn36"><sup>[36]</sup></a> Cribb, J., Farquharson, C., McKendrick, A. &amp; Waters, T. <em>The Policy Menu for School Lunches: Options and Trade-offs in Expanding Free School Meals in England, </em>Institute for Fiscal Studies, March 2023 <a href="https://ifs.org.uk/publications/policy-menu-school-lunches-options-and-trade-offs-expanding-free-school-meals-england">link.</a></p>



<p class="wp-block-paragraph"><a href="#_ednref37" id="_edn37"><sup>[37]</sup></a> Department for Education, <em>Press Release: Over Half a Million More Children to Get Free School Meals,</em> June 2025, <a href="https://www.gov.uk/government/news/over-half-a-million-more-children-to-get-free-school-meals">link.</a></p>



<p class="wp-block-paragraph"><a href="#_ednref38" id="_edn38"><sup>[38]</sup></a> Farquharson, C. &amp; Waters T. <em>Benefits &#8211; and Costs &#8211; of Expanding Access to Free School Meals Will Grow Over Time</em>, Institute for Fiscal Studies, June 2025 <a href="https://ifs.org.uk/articles/benefits-and-costs-expanding-access-free-school-meals-will-grow-over-time">link.</a></p>



<p class="wp-block-paragraph"><a href="#_ednref39" id="_edn39"><sup>[39]</sup></a> Cribb, J., Farquharson, C., McKendrick, A. &amp; Waters, T. <em>The Policy Menu for School Lunches: Options and Trade-offs in Expanding Free School Meals in England, </em>Institute for Fiscal Studies, March 2023 <a href="https://ifs.org.uk/publications/policy-menu-school-lunches-options-and-trade-offs-expanding-free-school-meals-england">link.</a></p>



<p class="wp-block-paragraph"><a href="#_ednref40" id="_edn40"><sup>[40]</sup></a> Onward analysis. Stats Wales, <em>Pupils eligible for free school meals by local authority, region and year 2013/14-2024/25, </em>Pupil Level Annual School Census (PLASC), Retrieved January 2026 <a href="https://statswales.gov.wales/Catalogue/Education-and-Skills/Schools-and-Teachers/Schools-Census/Pupil-Level-Annual-School-Census/Provision-of-Meals-and-Milk/pupilseligibleforfreeschoolmeals-by-localauthorityregion-year">link.</a></p>



<p class="wp-block-paragraph"><a href="#_ednref41" id="_edn41"><sup>[41]</sup></a> Greater London Authority, <em>Request for Director Decision: Universal Free School Meals Programme 2025-26</em>, May 2025 <a href="https://www.london.gov.uk/media/110236/download">link.</a></p>



<p class="wp-block-paragraph"><a href="#_ednref42" id="_edn42"><sup>[42]</sup></a> Welsh Government, <em>Universal Primary Free School Meals</em>, July 2022 <a href="https://www.gov.wales/universal-primary-free-school-meals-upfsm">link.</a>&nbsp;</p>



<p class="wp-block-paragraph"><a href="#_ednref43" id="_edn43"><sup>[43]</sup></a> Welsh Government, <em>Press Release: Welsh Primary School Meals Served with a £8 Million Boost</em>, December 2025 <a href="https://www.gov.wales/welsh-primary-school-meals-served-8-million-boost">link.</a></p>



<p class="wp-block-paragraph"><a href="#_ednref44" id="_edn44"><sup>[44]</sup></a> UK Parliament, <em>Statement by Stephen Morgan MP to the House of Commons on Free School Meals</em>, June 2025 <a href="https://hansard.parliament.uk/commons/2025-06-05/debates/E0DF1D45-4AE9-4227-AE22-674EE9576812/FreeSchoolMeals">link.</a></p>



<p class="wp-block-paragraph"><a href="#_ednref45" id="_edn45"><sup>[45]</sup></a> Whittaker, F. <em>DfE Reviews Pupil Premium Amid Free Meals Extension Concerns</em>, Schools Week, June 2025 <a href="https://schoolsweek.co.uk/dfe-reviews-pupil-premium-amid-free-meals-extension-concerns/">link.</a></p>



<p class="wp-block-paragraph"><a href="#_ednref46" id="_edn46"><sup>[46]</sup></a> Department for Education, <em>Pupil Premium: Allocations and Conditions of Grant 2025 to 2026 (Guidance)</em>, March 2025 (Updated December 2025) <a href="https://www.gov.uk/government/publications/pupil-premium-allocations-and-conditions-of-grant-2025-to-2026">link.</a></p>



<p class="wp-block-paragraph"><a href="#_ednref47" id="_edn47"><sup>[47]</sup></a> The Sutton Trust, <em>NFER’s Teacher Voice Omnibus Survey: School Funding and Pupil Premium 2024, </em>April 2024 <a href="https://www.suttontrust.com/wp-content/uploads/2024/04/School-Funding-and-Pupil-Premium-2024.pdf">link.</a></p>



<p class="wp-block-paragraph"><a href="#_ednref48" id="_edn48"><sup>[48]</sup></a> Department for Education, <em>Schools Block Funding Formulae 2025 to 2026: Analysis of Local Authorities’ Schools Block Funding Formulae (Guidance)</em>, June 2025 <a href="https://www.gov.uk/government/publications/schools-block-funding-formulae-2025-to-2026/schools-block-funding-formulae-2025-to-2026-analysis-of-local-authorities-schools-block-funding-formulae">link.</a></p>



<p class="wp-block-paragraph"><a href="#_ednref49" id="_edn49"><sup>[49]</sup></a> Onward analysis. Department for Education, <em>Press Release: Thousands of Pupils Receive Support to Boost School Attendance</em>, October 2024 <a href="https://www.gov.uk/government/news/thousands-of-pupils-receive-support-to-boost-school-attendance--2">link.</a></p>



<p class="wp-block-paragraph"><a href="#_ednref50" id="_edn50"><sup>[50]</sup></a> UK Government, <em>Financial help if you have children: Free school transport</em>, Retrieved January 2026 <a href="https://www.gov.uk/free-school-transport">link.</a></p>



<p class="wp-block-paragraph"><a href="#_ednref51" id="_edn51"><sup>[51]</sup></a> Local Government Association, <em>The Future of Home to School Transport</em>, June 2025 <a href="https://www.local.gov.uk/publications/future-home-school-transport">link.</a></p>



<p class="wp-block-paragraph"><a href="#_ednref52" id="_edn52"><sup>[52]</sup></a> National Audit Office, Home to School Transport: Department for Education, October 2025<a href="https://www.nao.org.uk/wp-content/uploads/2025/10/Home-to-School-transport.pdf"> link</a>.&nbsp;</p>



<p class="wp-block-paragraph"><a href="#_ednref53" id="_edn53"><sup>[53]</sup></a>&nbsp; Local Government Association, <em>The Future of Home to School Transport</em>, June 2025 <a href="https://www.local.gov.uk/publications/future-home-school-transport">link.</a></p>



<p class="wp-block-paragraph"><a href="#_ednref54" id="_edn54"><sup>[54]</sup></a> Department for Education, <em>Home to School Transport: LA Data Collection</em>, October 2025 <a href="https://explore-education-statistics.service.gov.uk/find-statistics/home-to-school-transport-la-data-collection/2024-25">link.</a></p>



<p class="wp-block-paragraph"><a href="#_ednref55" id="_edn55"><sup>[55]</sup></a> Ministry of Housing, Communities and Local Government &amp; Department for Education, <em>Free School Travel: Funding Allocations (Guidance)</em>, February 2024 <a href="https://www.gov.uk/government/publications/extended-rights-to-free-school-travel--2">link.</a></p>



<p class="wp-block-paragraph"><a href="#_ednref56" id="_edn56"><sup>[56]</sup></a> UK Parliament, <em>A response to a written question by Catherine McKinnel MP on the impact of Free School Meal eligibility changes on Free School Transport from Munira Wilson MP</em>, June 2025 <a href="https://questions-statements.parliament.uk/written-questions/detail/2025-06-12/59499">link.</a></p>



<p class="wp-block-paragraph"><a href="#_ednref57" id="_edn57"><sup>[57]</sup></a> Ministry of Housing, Communities and Local Government &amp; Department for Education, <em>Extended Rights Grant Allocations Financial Year 2024 to 2025: Explanatory Note on Methodology, </em>February 2024 <a href="https://www.gov.uk/government/publications/extended-rights-to-free-school-travel--2/extended-rights-grant-allocations-financial-year-2024-to-2025-explanatory-note-on-methodology">link.</a></p>



<p class="wp-block-paragraph"><a href="#_ednref58" id="_edn58"><sup>[58]</sup></a> UK Parliament, <em>A response to a question by Georgia Gould MP on Government guidance to Local Authorities regarding Motability Scheme provision and Free Home to School Transport from David Simmonds MP</em>, October 2025, <a href="https://questions-statements.parliament.uk/written-questions/detail/2025-08-29/71479">link.</a></p>



<p class="wp-block-paragraph"><a href="#_ednref59" id="_edn59"><sup>[59]</sup></a> Ryder, M. &amp; Palmer, M., <em>Reverse Gear: Why Motability is Broken and How to fix it</em>, The Adam Smith Institute, 2025 <a href="https://static1.squarespace.com/static/56eddde762cd9413e151ac92/t/68c1b78edb28793e587820d3/1757525902789/Reverse_Gear-Matt_Ryder_%26_Mitchell_Palmer-Adam_Smith_Institute-September%2B2025.pdf">link.</a></p>



<p class="wp-block-paragraph"><a href="#_ednref60" id="_edn60"><sup>[60]</sup></a> Department for Education, <em>Holiday Activities and Food Programme 2025 to 2026 (Guidance)</em>, December 2025 <a href="https://www.gov.uk/government/publications/holiday-activities-and-food-programme/holiday-activities-and-food-programme-2025">link.</a></p>



<p class="wp-block-paragraph"><a href="#_ednref61" id="_edn61"><sup>[61]</sup></a> Department for Education, <em>Press Release: Parents to Save Thousands in Government Cost of Living Support</em>, August 2025 <a href="https://www.gov.uk/government/news/parents-to-save-thousands-in-government-cost-of-living-support">link.</a></p>



<p class="wp-block-paragraph"><a href="#_ednref62" id="_edn62"><sup>[62]</sup></a> Coram Hempsall’s, <em>Childcare Works HAF delivers DfE&#8217;s National Support Contract for the Holiday Activities and Food Programme</em>, Retrieved January 2026 <a href="https://www.coramhempsalls.org.uk/childcare/childcare-works-haf">link.</a></p>



<p class="wp-block-paragraph"><a href="#_ednref63" id="_edn63"><sup>[63]</sup></a> Department for Education, <em>Press Release: Parents to Save Thousands in Government Cost of Living Support</em>, August 2025 <a href="https://www.gov.uk/government/news/parents-to-save-thousands-in-government-cost-of-living-support">link.</a></p>



<p class="wp-block-paragraph"><a href="#_ednref64" id="_edn64"><sup>[64]</sup></a> Department for Education, <em>Evaluation of the 2021 Holiday Activities and Food Programme,</em> March 2022 <a href="https://assets.publishing.service.gov.uk/media/6246db758fa8f52777576286/Evaluation_of_the_2021_holiday_activities_and_food_programme.pdf">link.</a></p>



<p class="wp-block-paragraph"><a href="#_ednref65" id="_edn65"><sup>[65]</sup></a> Coram, <em>Families Facing Holiday Childcare Bill of Over £1,000 per Child This Summer, With Significant Gaps in Provision for Children With Additional Needs (News Article)</em>, July 2025 <a href="https://www.coram.org.uk/news/holiday-childcare-survey-2025/">link.</a></p>



<p class="wp-block-paragraph"><a href="#_ednref66" id="_edn66"><sup>[66]</sup></a> Smith, C., <em>Cost of Summer Holiday Clubs Rises to £1,076 a Child</em>, BBC News, July 2025 <a href="https://www.bbc.co.uk/news/articles/cx231jx70evo">link.</a></p>



<p class="wp-block-paragraph"><a href="#_ednref67" id="_edn67"><sup>[67]</sup></a> Coram Hempsall’s, <em>Childcare Works HAF delivers DfE&#8217;s National Support Contract for the Holiday Activities and Food Programme</em>, Retrieved January 2026 <a href="https://www.coramhempsalls.org.uk/childcare/childcare-works-haf">link.</a></p>



<p class="wp-block-paragraph"><a href="#_ednref68" id="_edn68"><sup>[68]</sup></a> Department for Education, <em>Press Release: Parents to Save Thousands in Government Cost of Living Support</em>, August 2025 <a href="https://www.gov.uk/government/news/parents-to-save-thousands-in-government-cost-of-living-support">link.</a></p>



<p class="wp-block-paragraph"><a href="#_ednref69" id="_edn69"><sup>[69]</sup></a> Department for Education, <em>Holiday Activities and Food and Local Authority Capacity Support: 2026 Financial Year Expected Allocations (Guidance)</em>, December 2025 <a href="https://www.gov.uk/government/publications/holiday-activities-and-food-programme-grant-allocations/holiday-activities-and-food-and-local-authority-capacity-support-2026-financial-year-expected-allocations">link.</a></p>



<p class="wp-block-paragraph"><a href="#_ednref70" id="_edn70"><sup>[70]</sup></a> Department for Education, <em>Eligibility: Holiday Activities and Food Programme 2026 to 2027 (Guidance)</em>, December 2025 <a href="https://www.gov.uk/government/publications/holiday-activities-and-food-programme/holiday-activities-and-food-programme-2026-to-2027#eligibility-1">link.</a></p>



<p class="wp-block-paragraph"><a href="#_ednref71" id="_edn71"><sup>[71]</sup></a> Department for Education, <em>16 to 19 Payment Data for Care to Learn and 16 to 19 Bursary Fund for Students in Defined Vulnerable Groups Schemes (Guidance)</em>, October 2025 <a href="https://www.gov.uk/government/publications/16-to-19-esfa-payment-data-for-care-to-learn-and-bursary-fund-for-students-from-vulnerable-groups-schemes">link.</a></p>



<p class="wp-block-paragraph"><a href="#_ednref72" id="_edn72"><sup>[72]</sup></a> Department for Work &amp; Pensions, Universal Credit and Students: Guidance on claiming Universal Credit if you&#8217;re a student, October 2025 <a href="https://www.gov.uk/guidance/universal-credit-and-students">link.</a></p>



<p class="wp-block-paragraph"><a href="#_ednref73" id="_edn73"><sup>[73]</sup></a> Britton, J., Ridpath, N., Villa, C. &amp; Waltman, B. <em>The short and long-run effects of the Education Maintenance Allowance, </em>Institute for Fiscal Studies, February 2025 <a href="https://ifs.org.uk/publications/short-and-long-run-effects-education-maintenance-allowance">link.</a></p>



<p class="wp-block-paragraph"><a href="#_ednref74" id="_edn74"><sup>[74]</sup></a> Ibid. <a href="https://ifs.org.uk/publications/short-and-long-run-effects-education-maintenance-allowance">link.</a>&nbsp;</p>



<p class="wp-block-paragraph"><a href="#_ednref75" id="_edn75"><sup>[75]</sup></a> Ibid, <a href="https://ifs.org.uk/publications/short-and-long-run-effects-education-maintenance-allowance">link</a>.</p>



<p class="wp-block-paragraph"><a href="#_ednref76" id="_edn76"><sup>[76]</sup></a> Department for Work &amp; Pensions, <em>Universal Credit and Education Course Levels (Guidance)</em>, September 2025, <a href="https://www.gov.uk/guidance/universal-credit-and-education-course-levels#non-advanced">link.</a></p>



<p class="wp-block-paragraph"><a href="#_ednref77" id="_edn77"><sup>[77]</sup></a> Department for Education, <em>Eligibility for 15 hours for 2 year olds receiving support, </em>December 2025, <a href="https://beststartinlife.gov.uk/childcare-early-years-education/15-and-30-hours-support/additional-support/eligibility/">link</a>.</p>



<p class="wp-block-paragraph"><a href="#_ednref78" id="_edn78"><sup>[78]</sup></a> Department for Education, <em>Children registered by disadvantaged status</em>, retrieved January 2026, <a href="https://explore-education-statistics.service.gov.uk/data-tables/permalink/311ee68d-387b-4d71-198f-08de58cbc7ae">link</a>.</p>



<p class="wp-block-paragraph"><a href="#_ednref79" id="_edn79"><sup>[79]</sup></a> Institute for Fiscal Studies, <em>Annual report on education spending in England 2025/25</em>, January 2026, <a href="https://ifs.org.uk/publications/annual-report-education-spending-england-2025-26">link</a>.</p>



<p class="wp-block-paragraph"><a href="#_ednref80" id="_edn80"><sup>[80]</sup></a> Nesta, <em>45 million lost house? Understanding usage of the two-year-old free childcare offer</em>, January 2023, <a href="https://media.nesta.org.uk/documents/45_million_lost_hours__Understanding_usage_of_the_two-year-old_free_childcare_offer_Nesta.pdf#:~:text=We%20estimate%20that%2C%20based%20on%20the%20average,for%20the%20two%2Dyear%2Dold%20offer%20in%20June%2020221">link.</a></p>



<p class="wp-block-paragraph"><a href="#_ednref81" id="_edn81"><sup>[81]</sup></a> Ibid. <a href="https://media.nesta.org.uk/documents/45_million_lost_hours__Understanding_usage_of_the_two-year-old_free_childcare_offer_Nesta.pdf#:~:text=We%20estimate%20that%2C%20based%20on%20the%20average,for%20the%20two%2Dyear%2Dold%20offer%20in%20June%2020221">link.</a></p>



<p class="wp-block-paragraph"><a href="#_ednref82" id="_edn82"><sup>[82]</sup></a> Johnson, T., Ghelani, D., Walker, R. &amp; Charlesworth, Z., Cheques and Imbalances: How Income Varies Throughout the Year for Universal Credit Households, Policy in Practice, March 2025, <a href="https://policyinpractice.co.uk/wp-content/uploads/2025/03/Report_-Cheques-and-imbalances-How-income-varies-throughout-the-year-for-Universal-Credit-households.-March-2025-1.pdf">link.</a></p>



<p class="wp-block-paragraph"><a href="#_ednref83" id="_edn83"><sup>[83]</sup></a> Ibid, <a href="https://policyinpractice.co.uk/wp-content/uploads/2025/03/Report_-Cheques-and-imbalances-How-income-varies-throughout-the-year-for-Universal-Credit-households.-March-2025-1.pdf">link.</a></p>



<p class="wp-block-paragraph"><a href="#_ednref84" id="_edn84"><sup>[84]</sup></a> National Audit Office,<em> Investigation into Penalty Charge Notices in Healthcare</em>, May 2019 <a href="https://www.nao.org.uk/wp-content/uploads/2019/05/Investigation-into-penalty-charge-notices-in-healthcare.pdf">link.</a></p>



<p class="wp-block-paragraph"><a href="#_ednref85" id="_edn85"><sup>[85]</sup></a> NHS Business Services Authority, <em>NHS Help with Health Costs (HwHC) 2018/19 to 2024/25</em>, June 2025 <a href="https://nhsbsa-opendata.s3.eu-west-2.amazonaws.com/hwhc/hwhc_summary_narrative_2024_25_v001.html#24_NHS_Low_Income_Scheme">link.</a></p>



<p class="wp-block-paragraph"><a href="#_ednref86" id="_edn86"><sup>[86]</sup></a> NHS Business Services Authority, <em>NHS Low Income Scheme: NHS Help with Health Costs (HwHC) 2018/19 to 2024/25,</em> June 2025 <a href="https://nhsbsa-opendata.s3.eu-west-2.amazonaws.com/hwhc/hwhc_summary_narrative_2024_25_v001.html#24_NHS_Low_Income_Scheme">link.</a></p>



<p class="wp-block-paragraph"><a href="#_ednref87" id="_edn87"><sup>[87]</sup></a>&nbsp; National Audit Office,<em> Investigation into Penalty Charge Notices in Healthcare</em>, May 2019 <a href="https://www.nao.org.uk/wp-content/uploads/2019/05/Investigation-into-penalty-charge-notices-in-healthcare.pdf">link.</a></p>



<p class="wp-block-paragraph"><a href="#_ednref88" id="_edn88"><sup>[88]</sup></a>&nbsp; NHS Business Services Authority, <em>Additional Tables: NHS Help with Health Costs (HwHC) 2018/19 to 2024/25,</em> June 2025 <a href="https://nhsbsa-opendata.s3.eu-west-2.amazonaws.com/pca/pca_additional_tables_2024_25_v001.xlsx">link.</a></p>



<p class="wp-block-paragraph"><a href="#_ednref89" id="_edn89"><sup>[89]</sup></a> NHS Business Services Authority,&nbsp; <em>Prescription Cost Analysis – England 2024/25</em>, June 2025 <a href="https://www.nhsbsa.nhs.uk/statistical-collections/prescription-cost-analysis-england/prescription-cost-analysis-england-202425">link.</a></p>



<p class="wp-block-paragraph"><a href="#_ednref90" id="_edn90"><sup>[90]</sup></a> Ibid <a href="https://www.nhsbsa.nhs.uk/statistical-collections/prescription-cost-analysis-england/prescription-cost-analysis-england-202425">link.</a></p>



<p class="wp-block-paragraph"><a href="#_ednref91" id="_edn91"><sup>[91]</sup></a> NHS Business Services Authority, <em>Additional Tables: NHS Help with Health Costs (HwHC) 2018/19 to 2024/25,</em> June 2025 <a href="https://nhsbsa-opendata.s3.eu-west-2.amazonaws.com/pca/pca_additional_tables_2024_25_v001.xlsx">link.</a></p>



<p class="wp-block-paragraph"><a href="#_ednref92" id="_edn92"><sup>[92]</sup></a> Wickware, C., <em>‘Outdated, illogical and unfair’: The True Cost of Prescription Charges</em>, The Pharmaceutical Journal, May 2023 <a href="https://pharmaceutical-journal.com/article/feature/outdated-illogical-and-unfair-the-true-cost-of-prescription-charges">link.</a></p>



<p class="wp-block-paragraph"><a href="#_ednref93" id="_edn93"><sup>[93]</sup></a> Ibid <a href="https://pharmaceutical-journal.com/article/feature/outdated-illogical-and-unfair-the-true-cost-of-prescription-charges">link.</a></p>



<p class="wp-block-paragraph"><a href="#_ednref94" id="_edn94"><sup>[94]</sup></a> NHS Business Services Authority, <em>NHS Dental Statistics for England: National Activity Overview 2019/20 to 2024/25</em>, August 2025 <a href="https://nhsbsa-opendata.s3.eu-west-2.amazonaws.com/dental/dental_contract_national_overview_24_25_v001.xlsx">link.</a></p>



<p class="wp-block-paragraph"><a href="#_ednref95" id="_edn95"><sup>[95]</sup></a> NHS, <em>HC11: Help with Healthcare Costs</em>, December 2025 <a href="https://www.nhsbsa.nhs.uk/sites/default/files/2025-12/HC11%20%28V27%29%2011.2025.pdf">link.</a></p>



<p class="wp-block-paragraph"><a href="#_ednref96" id="_edn96"><sup>[96]</sup></a> NHS, <em>Improving Non-Emergency Patient Transport Services: Report of the Non-Emergency Patient Transport Review</em>, August 2021 <a href="https://www.england.nhs.uk/wp-content/uploads/2021/08/B0682-fnal-report-of-the-non-emergency-patient-transport-review.pdf">link.</a></p>



<p class="wp-block-paragraph"><a href="#_ednref97" id="_edn97"><sup>[97]</sup></a> NHS Business Services Authority, <em>General Ophthalmic Services (GOS) Activity Data for 2020-2023</em>, August 2025 <a href="https://www.nhsbsa.nhs.uk/ophthalmic-data/general-ophthalmic-services-gos-activity-data">link.</a></p>



<p class="wp-block-paragraph"><a href="#_ednref98" id="_edn98"><sup>[98]</sup></a> UK Government, <em>Benefits and Financial Support for Families: Sure Start Maternity Grant</em>, Retrieved January 2026 <a href="https://www.gov.uk/sure-start-maternity-grant">link.</a></p>



<p class="wp-block-paragraph"><a href="#_ednref99" id="_edn99"><sup>[99]</sup></a> Department for Work &amp; Pensions, <em>Annual Report and Accounts 2024-2025</em>, July 2025 <a href="https://assets.publishing.service.gov.uk/media/686f993d10d550c668de3da5/dwp-annual-report-and-accounts-2024-to-2025.pdf">link.</a></p>



<p class="wp-block-paragraph"><a href="#_ednref100" id="_edn100"><sup>[100]</sup></a> Department for Work &amp; Pensions, <em>Policy Paper–Universal Credit: Welfare that Works</em>, November 2010 <a href="https://www.gov.uk/government/publications/universal-credit-welfare-that-works">link.</a></p>



<p class="wp-block-paragraph"><a href="#_ednref101" id="_edn101"><sup>[101]</sup></a> Leyland, A., Ouédraogo, S., Nam, J., Bond, L., Briggs, A., Gray, R., Wood, R. &amp; Dundas, R., <em>Evaluation of Health in Pregnancy Grants in Scotland: A Natural Experiment Using Routine Data,&nbsp;</em></p>



<p class="wp-block-paragraph">Public Health Research Volume: 5, Issue: 6, October 2017 <a href="https://www.journalslibrary.nihr.ac.uk/phr/PHR05060">link.</a></p>



<p class="wp-block-paragraph"><a href="#_ednref102" id="_edn102"><sup>[102]</sup></a> Scottish Government, <em>Best Start Grant and Best Start Foods: How it Works</em>, February 2024 <a href="https://www.mygov.scot/best-start-grant-best-start-foods">link</a>.</p>



<p class="wp-block-paragraph"><a href="#_ednref103" id="_edn103"><sup>[103]</sup></a> Biggs, H., Wildman, J., Hamid, A., Holman, E., &amp; MacGregor, A., <em>Evaluation of the Five Family Payments: Annex A: Mixed Method Research</em>, Scottish Government Social Research, September 2025 <a href="https://www.gov.scot/binaries/content/documents/govscot/publications/research-and-analysis/2025/09/evaluation-five-family-payments-annex-mixed-methods-research/documents/evaluation-five-family-payments-annex-mixed-methods-research/evaluation-five-family-payments-annex-mixed-methods-research/govscot%3Adocument/evaluation-five-family-payments-annex-mixed-methods-research.pdf">link.</a></p>



<p class="wp-block-paragraph"><a href="#_ednref104" id="_edn104"><sup>[104]</sup></a> NHS, <em>Healthy Start: How to Apply, </em>Retrieved January 2026 <a href="https://www.healthystart.nhs.uk/how-to-apply/">link.</a><sub></sub></p>



<p class="wp-block-paragraph"><a href="#_ednref105" id="_edn105"><sup>[105]</sup></a> Department for Health &amp; Social Care, <em>Eligibility for Healthy Start for Groups Who Have No Recourse to Public Funds or are Subject to Immigration Controls</em>, July 2024 <a href="https://www.gov.uk/government/consultations/healthy-start-eligibility-for-families-who-cannot-access-public-funds/eligibility-for-healthy-start-for-groups-who-have-no-recourse-to-public-funds-or-are-subject-to-immigration-controls">link.</a></p>



<p class="wp-block-paragraph"><a href="#_ednref106" id="_edn106"><sup>[106]</sup></a> NHS, <em>Healthy Start Scheme Rules: What You’ll Get</em>, Retrieved January 2026 <a href="https://www.healthystart.nhs.uk/scheme-rules/#:~:text=%C2%A34.25%20for%20each%20week,one%20and%204%20years%20old">link</a>.</p>



<p class="wp-block-paragraph"><a href="#_ednref107" id="_edn107"><sup>[107]</sup></a> Scottish Government, <em>Best Start Grant and Best Start Foods: How it Works</em>, February 2024 <a href="https://www.mygov.scot/best-start-grant-best-start-foods">link</a>.</p>



<p class="wp-block-paragraph"><a href="#_ednref108" id="_edn108"><sup>[108]</sup></a> NHS, <em>Healthy Start Scheme: A Guide for Retailers</em>, April 2025 <a href="https://qna.files.parliament.uk/qna-attachments/1795916/original/PQ47096%20Guide.pdf">link.</a></p>



<p class="wp-block-paragraph"><a href="#_ednref109" id="_edn109"><sup>[109]</sup></a> Mumsnet and Reddit user discussions of misuse of Healthy Start cards. Mumsnet, Retrieved January 2026, <a href="https://www.mumsnet.com/talk/cost_of_living/5244311-using-nhs-healthy-start-card?reply=141805757&amp;utm_campaign=thread&amp;utm_medium=share">link</a>; Reddit, Retrieved January 2026, <a href="https://www.reddit.com/r/DWPhelp/comments/1osgl2t/healthy_start_card/">link</a>, <a href="https://www.reddit.com/r/DWPhelp/comments/1az2iik/silly_question_regarding_healthy_start_card/">link</a>.</p>



<p class="wp-block-paragraph"><a href="#_ednref110" id="_edn110"><sup>[110]</sup></a> NHS Healthy Start, <em>Healthcare Professionals’ Guidance</em>, Retrieved January 2026 <a href="https://www.healthystart.nhs.uk/healthcare-professionals">link.</a></p>



<p class="wp-block-paragraph"><a href="#_ednref111" id="_edn111"><sup>[111]</sup></a> Ibid. <a href="https://www.healthystart.nhs.uk/healthcare-professionals">link.</a></p>



<p class="wp-block-paragraph"><a href="#_ednref112" id="_edn112"><sup>[112]</sup></a> UK Parliament, <em>A statement made to the House of Commons by Andrew Weston MP on Healthy Start Uptake Data</em>, November 2024 <a href="https://questions-statements.parliament.uk/written-statements/detail/2024-11-21/hcws242">link.</a></p>



<p class="wp-block-paragraph"><a href="#_ednref113" id="_edn113"><sup>[113]</sup></a> The Food Foundation, <em>Government Set to Miss Target for Increased Uptake of Healthy Start (News Article)</em>, February 2023 <a href="https://foodfoundation.org.uk/news/government-set-miss-target-increased-uptake-healthy-start">link.</a></p>



<p class="wp-block-paragraph"><a href="#_ednref114" id="_edn114"><sup>[114]</sup></a> Dundas, R., Boroujerdi, M., Browne, S., Deidda, M., Bradshaw, P., Craig, P., McIntosh, E., Parkes, A., Wight, D., Wright, C. &amp; Leyland AH., <em>An Evaluation of the Healthy Start Voucher Scheme on Maternal Vitamin Use and Child Breastfeeding: A Natural Experiment Using Data Linkage</em>,</p>



<p class="wp-block-paragraph">Public Health Research Volume 11, Issue 11, November 2023 <a href="https://www.journalslibrary.nihr.ac.uk/phr/RTEU2107">link.</a></p>



<p class="wp-block-paragraph"><a href="#_ednref115" id="_edn115"><sup>[115]</sup></a> Johnson, T., Ghelani, D., Walker, R. &amp; Charlesworth, Z., <em>Cheques and Imbalances: How Income Varies Throughout the Year for Universal Credit Households</em>, Policy in Practice, March 2025 <a href="https://policyinpractice.co.uk/wp-content/uploads/2025/03/Report_-Cheques-and-imbalances-How-income-varies-throughout-the-year-for-Universal-Credit-households.-March-2025-1.pdf">link.</a></p>



<p class="wp-block-paragraph"><a href="#_ednref116" id="_edn116"><sup>[116]</sup></a> UK Government, <em>Explanatory Memorandum to the Healthy Start Scheme and Welfare Food (Amendment) Regulations 2016</em>, October 2016 <a href="https://www.legislation.gov.uk/uksi/2016/985/pdfs/uksiem_20160985_en.pdf">link.</a></p>



<p class="wp-block-paragraph"><a href="#_ednref117" id="_edn117"><sup>[117]</sup></a> Department for Energy Security &amp; Net Zero, <em>Warm Home Discount: Eligibility Statement (England and Wales), 2023 to 2024 Scheme Year Onward (Statutory Guidance), </em>September 2023 <a href="https://www.gov.uk/government/publications/warm-home-discount-eligibility-statement-england-and-wales-2023-to-2024-scheme-year-onward">link.</a></p>



<p class="wp-block-paragraph"><a href="#_ednref118" id="_edn118"><sup>[118]</sup></a> Ofgem, <em>Warm Home Discount Annual Report: Scheme Year 13</em>, March 2025 <a href="https://www.gov.uk/the-warm-home-discount-scheme/low-income-England-Wales">link</a>.</p>



<p class="wp-block-paragraph"><a href="#_ednref119" id="_edn119"><sup>[119]</sup></a> Department for Energy Security &amp; Net Zero, <em>Warm Home Discount Statistics: England, Wales and Scotland 2024/25,</em> June 2025, <a href="https://www.gov.uk/government/statistics/warm-home-discount-statistics-2024-to-2025">link</a>.</p>



<p class="wp-block-paragraph"><a href="#_ednref120" id="_edn120"><sup>[120]</sup></a> Ibid, <a href="https://www.gov.uk/government/statistics/warm-home-discount-statistics-2024-to-2025">link</a>.</p>



<p class="wp-block-paragraph"><a href="#_ednref121" id="_edn121"><sup>[121]</sup></a> Department for Energy Security &amp; Net Zero, <em>Expanding the Warm Home Discount Scheme 2025/26: Impact Assessment</em>, April 2025 <a href="https://assets.publishing.service.gov.uk/media/68529908ff16d05c5e6aa678/expanding-the-warm-home-discount-scheme-2025-to-2026-impact-assessment.pdf">link. </a>&nbsp;</p>



<p class="wp-block-paragraph"><a href="#_ednref122" id="_edn122"><sup>[122]</sup></a> Ibid <a href="https://assets.publishing.service.gov.uk/media/68529908ff16d05c5e6aa678/expanding-the-warm-home-discount-scheme-2025-to-2026-impact-assessment.pdf">link.</a></p>



<p class="wp-block-paragraph"><a href="#_ednref123" id="_edn123"><sup>[123]</sup></a> Ofgem, <em>Energy Company Obligation Public Reports and Data: Energy Company Obligation 3 Interim Measures</em>, Retrieved January 2026 <a href="https://www.ofgem.gov.uk/energy-company-obligation-eco/contacts-guidance-and-resources/eco-public-reports-and-data">link.</a></p>



<p class="wp-block-paragraph"><a href="#_ednref124" id="_edn124"><sup>[124]</sup></a> Department for Business, Energy &amp; Industrial Strategy, <em>Final stage Impact Assessment ECO4</em>, April 2022 <a href="https://assets.publishing.service.gov.uk/media/6246c8f88fa8f527785ed18a/eco4-final-ia.pdf">link.</a></p>



<p class="wp-block-paragraph"><a href="#_ednref125" id="_edn125"><sup>[125]</sup></a> National Audit Office, <em>Report – Value for money: Energy Efficiency Installations Under the Energy Company Obligation, </em>October 2025 <a href="https://www.nao.org.uk/reports/energy-efficiency-installations-under-the-energy-company-obligation/">link.</a> <em>&nbsp;</em></p>



<p class="wp-block-paragraph"><a href="#_ednref126" id="_edn126"><sup>[126]</sup></a> UK Parliament, <em>A Response by Martin McCluskey MP to a Parliamentary Question on continuity between ECO4 and the Warm Homes Plan from Patricia Ferguson MP</em>, December 2025 <a href="https://questions-statements.parliament.uk/written-questions/detail/2025-12-10/99045">link.</a></p>



<p class="wp-block-paragraph"><a href="#_ednref127" id="_edn127"><sup>[127]</sup></a> Department for Energy Security and Net Zero, <em>Warm Homes Plan</em>, January 2026, <a href="https://www.gov.uk/government/publications/warm-homes-plan">link</a>.</p>



<p class="wp-block-paragraph"><a href="#_ednref128" id="_edn128"><sup>[128]</sup></a> Onward analysis using: Department for Energy Security &amp; Net Zero, <em>Household Energy Efficiency Statistics</em>, December 2025 <a href="https://assets.publishing.service.gov.uk/media/69414d16f9d902210154a4f4/Headline_HEE_tables_December_2025.xlsx">link</a>.</p>



<p class="wp-block-paragraph"><a href="#_ednref129" id="_edn129"><sup>[129]</sup></a> Child tax credits used as the highest legacy percentage. Cannot sum other legacy benefits as claimants could be in receipt of more than one. Department for Energy Security &amp; Net Zero, <em>Research and Analysis: Evaluation of the Energy Company Obligation (ECO) Phases 2t and 3</em>, October 2023<a href="https://www.gov.uk/government/publications/evaluation-of-the-energy-company-obligation-eco-phases-2t-and-3"> link.</a></p>



<p class="wp-block-paragraph"><a href="#_ednref130" id="_edn130"><sup>[130]</sup></a> Onward analysis using: Department for Energy Security &amp; Net Zero, <em>Household Energy Efficiency Statistics</em>, December 2025 <a href="https://assets.publishing.service.gov.uk/media/69414d16f9d902210154a4f4/Headline_HEE_tables_December_2025.xlsx">link</a>; Department for Energy Security &amp; Net Zero, <em>Research and Analysis: Evaluation of the Energy Company Obligation (ECO) Phases 2t and 3</em>, October 2023<a href="https://www.gov.uk/government/publications/evaluation-of-the-energy-company-obligation-eco-phases-2t-and-3"> link.</a></p>



<p class="wp-block-paragraph"><a href="#_ednref131" id="_edn131"><sup>[131]</sup></a> Department for Energy Security &amp; Net Zero,<em> Warm Homes: Social Housing Fund Wave 3 – Successful Social Housing Landlords Including Local Authorities and Housing </em>Associations, November 2025<a href="https://www.gov.uk/government/publications/warm-homes-social-housing-fund-wave-3-successful-social-housing-landlords-including-local-authorities-and-housing-associations"> link.</a></p>



<p class="wp-block-paragraph"><a href="#_ednref132" id="_edn132"><sup>[132]</sup></a> Department for Energy Security and Net Zero, <em>Warm Homes Plan</em>, January 2026, <a href="https://www.gov.uk/government/publications/warm-homes-plan">link</a>.</p>



<p class="wp-block-paragraph"><a href="#_ednref133" id="_edn133"><sup>[133]</sup></a> Department for Work &amp; Pensions, <em>Cold Weather Payment Estimates in England and Wales: 1 November 2024 to 31 March 2025, </em>April 2025 <a href="https://assets.publishing.service.gov.uk/media/67f3a5e153505b2ca44efedf/cold-weather-payment-estimates-to-31-march-2025.ods">link.</a></p>



<p class="wp-block-paragraph"><a href="#_ednref134" id="_edn134"><sup>[134]</sup></a> Department for Work &amp; Pensions, <em>Corporate Report:&nbsp; Social Fund Account 2023 to 2024</em>, December 2024 <a href="https://www.gov.uk/government/publications/social-fund-account-2023-to-2024/social-fund-account-2023-to-2024">link.</a></p>



<p class="wp-block-paragraph"><a href="#_ednref135" id="_edn135"><sup>[135]</sup></a> Department for Work &amp; Pensions, <em>Background and Methodology: Cold Weather Payment Estimates 2024 to 2025</em>, April 2025 <a href="https://www.gov.uk/government/statistics/cold-weather-payment-estimates-2024-to-2025/background-and-methodology-cold-weather-payment-estimates-2024-to-2025">link.</a></p>



<p class="wp-block-paragraph"><a href="#_ednref136" id="_edn136"><sup>[136]</sup></a> Welsh Water, <em>Bill Cap &#8211; WaterSure Wales Tariff</em>, Retrieved January 2026 <a href="https://www.dwrcymru.com/en/help-with-your-bills/watersure-tariff">link.</a>; Hafren Dyfrdwy, <em>Bill Cap Scheme &#8211; WaterSure</em>, Retrieved January 2026 <a href="https://www.hdcymru.co.uk/my-account/help-when-you-need-it/help-with-paying-your-bill/watersure-scheme/">link.</a></p>



<p class="wp-block-paragraph"><a href="#_ednref137" id="_edn137"><sup>[137]</sup></a> Consumer Council for Water, Water Mark 2025, November 2025 <a href="https://www.ccw.org.uk/publication/water-mark-2025/">link.</a></p>



<p class="wp-block-paragraph"><a href="#_ednref138" id="_edn138"><sup>[138]</sup></a> Consumer Council for Water, <em>Appendix 9d &#8211; Average Water Consumption (3 year rolling average (litres per person per day))</em>, August 2025 <a href="https://www.ccw.org.uk/app/uploads/2025/11/Water-Mark-Data-Appendices-2024-25.xlsx">link.</a>; <em>Consumer Council for Water, CCW 2020-21 Company Performance Data Appendices, </em>November 2021<a href="https://www.ccw.org.uk/app/uploads/2021/11/Company-Performance-Data-Appendices-2020-21.xlsx">link.</a></p>



<p class="wp-block-paragraph"><a href="#_ednref139" id="_edn139"><sup>[139]</sup></a> Department for Environment, Food &amp; Rural Affairs, Consultation on Reforming the WaterSure Scheme, July 2025 <a href="https://consult.defra.gov.uk/consumers-and-affordability/reforming-the-watersure-scheme/supporting_documents/WaterSure%20Consultation.pdf">link.</a></p>



<p class="wp-block-paragraph"><a href="#_ednref140" id="_edn140"><sup>[140]</sup></a> Consumer Council for Water, <em>Draft Determinations Research: Summary Report 2024,</em> November 2024 <a href="https://www.ccw.org.uk/app/uploads/2024/11/Draft-determinations-research-summary-report.pdf">link.</a></p>



<p class="wp-block-paragraph"><a href="#_ednref141" id="_edn141"><sup>[141]</sup></a> Robinson, S. &amp; O Regan N., <em>Briefing Paper: The Shape of a Social Tariff</em>, Social Market Foundation, January 2025 <a href="https://www.smf.co.uk/wp-content/uploads/2025/01/The-shape-of-a-social-tariff.pdf">link. </a>&nbsp;</p>



<p class="wp-block-paragraph"><a href="#_ednref142" id="_edn142"><sup>[142]</sup></a> UK Government, <em>The Water Industry (Charges) (Vulnerable Groups) Regulations 1999</em>, December 1999 <a href="https://www.legislation.gov.uk/uksi/1999/3441/made">link.</a></p>



<p class="wp-block-paragraph"><a href="#_ednref143" id="_edn143"><sup>[143]</sup></a> Kidney Care UK, <em>Home Dialysis Reimbursement: A Guide for Patients</em>, Retrieved January 2026<a href="https://kidneycareuk.org/get-involved/help-us-influence-change/home-dialysis-reimbursement-a-guide-for-patients/"> link.</a></p>



<p class="wp-block-paragraph"><a href="#_ednref144" id="_edn144"><sup>[144]</sup></a> Department for Environment, Food &amp; Rural Affairs, <em>Proposed Reforms to the WaterSure Support Scheme</em>, July 2025 <a href="https://consult.defra.gov.uk/consumers-and-affordability/reforming-the-watersure-scheme">link.</a></p>



<p class="wp-block-paragraph"><a href="#_ednref145" id="_edn145"><sup>[145]</sup></a> Consumer Council for Water, <em>Recommendations – Improving the WaterSure Financial Support Scheme</em>, January 2025 <a href="https://www.ccw.org.uk/publication/recommendations-improving-the-watersure-financial-support-scheme/">link.</a></p>



<p class="wp-block-paragraph"><a href="#_ednref146" id="_edn146"><sup>[146]</sup></a> Robinson, S. &amp; O Regan N., <em>Briefing Paper: The Shape of a Social Tariff</em>, Social Market Foundation, January 2025 <a href="https://www.smf.co.uk/wp-content/uploads/2025/01/The-shape-of-a-social-tariff.pdf">link. </a>&nbsp;</p>



<p class="wp-block-paragraph"><a href="#_ednref147" id="_edn147"><sup>[147]</sup></a> Consumer Council for Water,&nbsp; Help with bills: Social Tariffs, Retrieved January 2026 <a href="https://www.ccw.org.uk/save-money-and-water/help-with-bills/#social-tariffs">link.</a></p>



<p class="wp-block-paragraph"><a href="#_ednref148" id="_edn148"><sup>[148]</sup></a> Consumer Council for Water, Water Mark 2025, November 2025 <a href="https://www.ccw.org.uk/publication/water-mark-2025/">link.</a></p>



<p class="wp-block-paragraph"><a href="#_ednref149" id="_edn149"><sup>[149]</sup></a> Ofwat, Summary of Water Companies&#8217; Published Plans for Affordability for 2025-30, December 2024 <a href="https://www.ofwat.gov.uk/wp-content/uploads/2024/12/Summary-of-water-companies-published-plans-for-affordability-for-2025-30-republished-19-December-2024.pdf">link.</a></p>



<p class="wp-block-paragraph"><a href="#_ednref150" id="_edn150"><sup>[150]</sup></a> Ofwat, <em>Water Company Performance Report 2024-25</em>, October 2025 <a href="https://www.ofwat.gov.uk/wp-content/uploads/2025/10/WCPR-24-25.pdf">link.</a>; Robinson, S. &amp; O Regan N., <em>Briefing Paper: The Shape of a Social Tariff</em>, Social Market Foundation, January 2025 <a href="https://www.smf.co.uk/wp-content/uploads/2025/01/The-shape-of-a-social-tariff.pdf">link.</a></p>



<p class="wp-block-paragraph"><a href="#_ednref151" id="_edn151"><sup>[151]</sup></a> Ofwat, Summary of Water Companies&#8217; Published Plans for Affordability for 2025-30, December 2024 <a href="https://www.ofwat.gov.uk/wp-content/uploads/2024/12/Summary-of-water-companies-published-plans-for-affordability-for-2025-30-republished-19-December-2024.pdf">link</a>.</p>



<p class="wp-block-paragraph"><a href="#_ednref152" id="_edn152"><sup>[152]</sup></a> United Utilities, <em>Low Income Water Discount Terms and Conditions,</em> Retrieved January 2026 <a href="https://www.unitedutilities.com/my-account/your-bill/difficulty-paying-your-bill/how-we-can-help/low-income-water-discount/low-income-water-discount-terms-and-conditions/">link.</a></p>



<p class="wp-block-paragraph"><a href="#_ednref153" id="_edn153"><sup>[153]</sup></a> Welsh Water, South West Water and United Utilities tie eligibility directly to UC receipt;</p>



<p class="wp-block-paragraph">Consumer Council for Water, Water Mark 2025, November 2025 <a href="https://www.ccw.org.uk/publication/water-mark-2025/">link.</a></p>



<p class="wp-block-paragraph"><a href="#_ednref154" id="_edn154"><sup>[154]</sup></a> Ibid. <a href="https://www.ccw.org.uk/publication/water-mark-2025/">link.</a></p>



<p class="wp-block-paragraph"><a href="#_ednref155" id="_edn155"><sup>[155]</sup></a> Robinson, S. &amp; O Regan N., <em>Briefing Paper: The Shape of a Social Tariff</em>, Social Market Foundation, January 2025 <a href="https://www.smf.co.uk/wp-content/uploads/2025/01/The-shape-of-a-social-tariff.pdf">link.</a></p>



<p class="wp-block-paragraph"><a href="#_ednref156" id="_edn156"><sup>[156]</sup></a> Ibid <a href="https://www.smf.co.uk/wp-content/uploads/2025/01/The-shape-of-a-social-tariff.pdf">link.</a></p>



<p class="wp-block-paragraph"><a href="#_ednref157" id="_edn157"><sup>[157]</sup></a> Consumer Council for Water, <em>WaterVoice Social Tariffs</em>, December 2020 <a href="https://www.ccw.org.uk/app/uploads/2023/03/Social-Tariffs-Omnibus-Research.pdf">link.</a></p>



<p class="wp-block-paragraph"><a href="#_ednref158" id="_edn158"><sup>[158]</sup></a> Ofwat, <em>Ofwat Approves £104bn Upgrade to Accelerate Delivery of Cleaner Rivers and Seas and Secure Long-Term Drinking Water Supplies for Customers (News Article), </em>December 2024 <a href="https://www.ofwat.gov.uk/ofwat-approves-104bn-upgrade-to-accelerate-delivery-of-cleaner-rivers-and-seas-and-secure-long-term-drinking-water-supplies-for-customers/">link.</a></p>



<p class="wp-block-paragraph"><a href="#_ednref159" id="_edn159"><sup>[159]</sup></a> Consumer Council for Water, <em>2 in 5 Households Say They Will Find it Difficult to Afford Water Bill Increases (News Article)</em>, November 2024 <a href="https://www.ccw.org.uk/news/2-in-5-households-say-they-will-find-it-difficult-to-afford-water-bill-increases/">link.</a></p>



<p class="wp-block-paragraph"><a href="#_ednref160" id="_edn160"><sup>[160]</sup></a> Beckett, M., B<em>roadband Social Tariff Deals: How to Get Low Income Broadband on Universal Credit,</em> Uswitch, July 2025 <a href="https://www.uswitch.com/broadband/guides/broadband-deals-for-low-income-families/">link</a>.</p>



<p class="wp-block-paragraph"><a href="#_ednref161" id="_edn161"><sup>[161]</sup></a> Ofcom, <em>Social Tariffs: Cheaper Broadband and Phone Packages</em>, October 2025<a href="https://www.ofcom.org.uk/phones-and-broadband/saving-money/social-tariffs"> link.</a></p>



<p class="wp-block-paragraph"><a href="#_ednref162" id="_edn162"><sup>[162]</sup></a> Ofcom, <em>Pricing Trends for Communications Services in the UK</em>, December 2024 <a href="https://www.ofcom.org.uk/siteassets/resources/documents/research-and-data/multi-sector/pricing/2024/pricing-trends-for-communications-services-in-the-uk-2024.pdf?v=387092">link.</a></p>



<p class="wp-block-paragraph"><a href="#_ednref163" id="_edn163"><sup>[163]</sup></a> Ibid <a href="https://www.ofcom.org.uk/siteassets/resources/documents/research-and-data/multi-sector/pricing/2024/pricing-trends-for-communications-services-in-the-uk-2024.pdf?v=387092">link.</a></p>



<p class="wp-block-paragraph"><a href="#_ednref164" id="_edn164"><sup>[164]</sup></a> Ofcom, <em>Half of Low-Income Households in the Dark Over Broadband Social Tariffs</em>, April 2023 <a href="https://www.ofcom.org.uk/phones-and-broadband/saving-money/half-of-low-income-households-in-dark-over-broadband-social-tariffs">link.</a></p>



<p class="wp-block-paragraph"><a href="#_ednref165" id="_edn165"><sup>[165]</sup></a> Ofcom, <em>Pricing Trends for Communications Services in the UK</em>, December 2024 <a href="https://www.ofcom.org.uk/siteassets/resources/documents/research-and-data/multi-sector/pricing/2024/pricing-trends-for-communications-services-in-the-uk-2024.pdf?v=387092">link.</a></p>



<p class="wp-block-paragraph"><a href="#_ednref166" id="_edn166"><sup>[166]</sup></a> Ibid <a href="https://www.ofcom.org.uk/siteassets/resources/documents/research-and-data/multi-sector/pricing/2024/pricing-trends-for-communications-services-in-the-uk-2024.pdf?v=387092">link.</a></p>



<p class="wp-block-paragraph"><a href="#_ednref167" id="_edn167"><sup>[167]</sup></a> Torres Cortés, F., Godoy Jalil, T., Hession, M. &amp; Ghelan, D., <em>Missing Out 2025: £24 Billion of Support is Unclaimed</em>, Policy in Practice<em>, </em>September 2025 <a href="https://policyinpractice.co.uk/wp-content/uploads/2025/09/MO25-24bnUnclaimed-PolicyinPractice-Sept25.pdf">link.</a></p>



<p class="wp-block-paragraph"><a href="#_ednref168" id="_edn168"><sup>[168]</sup></a> Ofcom, <em>Half of Low-Income Households in the Dark Over Broadband Social Tariffs</em>, April 2023 <a href="https://www.ofcom.org.uk/phones-and-broadband/saving-money/half-of-low-income-households-in-dark-over-broadband-social-tariffs">link.</a></p>



<p class="wp-block-paragraph"><a href="#_ednref169" id="_edn169"><sup>[169]</sup></a> Legal Aid Agency, <em>Means Assessment Guidance,</em> April 2025 <a href="https://assets.publishing.service.gov.uk/media/67f4d2d86852ad6032f5c01d/Means_Assessment_Guidance_April_2025.pdf">link.</a></p>



<p class="wp-block-paragraph"><a href="#_ednref170" id="_edn170"><sup>[170]</sup></a> Ministry of Justice, <em>Consultation Outcome: Legal Aid Means Test Review, May 2023</em> <a href="https://www.gov.uk/government/consultations/legal-aid-means-test-review/legal-aid-means-test-review">link.</a></p>



<p class="wp-block-paragraph"><a href="#_ednref171" id="_edn171"><sup>[171]</sup></a>Legal Aid Agency, <em>Civil Legal Aid: Means Testing–Eligibility Limits,</em> June 2025 <a href="https://www.gov.uk/guidance/civil-legal-aid-means-testing#eligibility-limits">link.</a></p>



<p class="wp-block-paragraph"><a href="#_ednref172" id="_edn172"><sup>[172]</sup></a> Public Accounts Committee, <em>Written Evidence Submitted by Commons Law CIC</em>, March 2024 <a href="https://committees.parliament.uk/writtenevidence/128735/pdf/">link.</a></p>



<p class="wp-block-paragraph"><a href="#_ednref173" id="_edn173"><sup>[173]</sup></a> Bellamy, C. <em>Independent Review of Criminal Legal Aid,</em> Criminal Bar, November 2021 <a href="https://www.criminalbar.com/wp-content/uploads/2021/12/Criminal-Legal-Aid-Independent-Review-Report-2021_.pdf">link.</a></p>



<p class="wp-block-paragraph"><a href="#_ednref174" id="_edn174"><sup>[174]</sup></a> Ministry of Justice, <em>Consultation Outcome: Legal Aid Means Test Review, May 2023</em> <a href="https://www.gov.uk/government/consultations/legal-aid-means-test-review/legal-aid-means-test-review">link.</a></p>



<p class="wp-block-paragraph"><a href="#_ednref175" id="_edn175"><sup>[175]</sup></a> Ministry of Justice, <em>Consultation Outcome: Legal Aid Means Test Review, May 2023</em> <a href="https://www.gov.uk/government/consultations/legal-aid-means-test-review/legal-aid-means-test-review">link.</a></p>



<p class="wp-block-paragraph"><a href="#_ednref176" id="_edn176"><sup>[176]</sup></a> UK Parliament, <em>A Statement to the House of Commons by Mike Freer MP on the Government Response to Legal Aid Means Test Review,</em> May 2023 <a href="https://questions-statements.parliament.uk/written-statements/detail/2023-05-25/hcws809">link</a>.&nbsp;</p>



<p class="wp-block-paragraph"><a href="#_ednref177" id="_edn177"><sup>[177]</sup></a>&nbsp; Ministry of Justice, <em>Legal Aid Means Test Review &#8211; Civil</em>, May 2023 <a href="https://assets.publishing.service.gov.uk/media/646f17edab40bf0010196a14/government-response-to-legal-aid-means-test-review-impact-assessment-civil.pdf">link</a>.&nbsp;</p>



<p class="wp-block-paragraph"><a href="#_ednref178" id="_edn178"><sup>[178]</sup></a> Ministry of Justice, <em>Legal Aid Data Dashboard</em>, November 2025 <a href="https://data.justice.gov.uk/legalaid">link.</a></p>



<p class="wp-block-paragraph"><a href="#_ednref179" id="_edn179"><sup>[179]</sup></a> Legal Aid Agency, <em>Corporate Report Annual Report and Accounts 2024-25: Performance Report, </em>November 2025 <a href="https://www.gov.uk/government/publications/legal-aid-agency-annual-report-and-accounts-2024-to-2025/annual-report-and-accounts-2024-25-performance-report-html#performance-overview">link.</a></p>



<p class="wp-block-paragraph"><a href="#_ednref180" id="_edn180"><sup>[180]</sup></a> Ministry of Justice, <em>Review of Civil Legal Aid Summary Report, </em>January 2025 <a href="https://assets.publishing.service.gov.uk/media/679241d223c34b0ef8fad5ef/Review_of_Civil_Legal_Aid_-_Summary_report__web__1_.pdf">link</a>.</p>



<p class="wp-block-paragraph"><a href="#_ednref181" id="_edn181"><sup>[181]</sup></a> Bellamy, C. <em>Independent Review of Criminal Legal Aid,</em> Criminal Bar, November 2021 <a href="https://www.criminalbar.com/wp-content/uploads/2021/12/Criminal-Legal-Aid-Independent-Review-Report-2021_.pdf">link.</a></p>



<p class="wp-block-paragraph"><a href="#_ednref182" id="_edn182"><sup>[182]</sup></a> Ministry of Justice, <em>Legal Aid Data Dashboard</em>, November 2025 <a href="https://data.justice.gov.uk/legalaid">link.</a></p>



<p class="wp-block-paragraph"><a href="#_ednref183" id="_edn183"><sup>[183]</sup></a> Ministry of Justice, <em>Get Help Paying Court and Tribunal Fees,</em> Retrieved January 2026 <a href="https://www.gov.uk/get-help-with-court-fees">link.</a></p>



<p class="wp-block-paragraph"><a href="#_ednref184" id="_edn184"><sup>[184]</sup></a> Ministry of Justice, Consultation Outcome: Revising the ‘Help with Fees’ Remission Scheme – Protecting and Enhancing Access to Justice, October 2023 <a href="https://www.gov.uk/government/consultations/revising-the-help-with-fees-remission-scheme/revising-the-help-with-fees-remission-scheme-protecting-and-enhancing-access-to-justice">link.</a></p>



<p class="wp-block-paragraph"><a href="#_ednref185" id="_edn185"><sup>[185]</sup></a> Ministry of Justice, <em>Get Help Paying Court and Tribunal Fees,</em> Retrieved January 2026 <a href="https://www.gov.uk/get-help-with-court-fees">link.</a></p>



<p class="wp-block-paragraph"><a href="#_ednref186" id="_edn186"><sup>[186]</sup></a> Ministry of Justice, Court and Tribunal Fees: What They Are, Retrieved January 2026<a href="https://www.gov.uk/court-fees-what-they-are"> link</a>.</p>



<p class="wp-block-paragraph"><a href="#_ednref187" id="_edn187"><sup>[187]</sup></a> Ministry of Justice, Consultation Outcome: Revising the ‘Help with Fees’ Remission Scheme – Protecting and Enhancing Access to Justice, October 2023 <a href="https://www.gov.uk/government/consultations/revising-the-help-with-fees-remission-scheme/revising-the-help-with-fees-remission-scheme-protecting-and-enhancing-access-to-justice">link.</a></p>



<p class="wp-block-paragraph"><a href="#_ednref188" id="_edn188"><sup>[188]</sup></a> Ibid. <a href="https://www.gov.uk/government/consultations/revising-the-help-with-fees-remission-scheme/revising-the-help-with-fees-remission-scheme-protecting-and-enhancing-access-to-justice">link</a>.</p>



<p class="wp-block-paragraph"><a href="#_ednref189" id="_edn189"><sup>[189]</sup></a> Ibid <a href="https://www.gov.uk/government/consultations/revising-the-help-with-fees-remission-scheme/revising-the-help-with-fees-remission-scheme-protecting-and-enhancing-access-to-justice">link.</a></p>



<p class="wp-block-paragraph"><a href="#_ednref190" id="_edn190"><sup>[190]</sup></a> Ibid. <a href="https://www.gov.uk/government/consultations/revising-the-help-with-fees-remission-scheme/revising-the-help-with-fees-remission-scheme-protecting-and-enhancing-access-to-justice">link.</a></p>



<p class="wp-block-paragraph"><a href="#_ednref191" id="_edn191"><sup>[191]</sup></a> European Social Charter (Council of Europe),<em> Comments Submitted by the Quaker Social Action Concerning the Ad Hoc Report on the Cost-of-Living Crisis Submitted by The Government of the United Kingdom</em>, June 2024 <a href="https://rm.coe.int/uk-comments-quaker-social-action-ad-hoc-report-cost-of-living-2024/1680b0fb12#:~:text=44.,their%20claim%20will%20be%20successful.">link.</a></p>



<p class="wp-block-paragraph"><a href="#_ednref192" id="_edn192"><sup>[192]</sup></a> UK Parliament,<em> A Response from Torsten Bell MP to a written question from Ellie Chowns MP on the family tests in the eligibility criteria for Social Fund Funeral Expenses Payments, </em>June 2025 <a href="https://questions-statements.parliament.uk/written-questions/detail/2025-06-05/57896">link</a>.</p>



<p class="wp-block-paragraph"><a href="#_ednref193" id="_edn193"><sup>[193]</sup></a> Sunlife, <em>Cost of Dying 2025 Report: A Comprehensive View of Funeral Costs and Attitudes to Funerals Over Time,&nbsp; </em>June 2025 <a href="https://www.sunlife.co.uk/siteassets/documents/cost-of-dying/sunlife-cost-of-dying-report-2025.pdf/">link.</a></p>



<p class="wp-block-paragraph"><a href="#_ednref194" id="_edn194"><sup>[194]</sup></a> Department for Work &amp; Pensions, <em>Corporate report Social Fund account 2024 to 2025</em>, December 2025 <a href="https://www.gov.uk/government/publications/social-fund-account-2024-to-2025/social-fund-account-2024-to-2025">link.</a></p>



<p class="wp-block-paragraph"><a href="#_ednref195" id="_edn195"><sup>[195]</sup></a> Sunlife, <em>Cost of Dying 2025 Report: A Comprehensive View of Funeral Costs and Attitudes to Funerals Over Time,&nbsp; </em>June 2025 <a href="https://www.sunlife.co.uk/siteassets/documents/cost-of-dying/sunlife-cost-of-dying-report-2025.pdf/">link.</a></p>



<p class="wp-block-paragraph"><a href="#_ednref196" id="_edn196"><sup>[196]</sup></a> UK Parliament, <em>A Response from Guy Opperman MP to a question on how many claims were made for Funeral Expenses Payments, and how many were successful, from Steve McCabe MP, </em>February 2022 <a href="https://questions-statements.parliament.uk/written-questions/detail/2022-02-18/124963">link.</a></p>



<p class="wp-block-paragraph"><a href="#_ednref197" id="_edn197"><sup>[197]</sup></a> Scottish Government, <em>Funeral Support Payment: If the Person Who Died was 18 or Over</em>, April 2022, <a href="https://www.mygov.scot/funeral-support-payment/if-the-person-who-died-was-18-or-over">link.</a></p>



<p class="wp-block-paragraph"><a href="#_ednref198" id="_edn198"><sup>[198]</sup></a> Department for Work &amp; Pensions, P<em>ress Release: Benefit Claimants to Get More Cash to Help With Funeral Costs</em>, November 2019 <a href="https://www.gov.uk/government/news/benefit-claimants-to-get-more-cash-to-help-with-funeral-costs">link.</a></p>



<p class="wp-block-paragraph"><a href="#_ednref199" id="_edn199"><sup>[199]</sup></a> Scottish Government, <em>Evaluation of Funeral Support Payment, Equality &amp; Welfare Social Research,</em> July 2022 <a href="https://www.gov.scot/binaries/content/documents/govscot/publications/research-and-analysis/2022/07/evaluation-funeral-support-payment/documents/evaluation-funeral-support-payment/evaluation-funeral-support-payment/govscot%3Adocument/evaluation-funeral-support-payment.pdf">link.</a></p>



<p class="wp-block-paragraph"><a href="#_ednref200" id="_edn200"><sup>[200]</sup></a> UK Government, <em>Benefits and Financial Support When Someone Dies: Bereavement Support Payment</em>, Retrieved January 2026 <a href="https://www.gov.uk/bereavement-support-payment/eligibility">link.</a></p>



<p class="wp-block-paragraph"><a href="#_ednref201" id="_edn201"><sup>[201]</sup></a> Ibid <a href="https://www.gov.uk/bereavement-support-payment/eligibility">link.</a></p>



<p class="wp-block-paragraph"><a href="#_ednref202" id="_edn202"><sup>[202]</sup></a> UK Government, <em>Get Help with Savings if You’re on a Low Income (Help to Save), </em>Retrieved January 2026 <a href="https://www.gov.uk/get-help-savings-low-income/what-youll-get">link.</a></p>



<p class="wp-block-paragraph"><a href="#_ednref203" id="_edn203"><sup>[203]</sup></a> HM Revenue &amp; Customs,&nbsp; <em>HMRC Annual Report and Accounts: 2024 to 2025</em>, July 2025 <a href="https://www.gov.uk/government/publications/hmrc-annual-report-and-accounts-2024-to-2025">link.</a></p>



<p class="wp-block-paragraph"><a href="#_ednref204" id="_edn204"><sup>[204]</sup></a> HM Revenue &amp; Customs, <em>Annual Savings Statistics 2025: HMRC Statistics on Individual Savings Accounts, Child Trust Funds and Help to Save Accounts</em>, September 2025 <a href="https://www.gov.uk/government/statistics/annual-savings-statistics-2025">link.</a></p>



<p class="wp-block-paragraph"><a href="#_ednref205" id="_edn205"><sup>[205]</sup></a> HM Treasury and HM Revenue &amp; Customs, <em>Help to Save Reform Consultation Response and Delivery Consultation, </em>October 2024, <a href="https://assets.publishing.service.gov.uk/media/67213a1d4da1c0d41942a8c3/Help_to_Save_Consultation_Response_and_Delivery_Consultation.pdf">link.</a></p>



<p class="wp-block-paragraph"><a href="#_ednref206" id="_edn206"><sup>[206]</sup></a> HM Revenue &amp; Customs, <em>Annual Savings Statistics 2025: HMRC Statistics on Individual Savings Accounts, Child Trust Funds and Help to Save Accounts</em>, September 2025 <a href="https://www.gov.uk/government/statistics/annual-savings-statistics-2025">link.</a></p>



<p class="wp-block-paragraph"><a href="#_ednref207" id="_edn207"><sup>[207]</sup></a> HM Treasury and HM Revenue &amp; Customs, <em>Help to Save Reform Consultation Response and Delivery Consultation, </em>October 2024, <a href="https://assets.publishing.service.gov.uk/media/67213a1d4da1c0d41942a8c3/Help_to_Save_Consultation_Response_and_Delivery_Consultation.pdf">link.</a></p>



<p class="wp-block-paragraph"><a href="#_ednref208" id="_edn208"><sup>[208]</sup></a> HM Revenue &amp; Customs, <em>Evaluation of the Help to Save Scheme: HMRC Commissioned Ipsos to Undertake Qualitative and Quantitative Research with Users and Eligible non-users of the Help to Save Scheme</em>, November 2025 <a href="https://www.gov.uk/government/publications/evaluation-of-the-help-to-save-scheme">link.</a></p>



<p class="wp-block-paragraph"><a href="#_ednref209" id="_edn209"><sup>[209]</sup></a> Ibid <a href="https://www.gov.uk/government/publications/evaluation-of-the-help-to-save-scheme">link.</a></p>



<p class="wp-block-paragraph"><a href="#_ednref210" id="_edn210"><sup>[210]</sup></a> Johnson, T., Ghelani, D., Walker, R. &amp; Charlesworth, Z., <em>Cheques and Imbalances: How Income Varies Throughout the Year for Universal Credit Households</em>, Policy in Practice, March 2025 <a href="https://policyinpractice.co.uk/wp-content/uploads/2025/03/Report_-Cheques-and-imbalances-How-income-varies-throughout-the-year-for-Universal-Credit-households.-March-2025-1.pdf">link.</a></p>



<p class="wp-block-paragraph"><a href="#_ednref211" id="_edn211"><sup>[211]</sup></a> Ibid <a href="https://policyinpractice.co.uk/wp-content/uploads/2025/03/Report_-Cheques-and-imbalances-How-income-varies-throughout-the-year-for-Universal-Credit-households.-March-2025-1.pdf">link.</a></p>



<p class="wp-block-paragraph"><a href="#_ednref212" id="_edn212"><sup>[212]</sup></a> UK Government, <em>Local Government Finance Act 2012: c. 17 (Council tax), Section 9,</em> October 2012 <a href="https://www.legislation.gov.uk/ukpga/2012/17/section/9/enacted">link</a>.</p>



<p class="wp-block-paragraph"><a href="#_ednref213" id="_edn213"><sup>[213]</sup></a> Ollenrenshaw, E. <em>Three Years On: An Independent Review of Local Council Tax Support Schemes,</em> March 2016 <a href="https://assets.publishing.service.gov.uk/government/uploads/system/uploads/attachment_data/file/514767/Local_Council_Tax_support_schemes_-_review_report.pdf">link.</a></p>



<p class="wp-block-paragraph"><a href="#_ednref214" id="_edn214"><sup>[214]</sup></a> Ministry for Housing, Communities and Local Government, <em>The Government Response to an Independent Review of Local Council Tax Support Schemes, </em>January 2018 <a href="https://assets.publishing.service.gov.uk/government/uploads/system/uploads/attachment_data/file/676786/LCTS_Government_Response.pdf">link.</a></p>



<p class="wp-block-paragraph"><a href="#_ednref215" id="_edn215"><sup>[215]</sup></a>Adam, S., Joyce R. &amp; Pope T., <em>The Impacts of Localised Council Tax Support Schemes,</em> The Institute for Fiscal Studies, January 2019 <a href="https://ifs.org.uk/publications/impacts-localised-council-tax-support-scheme">link.</a></p>



<p class="wp-block-paragraph"><a href="#_ednref216" id="_edn216"><sup>[216]</sup></a> Ibid. <a href="https://ifs.org.uk/publications/impacts-localised-council-tax-support-scheme">link.</a></p>



<p class="wp-block-paragraph"><a href="#_ednref217" id="_edn217"><sup>[217]</sup></a> Clegg, A., <em>The Localisation Era: Assessing the Post-2013 Rise of Localised Social Security,</em> The Resolution Foundation, November 2025 <a href="https://www.resolutionfoundation.org/publications/the-localisation-era/">link.</a></p>



<p class="wp-block-paragraph"><a href="#_ednref218" id="_edn218"><sup>[218]</sup></a> Griffiths, R. &amp; Wood, M., <em>Cliff Edges and Precipitous Inclines: The Interaction Between Universal Credit and Additional Means-Tested Help for Working Claimants,</em> The Institute for Policy Research, September 2024 <a href="https://www.bath.ac.uk/publications/cliff-edges-and-precipitous-inclines-the-interaction-between-uc-and-additional-means-tested-help/attachments/cliff-edges-and-precipitous-inclines-research-report.pdf">link.</a></p>



<p class="wp-block-paragraph"><a href="#_ednref219" id="_edn219"><sup>[219]</sup></a> Johnson, T., Ghelani, D., Walker, R. &amp; Charlesworth, Z., <em>Cheques and Imbalances: How Income Varies Throughout the Year for Universal Credit Households</em>, Policy in Practice, March 2025 <a href="https://policyinpractice.co.uk/wp-content/uploads/2025/03/Report_-Cheques-and-imbalances-How-income-varies-throughout-the-year-for-Universal-Credit-households.-March-2025-1.pdf">link.</a></p>



<p class="wp-block-paragraph"><a href="#_ednref220" id="_edn220"><sup>[220]</sup></a> Ministry of Housing, Communities and Local Government, <em>Statistical Data Set: Live Tables on Local Government Finance (Local Council Tax support), </em>December 2025 <a href="https://www.gov.uk/government/statistical-data-sets/live-tables-on-local-government-finance#local-council-tax-support">link.</a></p>



<p class="wp-block-paragraph"><a href="#_ednref221" id="_edn221"><sup>[221]</sup></a> Take-up estimate includes England, Wales and Scotland: Torres Cortés, F., Godoy Jalil, T., Hession, M. &amp; Ghelan, D., <em>Missing Out 2025: £24 Billion of Support is Unclaimed</em>, Policy in Practice<em>, </em>September 2025 <a href="https://policyinpractice.co.uk/wp-content/uploads/2025/09/MO25-24bnUnclaimed-PolicyinPractice-Sept25.pdf">link.</a></p>



<p class="wp-block-paragraph"><a href="#_ednref222" id="_edn222"><sup>[222]</sup></a> UK Parliament, <em>Written questions, answers and statements: Guy Opperman MP in response to a written question from Jonathan Ashworth MP, </em>October 2023, <a href="https://questions-statements.parliament.uk/written-questions/detail/2023-09-15/199739/">link</a>.</p>



<p class="wp-block-paragraph"><a href="#_ednref223" id="_edn223"><sup>[223]</sup></a> Department for Work &amp; Pensions, <em>Crisis and Resilience Fund Guidance for local authorities in England (1 April 2026 to 31 March 2029), </em>January 2026, <a href="https://www.gov.uk/government/publications/crisis-and-resilience-fund-guidance-for-local-authorities-in-england-1-april-2026-to-31-march-2029/the-crisis-and-resilience-fund-guidance-for-local-authorities-in-england-1-april-2026-to-31-march-2029#introduction">link</a>.</p>



<p class="wp-block-paragraph"><a href="#_ednref224" id="_edn224"><sup>[224]</sup></a> Department for Work &amp; Pensions, Crisis and Resilience Fund: Guidance for local authorities in England (1 April 2026 to 31 March 2029): Annex E: CRF Allocations for Housing Payments, January 2026 <a href="https://www.gov.uk/government/publications/crisis-and-resilience-fund-guidance-for-local-authorities-in-england-1-april-2026-to-31-march-2029/the-crisis-and-resilience-fund-guidance-for-local-authorities-in-england-1-april-2026-to-31-march-2029#annex-e-crf-allocations-for-housing-payments">link.</a></p>



<p class="wp-block-paragraph"><a href="#_ednref225" id="_edn225"><sup>[225]</sup></a> Department for Work &amp; Pensions, <em>Support for Mortgage Interest</em>. Retrieved January 2026, <a href="https://www.gov.uk/support-for-mortgage-interest/eligibility">link</a>.</p>



<p class="wp-block-paragraph"><a href="#_ednref226" id="_edn226"><sup>[226]</sup></a>&nbsp; Department for Work &amp; Pensions, <em>Use of Discretionary Housing Payments (DHPs) in England, </em><a href="https://assets.publishing.service.gov.uk/media/6943de688f4636fa2c547e41/dhp-data-for-april-september-2025.ods">link</a>.</p>



<p class="wp-block-paragraph"><a href="#_ednref227" id="_edn227"><sup>[227]</sup></a> Onward analysis. 93% is the sum of the proportion used to weight the sample by age cohorts. Department for Work &amp; Pensions,<em> Research and Analysis: Early Evaluation of Discretionary Housing Payments</em>, February 2024 <a href="https://www.gov.uk/government/publications/early-evaluation-of-discretionary-housing-payments/early-evaluation-of-discretionary-housing-payments">link</a>.</p>



<p class="wp-block-paragraph"><a href="#_ednref228" id="_edn228"><sup>[228]</sup></a> Department for Work &amp; Pensions, <em>Use of Discretionary Housing Payments: Analysis of End-of-Year Returns from Local Authorities, Data for April 2024 to March 2025</em>, July 2025 <a href="https://www.gov.uk/government/statistics/use-of-discretionary-housing-payments-financial-year-2024-to-2025/use-of-discretionary-housing-payments-analysis-of-end-of-year-returns-from-local-authorities-data-for-april-2024-to-march-2025">link.</a></p>



<p class="wp-block-paragraph"><a href="#_ednref229" id="_edn229"><sup>[229]</sup></a> Department for Work &amp; Pensions,<em> Research and Analysis: Early Evaluation of Discretionary Housing Payments</em>, February 2024 <a href="https://www.gov.uk/government/publications/early-evaluation-of-discretionary-housing-payments/early-evaluation-of-discretionary-housing-payments">link</a>.</p>



<p class="wp-block-paragraph"><a href="#_ednref230" id="_edn230"><sup>[230]</sup></a> Department for Work &amp; Pensions, <em>DWP Management Information on Progress of the Household Support Fund, Provided by Local Authorities, October 2024 </em><a href="https://www.gov.uk/government/collections/household-support-fund-management-information">link.</a></p>



<p class="wp-block-paragraph"><a href="#_ednref231" id="_edn231"><sup>[231]</sup></a> Department for Work &amp; Pensions, <em>Guidance 1 April 2025 to 31 March 2026: Household Support Fund guidance for county councils and unitary authorities in England</em>, January 2026 <a href="https://www.gov.uk/government/publications/household-support-fund-guidance-for-local-councils/1-april-2025-to-31-march-2026-household-support-fund-guidance-for-county-councils-and-unitary-authorities-in-england">link.</a></p>



<p class="wp-block-paragraph"><a href="#_ednref232" id="_edn232"><sup>[232]</sup></a> Department for Work &amp; Pensions, <em>Evaluation of the Household Support Fund 4</em>, January 2025, <a href="https://www.gov.uk/government/publications/evaluation-of-the-household-support-fund-4/evaluation-of-the-household-support-fund-4#key-findings">link</a>.</p>



<p class="wp-block-paragraph"><a href="#_ednref233" id="_edn233"><sup>[233]</sup></a> Onward analysis.</p>



<p class="wp-block-paragraph"><a href="#_ednref234" id="_edn234"><sup>[234]</sup></a> Department for Work &amp; Pensions, <em>Family Resources Survey: background information and methodology</em>, January 2026 <a href="https://www.gov.uk/government/statistics/family-resources-survey-financial-year-2023-to-2024/family-resources-survey-background-information-and-methodology">link.</a></p>



<p class="wp-block-paragraph"><a href="#_ednref235" id="_edn235"><sup>[235]</sup></a> Money Helper, <em>Benefits Calculator</em>, Accessed January 2026 <a href="https://www.moneyhelper.org.uk/en/benefits/benefits-calculator">link.</a>; UK Government, B<em>enefits calculators (entitledto benefits calculator, Turn2us benefits calculator, Policy in Practice better off calculator), Accessed January 2026 </em><a href="https://www.gov.uk/benefits-calculators">link</a>.</p>



<p class="wp-block-paragraph"><a href="#_ednref236" id="_edn236"><sup>[236]</sup></a> Holford, A., &amp; Rabe, B., <em>Going Universal. The Impact of Free School Lunches on Child Body Weight Outcomes,</em> Journal of Public Economics Plus, March 2022 <a href="https://doi.org/10.1016/j.pubecp.2022.100016">link.</a></p>



<p class="wp-block-paragraph"><a href="#_ednref237" id="_edn237"><sup>[237]</sup></a> Department for Work &amp; Pensions, <em>Improving Lives: Helping Workless Families indicators and evidence base, </em>March 2025, <a href="https://www.gov.uk/government/collections/improving-lives-helping-workless-families-indicators-and-evidence-base">link</a>.</p>



<p class="wp-block-paragraph"><a href="#_ednref238" id="_edn238"><sup>[238]</sup></a> UK Parliament, <em>A Response from Matt Warman MP in answer to a question on Government plans to subsidise the cost of broadband in rural areas from Chi Onwurah MP</em>, March 2021 <a href="https://questions-statements.parliament.uk/written-questions/detail/2021-03-18/171595">link.</a></p>



<p class="wp-block-paragraph"><a href="#_ednref239" id="_edn239"><sup>[239]</sup></a> In England and Scotland. Wales revalued in 2003, implementing new bands from 2005.</p>



<p class="wp-block-paragraph"><a href="#_ednref240" id="_edn240"><sup>[240]</sup></a> Hoynes, H., Joyce, R. &amp; Waters, T., <em>Benefits and Tax Credits</em>, The Institute for Fiscal Studies, July 2024 <a href="https://ifs.org.uk/inequality/benefits-and-tax-credits/">link.</a></p>



<p class="wp-block-paragraph"><a href="#_ednref241" id="_edn241"><sup>[241]</sup></a> NEST Insight, Sidecar savings tools could address two of the biggest financial challenges facing UK households, says Nest Insight, April 2023, <a href="https://www.nestinsight.org.uk/sidecar-savings-tools-could-address-two-of-the-biggest-financial-challenges-facing-uk-households-says-nest-insight/">link</a>.</p>



<p class="wp-block-paragraph"><a href="#_ednref242" id="_edn242"><sup>[242]</sup></a> Department for Work and Pensions, <em>Universal Credit change brings £420 boost to over a million households</em>, April 2025, <a href="https://www.gov.uk/guidance/find-out-about-money-taken-off-your-universal-credit-payment">link</a>.</p>



<p class="wp-block-paragraph"><a href="#_ednref243" id="_edn243"><sup>[243]</sup></a> Local Government Association, <em>Public Health Funerals 2024: Research Report</em>, July 2024 <a href="https://www.local.gov.uk/sites/default/files/documents/Public%20Health%20Funerals%202024%20-%20Report%20-%20Final.pdf">link.</a></p>



<p class="wp-block-paragraph"><a href="#_ednref244" id="_edn244"><sup>[244]</sup></a> HM Treasury, <em>Autumn Budget and Spending Review 2021: Policy Costings</em>, October 2021, <a href="https://assets.publishing.service.gov.uk/media/617c2631e90e07197f18fe04/Policy_Costings_Document_FINAL.pdf">link</a>.</p>



<p class="wp-block-paragraph"><a href="#_ednref245" id="_edn245"><sup>[245]</sup></a> Clougherty, T., <em>Make Work Pay: A New Agenda for Fairer Taxes</em>, The Centre for Policy Studies, November 2018, <a href="https://cps.org.uk/wp-content/uploads/2021/07/181105085949-MakeWorkPay.pdf">link.</a></p>
<p>The post <a href="https://ukonward.com/reports/the-hidden-benefits-bill-how-universal-credit-claimants-get-10-billion-in-extra-benefits/">The Hidden Benefits Bill: How Universal Credit claimants get £10 billion in extra benefits</a> appeared first on <a href="https://ukonward.com">Onward</a>.</p>
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		<title>How long will Britain pay the cost of strangers in our prisons?</title>
		<link>https://ukonward.com/press/how-long-will-britain-pay-the-cost-of-strangers-in-our-prisons/</link>
		
		<dc:creator><![CDATA[Joanna Marchong]]></dc:creator>
		<pubDate>Thu, 27 Nov 2025 16:13:20 +0000</pubDate>
				<category><![CDATA[Crime, Justice and Policing]]></category>
		<guid isPermaLink="false">https://ukonward.com/?post_type=press&#038;p=41155</guid>

					<description><![CDATA[<p>It is no secret that there is a prison crisis in this country.</p>
<p>The post <a href="https://ukonward.com/press/how-long-will-britain-pay-the-cost-of-strangers-in-our-prisons/">How long will Britain pay the cost of strangers in our prisons?</a> appeared first on <a href="https://ukonward.com">Onward</a>.</p>
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										<content:encoded><![CDATA[
<p class="wp-block-paragraph">It is no secret that there is a prison crisis in this country.</p>
<p>The post <a href="https://ukonward.com/press/how-long-will-britain-pay-the-cost-of-strangers-in-our-prisons/">How long will Britain pay the cost of strangers in our prisons?</a> appeared first on <a href="https://ukonward.com">Onward</a>.</p>
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		<title>Foreign criminals costing taxpayers £643m a year as record numbers ‘spiralling out of control’</title>
		<link>https://ukonward.com/press/foreign-criminals-costing-taxpayers-643m-a-year-as-record-numbers-spiralling-out-of-control/</link>
		
		<dc:creator><![CDATA[Joanna Marchong]]></dc:creator>
		<pubDate>Sat, 15 Nov 2025 14:37:35 +0000</pubDate>
				<category><![CDATA[Crime, Justice and Policing]]></category>
		<guid isPermaLink="false">https://ukonward.com/?post_type=press&#038;p=41110</guid>

					<description><![CDATA[<p>Albanian, Polish, Romanian, Lithuanian, Portuguese, Jamaican, Pakistani and Somali make up the largest groups of foreign prisoners in British jails</p>
<p>The post <a href="https://ukonward.com/press/foreign-criminals-costing-taxpayers-643m-a-year-as-record-numbers-spiralling-out-of-control/">Foreign criminals costing taxpayers £643m a year as record numbers ‘spiralling out of control’</a> appeared first on <a href="https://ukonward.com">Onward</a>.</p>
]]></description>
										<content:encoded><![CDATA[
<p class="wp-block-paragraph">Albanian, Polish, Romanian, Lithuanian, Portuguese, Jamaican, Pakistani and Somali make up the largest groups of foreign prisoners in British jails<br></p>
<p>The post <a href="https://ukonward.com/press/foreign-criminals-costing-taxpayers-643m-a-year-as-record-numbers-spiralling-out-of-control/">Foreign criminals costing taxpayers £643m a year as record numbers ‘spiralling out of control’</a> appeared first on <a href="https://ukonward.com">Onward</a>.</p>
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		<title>Foreign criminals cost taxpayers £643m a year to imprison</title>
		<link>https://ukonward.com/press/foreign-criminals-cost-taxpayers-643m-a-year-to-imprison/</link>
		
		<dc:creator><![CDATA[Joanna Marchong]]></dc:creator>
		<pubDate>Sat, 15 Nov 2025 13:27:27 +0000</pubDate>
				<category><![CDATA[Crime, Justice and Policing]]></category>
		<guid isPermaLink="false">https://ukonward.com/?post_type=press&#038;p=41107</guid>

					<description><![CDATA[<p>Bill for accommodating prisoners increased by 50 per cent since 2019, report finds</p>
<p>The post <a href="https://ukonward.com/press/foreign-criminals-cost-taxpayers-643m-a-year-to-imprison/">Foreign criminals cost taxpayers £643m a year to imprison</a> appeared first on <a href="https://ukonward.com">Onward</a>.</p>
]]></description>
										<content:encoded><![CDATA[
<p class="wp-block-paragraph">Bill for accommodating prisoners increased by 50 per cent since 2019, report finds<a href="https://www.telegraph.co.uk/politics/2025/11/15/foreign-criminals-cost-taxpayers-643m-a-year-to-imprison/#comment"></a></p>
<p>The post <a href="https://ukonward.com/press/foreign-criminals-cost-taxpayers-643m-a-year-to-imprison/">Foreign criminals cost taxpayers £643m a year to imprison</a> appeared first on <a href="https://ukonward.com">Onward</a>.</p>
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		<title>The Cost of Strangers</title>
		<link>https://ukonward.com/reports/the-cost-of-strangers/</link>
		
		<dc:creator><![CDATA[Joanna Marchong]]></dc:creator>
		<pubDate>Fri, 14 Nov 2025 22:00:00 +0000</pubDate>
				<category><![CDATA[Reshaping the State]]></category>
		<category><![CDATA[Crime, Justice and Policing]]></category>
		<guid isPermaLink="false">https://ukonward.com/?post_type=reports&#038;p=41059</guid>

					<description><![CDATA[<p>Introduction England and Wales are facing a prison capacity crisis. This issue gained public attention recently when the Government implemented a swathe of early releases to ease pressure last summer.[1] But our male prisons have been operating with only a 5% vacancy margin for several years and are no better now. As of October this [&#8230;]</p>
<p>The post <a href="https://ukonward.com/reports/the-cost-of-strangers/">The Cost of Strangers</a> appeared first on <a href="https://ukonward.com">Onward</a>.</p>
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<h3 class="wp-block-heading"><strong>Introduction</strong></h3>



<p class="wp-block-paragraph">England and Wales are facing a prison capacity crisis. This issue gained public attention recently when the Government implemented a swathe of early releases to ease pressure last summer.<a href="#_edn1" id="_ednref1"><sup>[1]</sup></a> But our male prisons have been operating with only a 5% vacancy margin for several years and are no better now. As of October this year, prisons in England and Wales were operating at 98% capacity.<a href="#_edn2" id="_ednref2"><sup>[2]</sup></a></p>



<p class="wp-block-paragraph">One in every eight inmates housed on the prison estate in England and Wales is a foreign national offender (FNO), which equates to around 10,800 offenders.<a href="#_edn3" id="_ednref3"><sup>[3]</sup></a> With the FNO population in English and Welsh prisons taking up 12% of capacity, their removal presents an opportunity to alleviate prison capacity problems significantly. Currently, these offenders can be removed from this country through various means, including the early removal scheme, the facilitated return scheme and prisoner transfer agreements.</p>



<p class="wp-block-paragraph">But there are complexities that surround these processes that mean progress in deporting FNOs is slower than it could be. The interpretation of articles in the European Convention on Human Rights (ECHR) through domestic human rights law has been a significant barrier to removal: between April 2008 and June 2021 6,042 FNOs had their removal appeal allowed at the First Tier Tribunal with nearly 40% of these doing so on human rights grounds.<a href="#_edn4" id="_ednref4"><sup>[4]</sup></a></p>



<p class="wp-block-paragraph">Increasing the deportation of FNOs represents a significant opportunity not only to relieve prison capacity problems, but to deliver a significant saving to the taxpayer. Onward analysis reveals that the average annual cost of FNOs in our prison population is much higher than previous estimates: on average £537 million a year since 2019.<a href="#_edn5" id="_ednref5"><sup>[5]</sup></a> The process of removing FNOs needs urgent acceleration, and this paper sets out practical measures to achieve this.</p>



<h3 class="wp-block-heading"><strong>Prison capacity in England and Wales</strong></h3>



<p class="wp-block-paragraph">The English and Welsh prison system is at a dangerous tipping point. Prisons housing adult males, the vast majority of the prison population, have been operating at close to 95% capacity for several years. And in June 2024 the prison population rose to almost 88,000, putting adult male prison capacity under severe pressure as it reached 97-99.7%.<a href="#_edn6" id="_ednref6"><sup>[6]</sup></a> As of October this year, prisons in England and Wales were again operating at 98% capacity.<a href="#_edn7" id="_ednref7"><sup>[7]</sup></a></p>



<h4 class="wp-block-heading">How did our prisons get to this point?</h4>



<p class="wp-block-paragraph">There has been significant pressure on the courts with a backlog in cases increasing before 2020, but the COVID-19 pandemic intensified this. In particular, the most serious cases being heard in the Crown Court had already increased by 23% from 33,290 cases in March 2019 to 41,045 in March 2020 as the pandemic began.<a href="#_edn8" id="_ednref8"><sup>[8]</sup></a></p>



<p class="wp-block-paragraph"><strong>Figure 1: Number of open cases in the Crown Court 2016-2025<a href="#_edn9" id="_ednref9"><sup><strong><sup>[9]</sup></strong></sup></a></strong></p>



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<p class="wp-block-paragraph">As shown in Figure 1, the impact of pandemic restrictions can be seen with the backlog of cases increasing a further 46% to 59,928 in September 2021. And this has only worsened since. When restrictions were lifted, there was a sharp increase in the prison population as shown in Figure 2.</p>



<p class="wp-block-paragraph"><strong>Figure 2: Prison population and capacity in England and Wales 2015-2025<a href="#_edn10" id="_ednref10"><sup><strong><sup>[10]</sup></strong></sup></a></strong></p>



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<p class="wp-block-paragraph">The most recent figures show that by the end of March 2025, the Crown Court backlog reached 76,957 &#8211; an 11% increase on March 2024. The Magistrates’ court backlog also increased by 13% relative to the previous year, reaching 310,304 in March 2025. This means that there is now a larger population being held in custody on remand awaiting trial.<a href="#_edn11" id="_ednref11"><sup>[11]</sup></a></p>



<p class="wp-block-paragraph">Tougher and therefore longer sentences have also been rising since 2023. In 2012, the average prison sentence was a year and six weeks, which increased to a year and nine months by 2023.<a href="#_edn12" id="_ednref12"><sup>[12]</sup></a> And prison capacity has not increased over the same period. In 2024, excluding offenders recalled to jail after early release, prisoners with sentences of four or more years made up 72% of the prison population. This is compared to just 54% in 2009.<a href="#_edn13" id="_ednref13"><sup>[13]</sup></a></p>



<p class="wp-block-paragraph"><strong>Figure 3: Types of crimes 2020-2024<a href="#_edn14" id="_ednref14"><sup><strong><sup>[14]</sup></strong></sup></a></strong></p>



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<p class="wp-block-paragraph">There has been a sharp increase in offenders serving sentences for violent crimes which attract longer sentences since 2022, as shown in Figure 3 &#8211; the number of violent offences has increased by nearly a third since 2019. This has resulted in one in three prisoners being guilty of a violent offence. What’s more, the number of sexual offenders has increased by over 3,000 since March 2021.<a href="#_edn15" id="_ednref15"><sup>[15]</sup></a> Taken together, violent and sexual offenders make up more than half of all prisoners. Looking at the share of cautions and convictions among FNOs, the most represented crimes are drug offences, sexual offences, criminal damage and arson, and then fraud.<a href="#_edn16" id="_ednref16"><sup>[16]</sup></a></p>



<p class="wp-block-paragraph">In the last decade there has been a significant increase in the number of people recalled to prison after breaking the terms of their parole. Ministry of Justice data shows that between January and March 2025, there were 13,296 prisoner releases and 10,101 recalls &#8211; this means that for every four people released in the first quarter of 2025, a staggering three were recalled.<a href="#_edn17" id="_ednref17"><sup>[17]</sup></a></p>



<h4 class="wp-block-heading">Prison building and early release</h4>



<p class="wp-block-paragraph">The previous Government committed to delivering 20,000 new prison places by the mid-2020s. As of September 2024, only 6,518 new prison places have been added.<a href="#_edn18" id="_ednref18"><sup>[18]</sup></a></p>



<p class="wp-block-paragraph">The National Audit Office (NAO) identified several reasons for this delay: an over-ambitious timeline, weakness of governance and risk management, a lack of prioritisation from the Treasury, and a challenging economic and delivery environment. In particular, the NAO highlighted that given the time it takes to obtain planning permission to build new prisons, 20,000 new prison places in around five years was highly unrealistic. Rising costs and inflation also had a significant impact. Between January 2020 and February 2024, there was a 40% overall price rise which led to a near doubling of the cost per prison place for HMPP. This pushed total spending to £2.2 billion by March 2024.<a href="#_edn19" id="_ednref19"><sup>[19]</sup></a></p>



<p class="wp-block-paragraph">During the summer of 2024, the prison system came close to overflowing, prompting the current Labour Government to implement emergency early releases, reducing some offenders’ sentences to 40% of their original term.<a id="_ednref20" href="#_edn20"><sup>[20]</sup></a> Between September 2024 and June 2025, over 38,000 prisoners were freed early by the Government.<a id="_ednref21" href="#_edn21"><sup>[21]</sup></a></p>



<p class="wp-block-paragraph"><strong>Figure 4: Opinion on early release and prisons capacity<a href="#_edn22" id="_ednref22"><sup><strong><sup>[22]</sup></strong></sup></a></strong></p>



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<p class="wp-block-paragraph">Early release of prisoners is not a sustainable long-term solution to prison capacity issues &#8211; and it is highly unpopular with the public. Figure 4 shows a map of More in Common polling of public opinion of early release alongside prisons across the country and how close to capacity they are. This demonstrates a worrying picture.</p>



<p class="wp-block-paragraph">Removing London, over 50% of the country disapproves of early releases. Some areas like the South West, North East and East Anglia register nearly 70% disapproval. And with prisons across the country between 95% and 100% capacity, early releases will become more and more frequent. Future scenes similar to August 2024 of released prisoners celebrating in the local area near the prison could create significant tension in communities.</p>



<p class="wp-block-paragraph"><strong>Figure 5: Prison population and capacity projection in England and Wales by 2027<a href="#_edn23" id="_ednref23"><sup><strong><sup>[23]</sup></strong></sup></a></strong></p>



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<p class="wp-block-paragraph">Numerous projections, illustrated in Figure 5, indicate that by November 2027 at the latest, the prison population will exceed capacity, with estimated occupancy rates ranging from 101% to 113%. This underscores the pressing need for decisive action to prevent further early releases or the system reaching breaking point again.<a href="#_edn24" id="_ednref24"><sup>[24]</sup></a></p>



<p class="wp-block-paragraph">The number of erroneous early releases has increased at a staggering rate since 2024, as shown in Figure 6. While mistaken prison releases have been a long-standing issue as evidenced above, the spike since the current Government came to power is stark. The danger of this increased volume of mistaken early releases should not be underestimated and has been underscored in the last month with the release of two high-profile foreign national sex offenders. The former Chief Inspector of Prisons has said that the Government’s early release programme could be linked to a recent spike in cases.<a href="#_edn25" id="_ednref25"><sup>[25]</sup></a></p>



<p class="wp-block-paragraph"><strong>Figure 6 &#8211; Number of releases in error<a href="#_edn26" id="_ednref26"><sup><strong><sup>[26]</sup></strong></sup></a></strong></p>



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<h3 class="wp-block-heading"><strong>Foreign National Offenders</strong></h3>



<p class="wp-block-paragraph">There is another route that the Government could take to free up space in prisons &#8211; improving the removal of FNOs. FNOs are individuals that are not British citizens and have been convicted of a criminal offence in the UK.</p>



<p class="wp-block-paragraph">There are currently around 10,800 FNOs in prisons in England and Wales, which represents around 12% of the prison population.<a href="#_edn27" id="_ednref27"><sup>[27]</sup></a> As shown in Figure 7, the number of FNOs in our prisons is sharply increasing. There has been a 17% increase in the number of FNOs since 2019 and an almost 10% increase since the current Government came to power.<a href="#_edn28" id="_ednref28"><sup>[28]</sup></a></p>



<p class="wp-block-paragraph"><strong>Figure 7: Number of Foreign National Offenders in prison 2019-2024<a href="#_edn29" id="_ednref29"><sup><strong><sup>[29]</sup></strong></sup></a></strong></p>



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<p class="wp-block-paragraph">While many FNOs are housed across the general prison estate, there are also specific prisons that are exclusively used for FNOs. They are dedicated to offenders that are of interest to the Home Office who have between three and 36 months left to serve. Taken together, HMP Huntercombe, HMP Maidstone and HMP Morton Hall house nearly 1,400 FNOs &#8211; nearly a tenth of the total FNO population.<a href="#_edn30" id="_ednref30"><sup>[30]</sup></a></p>



<p class="wp-block-paragraph">If the current population of FNOs were to be removed from the prisons altogether, prisons in England and Wales would be operating at 86% capacity, compared to the 98% capacity they currently are.<a href="#_edn31" id="_ednref31"><sup>[31]</sup></a> While it is not feasible for the whole FNO population to be removed, this demonstrates the significance of the FNO population and the pressure it is putting on our prison capacity.<strong></strong></p>



<p class="wp-block-paragraph">Figure 8 below shows the makeup of FNOs. The plurality of FNOs are Albanian citizens and this has been the case for several years. Polish, Romanian and Irish offenders follow closely.</p>



<p class="wp-block-paragraph"><strong>Figure 8: Breakdown of Foreign National Offenders in prison 2019-2023<a href="#_edn32" id="_ednref32"><sup><strong><sup>[32]</sup></strong></sup></a></strong></p>



<figure class="wp-block-table"><table class="has-fixed-layout"><tbody><tr><td rowspan="2"><strong>Nationality</strong></td><td colspan="5"><strong>Number of FNOs</strong></td></tr><tr><td>2019</td><td>2020</td><td>2021</td><td>2022</td><td>2023</td></tr><tr><td><strong>Albanian</strong></td><td>876</td><td>1,144</td><td>1,528</td><td>1,336</td><td>1,475</td></tr><tr><td><strong>Polish</strong></td><td>754</td><td>903</td><td>868</td><td>830</td><td>856</td></tr><tr><td><strong>Romanian</strong></td><td>734</td><td>731</td><td>732</td><td>752</td><td>758</td></tr><tr><td><strong>Irish</strong></td><td>707</td><td>670</td><td>617</td><td>632</td><td>624</td></tr><tr><td><strong>Lithuanian</strong></td><td>415</td><td>467</td><td>401</td><td>414</td><td>402</td></tr><tr><td><strong>Jamaican</strong></td><td>460</td><td>411</td><td>403</td><td>395</td><td>403</td></tr><tr><td><strong>Pakistani</strong></td><td>295</td><td>260</td><td>271</td><td>277</td><td>306</td></tr><tr><td><strong>Somalian</strong></td><td>295</td><td>280</td><td>268</td><td>257</td><td>281</td></tr><tr><td><strong>Portuguese</strong></td><td>223</td><td>239</td><td>255</td><td>248</td><td>300</td></tr><tr><td><strong>Nigerian</strong></td><td>238</td><td>203</td><td>203</td><td>198</td><td>199</td></tr><tr><td><strong>Other</strong></td><td>4,092</td><td>4,000</td><td>4,269</td><td>4,343</td><td>4,717</td></tr><tr><td><strong>Total</strong></td><td>9,089</td><td>9,308</td><td>9,815</td><td>9,682</td><td>10,321 &nbsp; &nbsp;</td></tr></tbody></table></figure>



<p class="wp-block-paragraph">With the FNO population in prisons in England and Wales taking up a significant proportion of capacity, their removal presents an opportunity to alleviate prison capacity significantly, preventing prisons being dangerously full.</p>



<p class="wp-block-paragraph">It could also allow for significant savings on the amount the Government spends on foreign offenders, far beyond just the period the offender is in prison. Previous estimates have only looked at the cost of housing a prisoner for a year. For example, the TaxPayer’s Alliance calculated FNOs have cost around £600 million in the last year. It is worth noting that this figure is unusually high because the number of FNOs is beyond that of the Government’s official figures because offenders whose nationality was not recorded were assumed to be foreign born.<a href="#_edn33" id="_ednref33"><sup>[33]</sup></a> Other calculations that use the official FNO population statistics have estimated the cost to be around £530 million.<a href="#_edn34" id="_ednref34"><sup>[34]</sup></a></p>



<p class="wp-block-paragraph">Taking into consideration the cost of the prosecution process, prison time, court time and process, we have estimated the total cost of FNOs to the taxpayer at £3.2 billion since 2019/2020. And the cost has increased over the years, in particular since 2021/2022 as shown in Figure 9 below. Under the current Government, the cost of FNOs to the taxpayer is at an all-time high at almost £650 million per year &#8211; this is a 50% increase, over £200 million more, compared to 2019.<a href="#_edn35" id="_ednref35"><sup>[35]</sup></a></p>



<p class="wp-block-paragraph"><strong>Figure 9: Cost of Foreign National Offenders 2019-2025<a href="#_edn36" id="_ednref36"><sup><strong><sup>[36]</sup></strong></sup></a></strong></p>



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<p class="wp-block-paragraph">The Government finds itself in a precarious fiscal position with a £40 billion black hole and borrowing costs at a 27-year high.<a href="#_edn37" id="_ednref37"><sup>[37]</sup></a> There is little room for spending increases without tax rises. Onward analysis estimates that the cost of FNOs under this Government is equivalent to paying the salaries of over 20,000 new nurses or over 20,000 new teachers.<a href="#_edn38" id="_ednref38"><sup>[38]</sup></a> Likewise, it equates to the salaries of over 15,000 new police officers.<a href="#_edn39" id="_ednref39"><sup>[39]</sup></a> On the average starting salary, it is the same as the salaries of over 19,000 new prison officers.<a href="#_edn40" id="_ednref40"><sup>[40]</sup></a></p>



<h3 class="wp-block-heading"><strong>How can FNOs be removed?</strong></h3>



<h4 class="wp-block-heading">Legal background</h4>



<p class="wp-block-paragraph">The legal backdrop to the removal of FNOs comes from two major pieces of legislation: the Immigration Act 1971 and the UK Borders Act 2007. The former originally intended for deportation to be discretionary in so far as, <em>“a person would be liable to deportation if the Home Office decided it was conducive to the public good or a judge recommended it at the point of sentencing”</em>. The latter places a statutory duty on the Home Secretary to make a deportation order on an FNO which has largely overtaken discretionary deportation decisions of the Immigration Act.<a href="#_edn41" id="_ednref41"><sup>[41]</sup></a></p>



<p class="wp-block-paragraph">Under the Borders Act, an FNO is defined as a<em> “person who was not a British citizen or an Irish citizen who had been convicted of an offence in the UK and sentenced to a period of imprisonment of at least 12 months”.</em> This means that the discretionary power of deportation as outlined in the Immigration Act was converted into a duty in relevant cases.<a href="#_edn42" id="_ednref42"><sup>[42]</sup></a> Irish citizens are excluded in the legislative definition of an FNO owing to the longstanding Common Travel Area arrangements that mean the UK does not routinely deport Irish citizens. They are nevertheless counted as foreign nationals in statistics on the nationality of prisoners in English and Welsh prisons.</p>



<p class="wp-block-paragraph">Deportation of FNOs is not automatic. Exemptions, outlined in section 33 of the Act, include whether the offender was under 18 at the time of the crime or if it would breach the European Convention on Human Rights (ECHR), the UN Refugee Convention or the Council of Europe Convention Against Trafficking in Human Beings.</p>



<p class="wp-block-paragraph">There are two articles of the ECHR in particular that are frequently cited: Article 3 and Article 8. The former prohibits deportation if <em>“there is a real risk that the person would be tortured or subjected to inhuman or degrading treatment”</em>.<a href="#_edn43" id="_ednref43"><sup>[43]</sup></a> Article 8 protects the right to <em>“respect for private and family life”</em>. The articles are written into UK law under the Human Rights Act 1998. It has since been established that Article 8 can be used to challenge immigration decisions.<a href="#_edn44" id="_ednref44"><sup>[44]</sup></a></p>



<p class="wp-block-paragraph">These articles have different legislative footings. Article 3 is an absolute right, meaning it cannot be interfered with under any circumstances. Article 8 is a qualified right which means its application can be restricted if it is necessary for a legitimate aim, such as protecting public safety or other people’s rights. Maintaining effective immigration controls has been classified as a legitimate reason for interfering in Article 8. Butit is the decision of a judge to decide whether deportation is a proportionate interference with the rights awarded under Article 8. The judge must weigh up the rights of the individual against the interests of the respective country.</p>



<p class="wp-block-paragraph">The precedent for how Article 8 is applied in the case of an FNO in the UK comes from two landmark cases: the 2004 R (Razgar) v Secretary of State for the Home Department and the 2007 case Huang v Secretary of State for the Home Department.<a href="#_edn45" id="_ednref45"><sup>[45]</sup></a> These cases saw the shift from deferring to the judgement of the Home Office on whether a deportation or removal breached a person’s rights under the Human Rights Act to an independent assessment by immigration tribunal judges on the facts and proportionality of each case.</p>



<p class="wp-block-paragraph">There were several key principles that were established in these cases. In Razgar, there were five stages of analysis that were established and then later endorsed in Huang. These were:</p>



<ol style="list-style-type:lower-alpha" class="wp-block-list">
<li>Is there interference with private or family life?</li>



<li>Is it in accordance with the law?</li>



<li>Is there a legitimate aim?</li>



<li>Is there interference necessary in a democratic society?</li>



<li>Is it proportionate to that aim?</li>
</ol>



<p class="wp-block-paragraph">In Huang, it was held that the immigration appeal tribunal must decide whether removal is proportionate under Article 8. Secondly, the court in this case established that tribunals should weigh the public interest in immigration control against the individual’s rights under Article 8. And finally, Huang confirmed that the immigration tribunal is the primary forum for deciding Article 8 proportionality.</p>



<p class="wp-block-paragraph">Following the UK’s exit from the EU, FNOs from the EU are subject to different legal routes depending on the circumstances of their crime. EU citizens and family members with residence rights under the European Union (Withdrawal Agreement) Act 2020 are exempt from automatic removal if their offence was undertaken before 31 December 2020.</p>



<p class="wp-block-paragraph">Removal is instead decided under a framework derived from EU free movement law, which offers stronger protections against deportation. No particular length of prison sentence triggers deportation. With the exception of Irish citizens, if an EU citizen has committed a crime after 31 December 2020, they are liable to automatic deportation.</p>



<p class="wp-block-paragraph">Prisons refer all cases involving FNOs to the Home Office’s Foreign National Offenders Returns Command (FNORC). An FNO who is not eligible for automatic deportation under the Borders Act can be considered on the grounds of their deportation being conducive to the public good. Deportation can be pursued on the ground of criminality if the person:<strong></strong></p>



<ul class="wp-block-list">
<li>“has received a custodial sentence of 12 months or more for a single conviction for a single offence in the UK or overseas</li>



<li>has received combined sentences totalling 12 months or more in the UK or overseas</li>



<li>has been convicted in the UK or overseas of an offence which has caused serious harm</li>



<li>is a persistent offender”.<a id="_ednref46" href="#_edn46"><sup>[46]</sup></a></li>
</ul>



<p class="wp-block-paragraph">Removal can also be pursued for the following reasons:</p>



<ul class="wp-block-list">
<li>The offender is a threat to national security,</li>



<li>Court recommended deportation,</li>



<li>The person’s involvement in gun or serious drug crime regardless of the length of sentence received,</li>



<li>Regardless of if the person has not yet been convicted of a criminal offence, if there is evidence that the FNO’s conduct or presence in the UK has or will cause serious harm,</li>



<li>Involvement in a sham marriage.</li>
</ul>



<h4 class="wp-block-heading">Routes to removal</h4>



<p class="wp-block-paragraph">Currently, offenders can be removed from this country through various means including deportation; the early removal scheme; the facilitated return scheme; prisoner transfer agreements; and the tariff-expired removal scheme.</p>



<p class="wp-block-paragraph">The early removal scheme is available to FNOs eligible for removal that are serving a fixed-term prison sentence and allows for the removal of FNOs at an<em> “earlier point than would otherwise be possible for the sole purpose of removal or deportation from the UK”</em>.<a href="#_edn47" id="_ednref47"><sup>[47]</sup></a> Once deported they cannot legally return to the UK, and are no longer subject to imprisonment and are free once back in their home country. The Home Office considers all cases, but in most cases prison governors are responsible for authorisation. Any prisoner can now be considered so long as their offence is not terror related. Similarly, the Tariff-Expired Removal Scheme applies to FNOs serving indeterminate sentences.<a href="#_edn48" id="_ednref48"><sup>[48]</sup></a></p>



<p class="wp-block-paragraph">FNOs under this scheme can be released up to four years before their earliest release date. This was originally 12 months, but it was increased in 2022 and has most recently been increased to 48 months this year under the Nationality and Borders Act 2022.<a href="#_edn49" id="_ednref49"><sup>[49]</sup></a> So, the minimum pre-removal custodial period is now 30% compared to the previous 50%. The Government has recently stated their intention to remove the minimum requirement of sentence completion, meaning that FNOs could face immediate removal in the Sentencing Bill, which is likely to pass early next year.<a href="#_edn50" id="_ednref50"><sup>[50]</sup></a></p>



<p class="wp-block-paragraph">The facilitated return scheme is a voluntary programme run by the Home Office which offers money to help FNOs to resettle in their home country on the condition that they withdraw any appeals or applications to remain in the UK. This scheme is available to all FNOs liable for removal. A participant in the scheme can receive £1,500 if they are serving a custodial sentence or £750 if they have completed their sentence. The scheme is designed to <em>“encourage FNOs to leave the UK at the earliest possible opportunity, thereby reducing the resources and costs associated with time spent in prison and immigration detention”</em>.<a href="#_edn51" id="_ednref51"><sup>[51]</sup></a></p>



<p class="wp-block-paragraph">Prisoner transfer agreements allow for FNOs serving custodial sentences to be transferred to see out the rest of their sentence in their home country. This can be carried out if there is a reciprocal prisoner transfer agreement between the UK and the respective country. The UK has 110 such prisoner transfer agreements &#8211; they differ between countries with some requiring the consent of the prisoner, and some not.<a href="#_edn52" id="_ednref52"><sup>[52]</sup></a> Countries include Albania, France, Romania, Pakistan, Poland and the United States. Consent is generally required for these transfer agreements, but not always.</p>



<p class="wp-block-paragraph"><strong>Figure 10: FNO deportations since 2010<a href="#_edn53" id="_ednref53"><sup><strong><sup>[53]</sup></strong></sup></a></strong></p>



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<h4 class="wp-block-heading">Removal history</h4>



<p class="wp-block-paragraph">The number of FNOs removed from the UK averaged around 5,500 per year during the period from 2010 to 2019. FNO returns reached a peak in 2016 at 6,437, subsequently falling to below 3,000 per year during the pandemic in 2020 to 2021. Since then, returns of FNOs have been gradually increasing, although in the latest year they were still 18% below the 2016 peak.<a href="#_edn54" id="_ednref54"><sup>[54]</sup></a></p>



<p class="wp-block-paragraph">The early removal scheme is responsible for around two fifths of FNO deportations from the UK. Between January 2010 and June 2022, around 12,800 people were removed under the facilitated return scheme, meaning it featured in approximately one in every five removals during that period.<a href="#_edn55" id="_ednref55"><sup>[55]</sup></a></p>



<p class="wp-block-paragraph">In total, the UK has removed 945 people to 50 countries and territories under prisoner transfer agreements from 2010 to 2023.<a href="#_edn56" id="_ednref56"><sup>[56]</sup></a> The net effect on prison spaces will be smaller, as some prisoners come to the UK from other countries under the same agreements.</p>



<p class="wp-block-paragraph">In the year ending June 2025, there were 5,265 FNO returns, representing a 16% increase on the previous year &#8211; 48% were EU nationals and 52% were non-EU nationals. And in the period between 5 July 2024 and 31 January 2025, the early release scheme was responsible for over half of deportations.<a href="#_edn57" id="_ednref57"><sup>[57]</sup></a><strong></strong></p>



<p class="wp-block-paragraph"><strong>Figure 11: Breakdown of FNO returns by nationality 2021-2025<a href="#_edn58" id="_ednref58"><sup><strong><sup>[58]</sup></strong></sup></a></strong></p>



<div class="flourish-embed flourish-chart" data-src="visualisation/26004779"><script src="https://public.flourish.studio/resources/embed.js"></script><noscript><img decoding="async" src="https://public.flourish.studio/visualisation/26004779/thumbnail" width="100%" alt="chart visualization" /></noscript></div>



<p class="wp-block-paragraph">As shown in Figure 11, FNO returns have been increasing in recent years. Removals of Albanian offenders have been the largest group of returns. They were steadily increasing until 2024 and took a slight downturn in the most recent year ending June 2025.</p>



<p class="wp-block-paragraph">Building on the 2021 prisoner transfer agreement, the previous Conservative government signed a deal to send 200 Albanian prisoners to serve the balance of their sentences in Albania. In return, the UK helps Albania modernise its prisons. The deal outlined that the total cost for the Ministry of Justice to modernise Albanian prisons was around £8 million over two years.<a href="#_edn59" id="_ednref59"><sup>[59]</sup></a> This equated to £32 per prisoner per day &#8211; a significant saving compared to £109 per Albanian prisoner per day in prisons in England and Wales.<a href="#_edn60" id="_ednref60"><sup>[60]</sup></a></p>



<p class="wp-block-paragraph">As shown in Figure 12, between April 2008 and June 2021, just over a tenth of appeals against removal succeeded on human rights grounds. Home Office management data records 21,521 appeals in that period, of which 6,042 succeeded. Of the successful appeals, nearly 2,400 were successful on human rights grounds only.</p>



<p class="wp-block-paragraph">Most of these are thought to be Article 8 cases as indicated by a subsequent review. Between 2016 and 2021, of 1,011 appeals against deportation by FNOs that were allowed on a human rights basis, nearly three-quarters were allowed solely on Article 8 grounds.<a href="#_edn61" id="_ednref61"><sup>[61]</sup></a></p>



<p class="wp-block-paragraph"><strong>Figure 12: FNO appeals against deportation 2008-2021<a href="#_edn62" id="_ednref62"><sup><strong><sup>[62]</sup></strong></sup></a></strong></p>



<div class="flourish-embed flourish-chart" data-src="visualisation/26004476"><script src="https://public.flourish.studio/resources/embed.js"></script><noscript><img decoding="async" src="https://public.flourish.studio/visualisation/26004476/thumbnail" width="100%" alt="chart visualization" /></noscript></div>



<h4 class="wp-block-heading">Removals and the ECHR</h4>



<p class="wp-block-paragraph">While the UK’s future as a signatory of the ECHR continues to be debated, there are steps that can be taken to apply its protections more proportionately to domestic cases. The courts must also ensure that its application to protect the rights of FNOs is not infringing on the rights of UK citizens. In other words, if an FNO appealed deportation due to an infringement on their Convention rights under the Human Rights Act, would this jeopardise the safety of the public?</p>



<p class="wp-block-paragraph">The Conservative party recently announced its intention to withdraw from the ECHR when in government and repeal the Human Rights Act 1998. This presents the opportunity for an entirely new legal framework free from having to align with Articles 3 or 8 that could radically increase deportations. However, the Labour Government has stated that it will not take the UK out of the ECHR. With over three and a half years until the next General Election must come and the prisons capacity crisis showing no signs of abating in the meantime, it is crucial to consider what other legislative changes could go some way towards increasing successful deportations of FNOs while the UK remains a signatory to ECHR.</p>



<p class="wp-block-paragraph">As outlined above, Article 8 is a qualified right that was incorporated into the Human Rights Act from the ECHR. So, while the application of Article 3 cannot be changed as long as the UK remains in the ECHR, the Government can restrict the application of Article 8. And given that nearly three-quarters of appeals against removal that were granted to FNOs between 2008-2021 were on the grounds of Article 8, changing its application could radically increase FNO removals.</p>



<p class="wp-block-paragraph">The Human Rights Act states that,</p>



<p class="wp-block-paragraph"><em>“There shall be no interference by a public authority with the exercise of this right except such as is in accordance with the law and is necessary in a democratic society in the interests of national security, public safety or the economic well-being of the country, for the prevention of disorder or crime, for the protection of health or morals, or for the protection of the rights and freedoms of others.”<a href="#_edn63" id="_ednref63"><sup><strong><sup>[63]</sup></strong></sup></a></em><em></em></p>



<p class="wp-block-paragraph">Looking at FNOs, there is a strong argument that interference with Article 8 would be in the interest of public safety, the prevention of disorder and crime, and for the protection of the rights and freedoms of others.</p>



<p class="wp-block-paragraph">The Government has done this before in 2014 and the current Government is in the process of building on this. The Cameron Government’s Immigration Act 2014 changed how Article 8 applications are handled, instructing courts and tribunals to prioritise the public interest in maintaining immigration control over an individual’s right to private and family life. This legislation also made it harder for FNOs to successfully challenge deportation with sentences of four or more years requiring<em> “very compelling circumstances”</em> and for shorter sentences, the claim needs to outweigh the public interest.<a href="#_edn64" id="_ednref64"><sup>[64]</sup></a></p>



<p class="wp-block-paragraph">Exceptions to deportation were also established in this legislation, including long-term lawful residence and integration for private life and where deportation would be ‘unduly harsh’ for a partner or child of the offender in question. It is important to note that ‘unduly harsh’ does not mean uncomfortable, inconvenient, undesirable or difficult.<a href="#_edn65" id="_ednref65"><sup>[65]</sup></a></p>



<h3 class="wp-block-heading"><strong>Recommendations and conclusion</strong></h3>



<h4 class="wp-block-heading">Recommendations</h4>



<p class="wp-block-paragraph"><strong>Recommendation 1 &#8211; </strong>The Government should introduce tougher legislation to tighten the application of Article 8 regardless of ECHR membership</p>



<p class="wp-block-paragraph">Legislative action on the interpretation of Article 8 has been taken in the past, and the Government has signalled its intention to build on this. But it needs to go further. The rate at which Article 8 applications are successful clearly shows this is not working how it was intended. A recent example exemplifies this: an Albanian FNO’s deportation was halted partly because his son had an aversion to foreign chicken nuggets. An immigration tribunal cited it would be ‘unduly harsh’ for the FNO’s son to return to Albania due to his food sensitivities &#8211; the only example of which listed in court documents was<em> “the type of chicken nuggets that are available abroad”</em>.<a href="#_edn66" id="_ednref66"><sup>[66]</sup></a></p>



<p class="wp-block-paragraph">The de jure application of Article 8 under the Human Rights Act alone needs to be further restricted and de facto practice needs to be tightened to ensure it is being applied properly. The Government should therefore tighten the code published in 2014, making the following changes under Part 5A of the Immigration Act 2014:</p>



<p class="wp-block-paragraph"><strong>1.&nbsp;&nbsp;&nbsp;&nbsp;&nbsp; </strong><strong>Clarify that family life formed after conviction carries little weight &#8211; making Immigration Rule 398(c) statutory</strong></p>



<p class="wp-block-paragraph"><a></a>Looking at whether deportation is proportionate under section 117C(6) of the Nationality, Immigration and Asylum Act 2002, considerations to family or private life should not be given any material weight after the commission of the offence unless exceptional circumstances exist.</p>



<p class="wp-block-paragraph"><a></a>In the Hesham Ali v SSHD [2016] UKSC 60, it was stated that <em>“The Rules are relevant to, but not determinative of, the proportionality assessment required by Article 8”</em>.Putting this on a statutory footing would therefore give it equal weight to the Human Rights Act Article 8 clauses so it is binding rather than guiding.</p>



<p class="wp-block-paragraph"><a></a>It is worth noting that while Parliament can pass legislation instructing courts how to weight Article 8 rights relative to public safety, if it instructs to give no weight at all to relationships formed post-conviction (for example), it is likely the courts would make a declaration of incompatibility. And the UK government could get taken to Strasbourg itself for breach of Article 8 in a direct court action.</p>



<p class="wp-block-paragraph"><a></a><strong>2.&nbsp;&nbsp;&nbsp;&nbsp; </strong><strong>Replace “unduly harsh” with a higher threshold &#8211; align with ECtHR thresholds in Üner v Netherlands (2006), <em>Jeunesse v Netherlands (2014)</em> and <em>Unuane v UK (2020)</em></strong></p>



<p class="wp-block-paragraph">As established above, if deportation would be ‘unduly harsh’ for a partner or child of the offender in question, this is a legitimate reason for appeal from the UK. But this precedent has been used in a disproportionate manner.</p>



<p class="wp-block-paragraph"><em>Üner v Netherlands (2006)</em>, <em>Jeunesse v Netherlands (2014)</em> and <em>Unuane v UK (2020)</em> cases looked at the proportionality of deporting FNOs in light of their private and family rights under Article 8 and the best interests of their children. They established that national authorities must conduct a proper proportionality assessment under Article 8.</p>



<p class="wp-block-paragraph">In particular, Üner established the ‘<em>Üner criteria’</em> which is a set of factors for courts to balance the public interest against private and family life rights &#8211; notably that removal can be allowed despite Article 8 rights if the public interstate is strong enough. And <em>Unuane v UK</em> ruled that the UK had breached Article 8 because it did not provide a proportionality assessment that <em>&#8220;adequately considered the best interests of the children”</em>. The case established that sufficient weight must be given to the negative impact on family life and that ‘unduly harsh’ requires a proper balancing exercise.</p>



<p class="wp-block-paragraph">So, for the purpose of section 117C(5), the effect of deportation on a qualifying child or partner should be regarded as unduly harsh only if it would result in exceptional and irreversible harm to that person. The threshold should be raised so that it mirrors the exceptional and irreversible harm thresholds usually used in Strasbourg cases above.</p>



<p class="wp-block-paragraph"><strong>3</strong>.       <strong>Make very compelling circumstances apply to all offenders, not just those with 4 or more years sentences</strong></p>



<p class="wp-block-paragraph">A court or tribunal may not find that deportation is disproportionate under Article 8 unless satisfied that the case presents very exceptional circumstances compelling in nature, assessed against the strong public interest in removal.</p>



<p class="wp-block-paragraph"><strong>Recommendation 2 &#8211; </strong>Introduce a Diversion Scheme<strong></strong></p>



<p class="wp-block-paragraph">The Government should introduce a Diversion Scheme for lower-level crime committed by FNOs, in which these perpetrators are deported before they are convicted, as a substitute for incarceration. This should be applied to crimes that carry a sentence of up to two years.</p>



<p class="wp-block-paragraph">There are some international examples of similar schemes. For example, the United States operates a pre-trial diversion policy under Title 8 of the Code of Federal Regulations. In this, the Attorney General may <em>“permit any alien applicant for admission to withdraw his or her application for admission in lieu of removal proceedings… or expedited removal”.<a href="#_edn67" id="_ednref67"><sup><strong><sup>[67]</sup></strong></sup></a></em>&nbsp;</p>



<p class="wp-block-paragraph">If the Department of Homeland Security uses an expedited removal, an inadmissibility bar (usually of five years) is applied to the alien in question. This carries no criminal conviction.<a href="#_edn68" id="_ednref68"><sup>[68]</sup></a> On the southern border, Border Patrol agents run a Consequence Delivery System (CDS) through which they find on the first apprehension of an alien, either federal prosecution or expedited removal are the most effective courses of action.<a href="#_edn69" id="_ednref69"><sup>[69]</sup></a></p>



<p class="wp-block-paragraph">The Home Office would retain information on FNO removal under the diversion policy so that FNOs in question would not be allowed to re-enter the country. This would not only prevent the FNO population in prisons in England and Wales from increasing, but it would also lessen the cost of FNOs.</p>



<p class="wp-block-paragraph"><strong>Recommendation 3 &#8211; </strong>Remove the minimum requirement for the early removal scheme</p>



<p class="wp-block-paragraph">Under the previous Conservative government, the minimum requirement was for an offender to have served 50% of their sentence, this was subsequently reduced to 30% under the Labour Government and is currently in place. As outlined above, the Government has signalled its intention to take this further and remove the minimum requirement for the early removal scheme altogether.</p>



<p class="wp-block-paragraph">There is international precedent for this policy. For example, in Italy a ‘judicial expulsion’ can be ordered as an alternative to a current term of imprisonment or as a substitute penalty to imprisonment. Both are applicable to sentences of two years or less but only to crimes of irregular entry or stay in Italy.<a href="#_edn70" id="_ednref70"><sup>[70]</sup></a> In Spain, an FNO who has been sentenced to a custodial sentence of more than a year can have their sentence substituted by “expulsion from Spanish territory”. A judge can also order for part of the sentence to be served and substitute the rest of their sentence with expulsion.<a href="#_edn71" id="_ednref71"><sup>[71]</sup></a></p>



<p class="wp-block-paragraph">The Government should press ahead with the removal of the minimum requirement for the early removal scheme at an accelerated pace. Introducing this means that offenders who have not qualified for the Diversion Scheme, perhaps as they have chosen to go through the court process in the hopes they would not be convicted, can be removed at the earliest opportunity post-conviction. This policy alongside the Diversion Scheme allows for a comprehensive set of deportation levers for new offenders.</p>



<p class="wp-block-paragraph"><strong>Recommendation 4 &#8211; </strong>Expand the ‘deport now, appeal later’ policy</p>



<p class="wp-block-paragraph">Legislation passed in 2014 introduced the system known as ‘deport first, appeal later’. This policy means that the Government can send FNOs back to their home nation before they can appeal against the decision. They can be removed from the UK and they can have their appeal heard through a video link.&nbsp;</p>



<p class="wp-block-paragraph">The current Government has recently expanded this list from the original eight countries to 23.<a href="#_edn72" id="_ednref72"><sup>[72]</sup></a> The list of countries that qualify for this policy are:</p>



<ul class="wp-block-list">
<li>Albania                                          </li>



<li>Angola</li>



<li>Australia</li>



<li>Belize</li>



<li>Botswana</li>



<li>Brunei</li>



<li>Bulgaria</li>



<li>Canada</li>



<li>Estonia</li>



<li>Finland</li>



<li>Guyana</li>



<li>India</li>



<li>Indonesia</li>



<li>Kenya</li>



<li>Kosovo</li>



<li>Latvia</li>



<li>Lebanon</li>



<li>Malaysia</li>



<li>Mauritius</li>



<li>Nigeria</li>



<li>Tanzania</li>



<li>Uganda</li>



<li>Zambia</li>
</ul>



<p class="wp-block-paragraph">Apart from Albania and Nigeria, this list omits the countries that are responsible for the majority of FNOs in prisons in England and Wales as shown in Figure 8. So, for this policy to be truly effective in decreasing the number of FNOs in prisons, this list needs to contain more of the countries outlined in Figure 8.</p>



<p class="wp-block-paragraph">The remaining countries that make up the top 10 FNO nations are:</p>



<ul class="wp-block-list">
<li>Poland</li>



<li>Romania</li>



<li>Ireland</li>



<li>Lithuania</li>



<li>Jamacia</li>



<li>Pakistan</li>



<li>Somalia</li>



<li>Portugal</li>
</ul>



<p class="wp-block-paragraph">The Home Secretary has the power to review and amend the countries on the deport now, appeal later list. Allowing removal before an appeal applies on a case-by-case basis, but being from a designated safe country strengthens the Home Secretary’s case for deportation. And Section 80AA list of the Nationality, Immigration and Asylum Act 2002 already contains a list of countries the Home Office deems as safe.</p>



<p class="wp-block-paragraph">Two actions should be taken to address this. First, the Home Office should put in place scheduled reviews of potential countries that could be added to the list. These reviews should happen at least bi-annually and should look at countries of interest:</p>



<ol start="1" style="list-style-type:upper-alpha" class="wp-block-list">
<li>The review should consider how effective adding this country would be in reducing the number of FNOs in English and Welsh prisons.</li>



<li>The safety of the home nation should be considered for both the FNO and possible dependants. The Home Office must ensure that there is no real risk of serious or irreversible harm to the individual or dependants if they are removed.</li>



<li>The viability of the home nation to conduct a fair remote appeal should be considered. This would include access to legal representation, sufficient internet access, diplomatic cooperation and arrangements, legal fairness and procedural safeguarding, and the assurance of no political interference.</li>
</ol>



<p class="wp-block-paragraph">Second, the remaining countries that are in the EU should be added immediately. Given that all EU countries fall within the Nationality, Immigration and Asylum Act’s safe countries, Poland, Romania, Lithuania, and Portugal are all already deemed as safe by the Home Office. And looking more broadly, based on 2023 prison population figures and the cost of incarceration in 2023, these FNOs cost the taxpayer over £124 million in 2023 alone. Therefore, as there is no real risk of serious harm to these offenders if they were deported and there is significant cost incurred by housing them in our prisons, these countries should be added to the ‘deport now, appeal later’ list at an accelerated pace.</p>



<p class="wp-block-paragraph">Finally, for countries on this list that do not cooperate with the deportation policy, the Home Office should signal their intention to stop issuing new visas to countries to work as a diplomatic tool to encourage an increase in the volume of removals to these countries. There would be unintended consequences for non-offenders trying to seek legal settlement in the UK, so the Government should only stop issuing new visas as a last resort.</p>



<h4 class="wp-block-heading">Conclusion</h4>



<p class="wp-block-paragraph">The prison population in England and Wales has reached dangerous levels in recent years and we cannot continue like this. And with inmate capacity across the prison estate at 98% in October 2025, the demand on our prisons is not being alleviated. There are several reasons our prisons have reached this tipping point: an increased backlog on the crown court due to the COVID-19 pandemic, tougher and therefore longer sentences have been on the rise since 2023 due to an increase in sentences for violent crimes, an increase in the number of offenders being recalled to prison, and a lack of prisons being built.</p>



<p class="wp-block-paragraph">There is a clear group of inmates that should not be in our prisons: foreign national offenders (FNOs). Britain is not open to business for crime. But with English and Welsh prisons housing 10,800 foreign national offenders, one could be forgiven for thinking it is. What’s more, FNOs have cost the taxpayer over £3.2 billion since 2019 alone.</p>



<p class="wp-block-paragraph">It is crucial for the integrity of our justice system, immigration system and tax system to send a clear message: if you come to this country and commit crime, you cannot stay. But on average, only 5,500 FNOs a year were removed from the UK between 2010 and 2019 &#8211; only around half of the annual FNO population.</p>



<p class="wp-block-paragraph">Britain expects migrants to abide by our laws and should not tolerate it when that does not happen. So, more needs to be done to ensure this, and fast. This paper has identified several areas of FNO removal that need to change and recommends a series of pragmatic reforms to accelerate deportations:</p>



<ul class="wp-block-list">
<li>The Government should introduce tougher legislation to tighten the application of Article 8 regardless of ECHR membership,</li>



<li>A Diversion Scheme should be introduced,</li>



<li>The Government should remove the minimum requirement for the early removal scheme,</li>



<li>And the Government should expand the ‘deport now, appeal later’ policy and stop issuing new visas to countries that do not comply.</li>
</ul>



<p class="wp-block-paragraph">In taking these steps and increasing the level of FNO deportations, this paper offers options to not only address the urgent issue of prison capacity but also alleviate the court backlog and reduce the associated cost.</p>



<h3 class="wp-block-heading">Costings Methodological note</h3>



<ol class="wp-block-list">
<li>We used MoJ data to calculate the cost of legal aid per crime higher case.<a id="_ednref73" href="#_edn73"><sup>[73]</sup></a></li>



<li>We used CPS data to calculate the average cost to the CPS of convicting someone.<a id="_ednref74" href="#_edn74"><sup>[74]</sup></a></li>



<li>We used government data on the average cost per prisoner for each year from 2019/20 &#8211; 2023/24. We used an inflation calculator to estimate the cost for 2024/25 since figures are not available. Note that this data is the average cost per prisoner for a year&#8217;s stay in prison.</li>



<li>Used data from a written question in parliament to calculate cost to HMCTS for 1.4 sitting days.<a id="_ednref75" href="#_edn75"><sup>[75]</sup></a></li>



<li>Found the number of FNOs per year (from 2019/20 &#8211; 2024/25).</li>



<li>Given that around 7% of determinate sentences come from the magistrates courts and the FNOs in question are all in prison, we have assumed they went through the Crown Courts.<a id="_ednref76" href="#_edn76"><sup>[76]</sup></a></li>



<li>Adding the court costs for each year assumes that every FNO in prison undergoes a full court process within a given year &#8211; implying a custodial sentence of 12 months and no carryover. But given the average custodial sentence is 22 months, we have adjusted the total court costs by 55%.</li>



<li>To calculate how many new nurses salaries the 2024/25 FNO cost is equivalent to, we found the starting salary (£31,048).<a id="_ednref77" href="#_edn77"><sup>[77]</sup></a> And for new teachers, we took the average of the starting salaries for England excluding London (£31,650).<a id="_ednref78" href="#_edn78"><sup>[78]</sup></a> And for police officer salaries, we found the police starting salary (£40,776). And according to the Met Police, the average cost to train a police constable over the three year course is £210,000 &#8211; this includes wages and operating costs.<a id="_ednref79" href="#_edn79"><sup>[79]</sup></a> For prison officer salaries, we used HMPPS’ starting salary of £33,746.<a id="_ednref80" href="#_edn80"><sup>[80]</sup></a> These comparisons do not include non-pay associated costs.</li>
</ol>



<p class="wp-block-paragraph">Data is accessible at the following link, alongside the calculations and the sources for each individual dataset: <a href="https://github.com/ukonward/The-Cost-of-Strangers.git" target="_blank" rel="noreferrer noopener">https://github.com/ukonward/The-Cost-of-Strangers.git</a> </p>



<h3 class="wp-block-heading">Endnotes</h3>



<hr class="wp-block-separator has-alpha-channel-opacity"/>



<p class="wp-block-paragraph"><a href="#_ednref1" id="_edn1"><sup>[1]</sup></a><em> Increasing the Capacity of the Prison Estate to Meet Demand</em> – National Audit Office (<a href="https://www.nao.org.uk/wp-content/uploads/2024/12/increasing-the-capacity-of-the-prison-estate-to-meet-demand.pdf">link</a>)</p>



<p class="wp-block-paragraph"><a href="#_ednref2" id="_edn2"><sup>[2]</sup></a><em> Prison Population: Monthly Prison Figures 2025</em> – Ministry of Justice, October 2025, Onward Analysis (<a href="https://www.gov.uk/government/publications/prison-population-monthly-prison-figures-2025">link</a>)</p>



<p class="wp-block-paragraph"><a href="#_ednref3" id="_edn3"><sup>[3]</sup></a><em> Offender Management Statistics Quarterly: Q4 2024</em> – Ministry of Justice (<a href="https://assets.publishing.service.gov.uk/media/680a2271532adcaaab3a273e/OMSQ_Q4_2024.pdf">link</a>)</p>



<p class="wp-block-paragraph"><a href="#_ednref4" id="_edn4"><sup>[4]</sup></a><em> Foreign National Offenders: Appeals on Human Rights Grounds 2008 to 2021</em> – Home Office (<a href="https://www.gov.uk/government/publications/foreign-national-offenders-appeals-on-human-rights-grounds-2008-to-2021/statistical-note-fno-appeals-lodged-and-allowed-on-human-rights-grounds-2008-to-2021">link</a>)</p>



<p class="wp-block-paragraph"><a href="#_ednref5" id="_edn5"><sup>[5]</sup></a> Onward analysis and methodology note</p>



<p class="wp-block-paragraph"><a href="#_ednref6" id="_edn6"><sup>[6]</sup></a> Increasing the Capacity of the Prison Estate to Meet Demand – National Audit Office (NAO) (<a href="https://www.nao.org.uk/reports/increasing-the-capacity-of-the-prison-estate-to-meet-demand/?nab=1">link</a>)</p>



<p class="wp-block-paragraph"><a href="#_ednref7" id="_edn7"><sup>[7]</sup></a> Prison Population: Monthly Prison Figures 2025 – Ministry of Justice, October 2025; Onward analysis (<a href="https://www.gov.uk/government/publications/prison-population-monthly-prison-figures-2025">link</a>)</p>



<p class="wp-block-paragraph"><a href="#_ednref8" id="_edn8"><sup>[8]</sup></a> Reducing the Backlog in the Criminal Courts – House of Commons Committee of Public Accounts, UK Parliament (<a href="https://committees.parliament.uk/publications/9159/documents/159649/default/">link</a>).&nbsp;</p>



<p class="wp-block-paragraph"><a href="#_ednref9" id="_edn9"><sup>[9]</sup></a> Criminal Court Statistics Quarterly, January to March 2025 – Ministry of Justice (<a href="https://www.gov.uk/government/statistics/criminal-court-statistics-quarterly-january-to-march-2025/criminal-court-statistics-quarterly-january-to-march-2025">link</a>)</p>



<p class="wp-block-paragraph"><a href="#_ednref10" id="_edn10"><sup>[10]</sup></a> Prison Population Statistics (monthly statistics for August) – Ministry of Justice (<a href="https://www.gov.uk/government/collections/prison-population-statistics">link</a>)</p>



<p class="wp-block-paragraph"><a href="#_ednref11" id="_edn11"><sup>[11]</sup></a> Court waiting times undermine justice / Independent Sentencing Review – Law Society Press Office (<a href="https://www.lawsociety.org.uk/contact-or-visit-us/press-office/press-releases/court-waiting-times-undermine-justice#:~:text=Notes%20to%20editors,about%20the%20Independent%20Sentencing%20Review">link</a>)</p>



<p class="wp-block-paragraph"><a href="#_ednref12" id="_edn12"><sup>[12]</sup></a> “Why are prisons so full in England and Wales?” – The Guardian, 14 September 2024 (<a href="https://www.theguardian.com/society/2024/sep/14/why-are-prisons-so-full-in-england-and-wales">link</a>)</p>



<p class="wp-block-paragraph"><a href="#_ednref13" id="_edn13"><sup>[13]</sup></a> “Why are prisons so full in England and Wales?” – The Guardian, 14 September 2024 (<a href="https://www.theguardian.com/society/2024/sep/14/why-are-prisons-so-full-in-england-and-wales">link</a>)</p>



<p class="wp-block-paragraph"><a href="#_ednref14" id="_edn14"><sup>[14]</sup></a> MoJ, Offender management quarterly April &#8211; June 2025 (<a href="https://www.gov.uk/government/statistics/offender-management-statistics-quarterly-april-to-june-2025/offender-management-statistics-quarterly-april-to-june-2025">link</a>) &amp; MoJ, Offender management quarterly April &#8211; June 2024 (<a href="https://assets.publishing.service.gov.uk/media/67218af33ce5634f5f6ef455/prison-population-30-Sept-2024.ods">link</a>) &amp; MoJ, Offender management quarterly April &#8211; June 2023 (<a href="https://www.gov.uk/government/statistics/offender-management-statistics-quarterly-april-to-june-2023">link</a>) &amp; MoJ, Offender management quarterly April &#8211; June 2022 (<a href="https://www.gov.uk/government/statistics/offender-management-statistics-quarterly-april-to-june-2022">link</a>) &amp; MoJ, Offender management quarterly April &#8211; June 2021 (<a href="https://www.gov.uk/government/statistics/offender-management-statistics-quarterly-april-to-june-2021">link</a>)</p>



<p class="wp-block-paragraph"><a href="#_ednref15" id="_edn15"><sup>[15]</sup></a> “Why are prisons so full in England and Wales?” – The Guardian, 14 September 2024 (<a href="https://www.theguardian.com/society/2024/sep/14/why-are-prisons-so-full-in-england-and-wales">link</a>)</p>



<p class="wp-block-paragraph"><a href="#_ednref16" id="_edn16"><sup>[16]</sup></a> Migrant Convictions and the Prison Population (on over-representation of non-citizens in prison) – Migration Observatory, University of Oxford (<a href="https://migrationobservatory.ox.ac.uk/resources/commentaries/migrant-convictions-and-prison-population/#:~:text=Some%20differences%20in%20conviction%20and%20incarceration%20rates,Significantly%20higher%20share%20of%20non%2Dcitizens%20in%20prison">link</a>)</p>



<p class="wp-block-paragraph"><a href="#_ednref17" id="_edn17"><sup>[17]</sup></a> “Three of Every Four Prisoners Released Are Recalled Back to Prison” – Prisoners’ Advice Service (<a href="https://www.prisonersadvice.org.uk/three-of-every-four-prisoners-released-are-recalled-back-to-prison/">link</a>)</p>



<p class="wp-block-paragraph"><a href="#_ednref18" id="_edn18"><sup>[18]</sup></a> Increasing the Capacity of the Prison Estate to Meet Demand – National Audit Office (NAO) (<a href="https://www.nao.org.uk/reports/increasing-the-capacity-of-the-prison-estate-to-meet-demand/?nab=1">link</a>)</p>



<p class="wp-block-paragraph"><a href="#_ednref19" id="_edn19"><sup>[19]</sup></a> Increasing the Capacity of the Prison Estate to Meet Demand – National Audit Office (NAO) (<a href="https://www.nao.org.uk/reports/increasing-the-capacity-of-the-prison-estate-to-meet-demand/?nab=1">link</a>)</p>



<p class="wp-block-paragraph"><a href="#_ednref20" id="_edn20"><sup>[20]</sup></a> Prisons Capacity and Performance – Parliamentary Office of Science and Technology (POST), UK Parliament, 7 October 2024 (<a href="https://post.parliament.uk/prisons-capacity-and-performance/">link</a>)</p>



<p class="wp-block-paragraph"><a href="#_ednref21" id="_edn21"><sup>[21]</sup></a> BBC News report on early release of prisoners due to capacity pressures (early release numbers in England and Wales) – BBC News (<a href="https://www.bbc.co.uk/news/articles/c93x001ve9ko">link</a>)</p>



<p class="wp-block-paragraph"><a href="#_ednref22" id="_edn22"><sup>[22]</sup></a> Prison Population Statistics – Ministry of Justice (<a href="https://assets.publishing.service.gov.uk/media/690dc81f43f8a163237298b4/prison-pop-october-2025.ods">link</a>) &amp; Approval Tracking – More in Common (<a href="https://www.moreincommon.org.uk/media/jgzjkqos/approval-tracking-and-labour-corruption.xlsx">link</a>)</p>



<p class="wp-block-paragraph"><a href="#_ednref23" id="_edn23"><sup>[23]</sup></a>&nbsp; Performance Tracker (Prisons) – Institute for Government; Increasing the Capacity of the Prison Estate to Meet Demand – National Audit Office; Prison Population Projections 2024 to 2029 – Ministry of Justice; Onward analysis (<a href="https://www.instituteforgovernment.org.uk/publication/performance-tracker-2023/prisons">link</a>) (<a href="https://www.nao.org.uk/reports/increasing-the-capacity-of-the-prison-estate-to-meet-demand/?nab=1">link</a>) (<a href="https://www.gov.uk/government/statistics/prison-population-projections-2024-to-2029/prison-population-projections-2024-to-2029?utm_source=chatgpt.com">link</a>)</p>



<p class="wp-block-paragraph"><a href="#_ednref24" id="_edn24"><sup>[24]</sup></a> Performance Tracker (Prisons) – Institute for Government; Increasing the Capacity of the Prison Estate to Meet Demand – National Audit Office; Prison Population Projections 2024 to 2029 – Ministry of Justice; Onward analysis (<a href="https://www.instituteforgovernment.org.uk/publication/performance-tracker-2023/prisons">link</a>) (<a href="https://www.nao.org.uk/reports/increasing-the-capacity-of-the-prison-estate-to-meet-demand/?nab=1">link</a>) (<a href="https://www.gov.uk/government/statistics/prison-population-projections-2024-to-2029/prison-population-projections-2024-to-2029?utm_source=chatgpt.com">link</a>)</p>



<p class="wp-block-paragraph"><a href="#_ednref25" id="_edn25"><sup>[25]</sup></a> The Telegraph, <em>David Lammy: I didn’t have a;; the facts to tell MPs about accidental releases,</em> 6th November 2025 (<a href="https://www.telegraph.co.uk/politics/2025/11/06/lammy-prisoners-accidentally-released/">link</a>).</p>



<p class="wp-block-paragraph"><a href="#_ednref26" id="_edn26"><sup>[26]</sup></a> The Ministry of Justice, <em>Releases in error data,</em> (<a href="https://data.justice.gov.uk/prisons/additional/releases-in-error#:~:text=A%20prisoner%20is%20released%20in,probation%20service%20annual%20digest%20publication.">link</a>).</p>



<p class="wp-block-paragraph"><a href="#_ednref27" id="_edn27"><sup>[27]</sup></a> Offender Management Statistics Quarterly, Q4 2024 – Ministry of Justice (<a href="https://assets.publishing.service.gov.uk/media/680a2271532adcaaab3a273e/OMSQ_Q4_2024.pdf">link</a>)</p>



<p class="wp-block-paragraph"><a href="#_ednref28" id="_edn28"><sup>[28]</sup></a> Onward analysis</p>



<p class="wp-block-paragraph"><a href="#_ednref29" id="_edn29"><sup>[29]</sup></a> Offender management statistics quarterly: January to March 2024&nbsp; – Ministry of Justice (<a href="https://www.gov.uk/government/statistics/offender-management-statistics-quarterly-january-to-march-2024">link</a>)</p>



<p class="wp-block-paragraph"><a href="#_ednref30" id="_edn30"><sup>[30]</sup></a> Prison Population: Monthly Prison Figures 2025 (October) – Ministry of Justice (<a href="https://www.gov.uk/government/publications/prison-population-monthly-prison-figures-2025">link</a>)</p>



<p class="wp-block-paragraph"><a href="#_ednref31" id="_edn31"><sup>[31]</sup></a> Onward analysis</p>



<p class="wp-block-paragraph"><a href="#_ednref32" id="_edn32"><sup>[32]</sup></a> Foreign National Offenders in UK Prisons: Powers to Deport – House of Lords Library (<a href="https://lordslibrary.parliament.uk/foreign-national-offenders-in-uk-prisons-powers-to-deport/">link</a>)</p>



<p class="wp-block-paragraph"><a href="#_ednref33" id="_edn33"><sup>[33]</sup></a> TaxPayer’s Alliance analysis (<a href="https://www.taxpayersalliance.com/_analysis_up_to_600_million_cost_to_taxpayers_of_keeping_foreign_national_offenders_in_prison">link</a>)</p>



<p class="wp-block-paragraph"><a href="#_ednref34" id="_edn34"><sup>[34]</sup></a> The Daily Express, <em>Shocking cost of locking up foreign criminals in British jails </em>(<a href="https://www.express.co.uk/news/politics/1964074/Prisons-jails-cost-foreign-criminals">link</a>)</p>



<p class="wp-block-paragraph"><a href="#_ednref35" id="_edn35"><sup>[35]</sup></a> Crown Prosecution Service Annual Report and Accounts 2024–2025 – Crown Prosecution Service (<a href="https://assets.publishing.service.gov.uk/media/6880fa32901d5f8d47120560/Crown_Prosecution_Service_annual_report_and_accounts_2024_-_2025.pdf">link</a>); CPS Data Summary Q4 2024–2025 – CPS (<a href="https://www.cps.gov.uk/publication/cps-data-summary-quarter-4-2019-2020">link</a>); Costs per Place / Costs per Prisoner 2023–2024 Summary – Ministry of Justice (<a href="https://www.cps.gov.uk/publication/cps-data-summary-quarter-4-2019-2020">link</a>); Written Parliamentary Question UIN 4727 (30 Nov 2023) – UK Parliament (<a href="https://questions-statements.parliament.uk/written-questions/detail/2023-11-30/4727/">link</a>); Offender Management Statistics Quarterly Q4 2024 – Ministry of Justice; Onward analysis (<a href="https://assets.publishing.service.gov.uk/media/5ea98ea3e90e0723bad309c0/Offender_Management_Statistics_Quarterly_Q4_2019.pdf">link</a>)</p>



<p class="wp-block-paragraph"><a href="#_ednref36" id="_edn36"><sup>[36]</sup></a> Onward analysis</p>



<p class="wp-block-paragraph"><a href="#_ednref37" id="_edn37"><sup>[37]</sup></a> “Rachel Reeves feels budget heat” – The Times (<a href="https://www.thetimes.com/uk/politics/article/rachel-reeves-budget-government-borrowing-g0srhp3j0?t=1756885544561">link</a>)</p>



<p class="wp-block-paragraph"><a href="#_ednref38" id="_edn38"><sup>[38]</sup></a> Typical starting wage for nurses – Nurses.co.uk (<a href="https://www.nurses.co.uk/nhs-pay-calculator">link</a>); Teacher pay and benefits – Get Into Teaching (Department for Education); Onward analysis (<a href="https://getintoteaching.education.gov.uk/life-as-a-teacher/pay-and-benefits/teacher-pay">link</a>)</p>



<p class="wp-block-paragraph"><a href="#_ednref39" id="_edn39"><sup>[39]</sup></a> Metropolitan Police starting salary information (<a href="https://www.met.police.uk/police-forces/metropolitan-po...20will%20receive%20a%20starting,the%20longer%20you%20work%20here">link</a>); Metropolitan Police FOI disclosure on lifetime cost per officer; Onward analysis (<a href="https://www.met.police.uk/foi-ai/metropolitan-police/di...20officer%20over%20the,period%20is%20approximately%20%C2%A3210k">link</a>)</p>



<p class="wp-block-paragraph"><a href="#_ednref40" id="_edn40"><sup>[40]</sup></a> HM Prison &amp; Probation Service, <em>Prison Officer Pay</em> (<a href="https://prisonandprobationjobs.gov.uk/roles-at-hmpps/prison-officer/prison-officer-pay/#:~:text=When%20you%20start%20your%20career,you%20earn%20will%20depend%20on:">link</a>).</p>



<p class="wp-block-paragraph"><a href="#_ednref41" id="_edn41"><sup>[41]</sup></a> Immigration Act 1971 – UK Parliament (<a href="https://www.legislation.gov.uk/ukpga/1971/77/contents">link</a>); UK Borders Act 2007 – UK Parliament (<a href="https://www.legislation.gov.uk/ukpga/2007/30/contents">link</a>)</p>



<p class="wp-block-paragraph"><a href="#_ednref42" id="_edn42"><sup>[42]</sup></a> UK Borders Act 2007 – UK Parliament (<a href="https://www.legislation.gov.uk/ukpga/2007/30/contents">link</a>)</p>



<p class="wp-block-paragraph"><a href="#_ednref43" id="_edn43"><sup>[43]</sup></a> European Convention on Human Rights (full text) – Council of Europe (<a href="https://www.echr.coe.int/documents/d/echr/convention_ENG">link</a>)</p>



<p class="wp-block-paragraph"><a href="#_ednref44" id="_edn44"><sup>[44]</sup></a> European Convention on Human Rights (full text) – Council of Europe (<a href="https://www.echr.coe.int/documents/d/echr/convention_ENG">link</a>)</p>



<p class="wp-block-paragraph"><a href="#_ednref45" id="_edn45"><sup>[45]</sup></a> R (Razgar) v Secretary of State for the Home Department [2004] UKHL 27 (<a href="https://publications.parliament.uk/pa/ld200304/ldjudgmt/jd040617/razgar-1.htm">link</a>); Huang v Secretary of State for the Home Department [2007] UKHL 11 – House of Lords judgments (<a href="https://publications.parliament.uk/pa/ld200607/ldjudgmt/jd070321/huang%20-1.htm">link</a>)</p>



<p class="wp-block-paragraph"><a href="#_ednref46" id="_edn46"><sup>[46]</sup></a> Foreign National Offenders in UK Prisons: Powers to Deport – House of Lords Library (<a href="https://lordslibrary.parliament.uk/foreign-national-offenders-in-uk-prisons-powers-to-deport/">link</a>)</p>



<p class="wp-block-paragraph"><a href="#_ednref47" id="_edn47"><sup>[47]</sup></a> Foreign National Offenders in UK Prisons: Powers to Deport – House of Lords Library (<a href="https://lordslibrary.parliament.uk/foreign-national-offenders-in-uk-prisons-powers-to-deport/">link</a>)</p>



<p class="wp-block-paragraph"><a href="#_ednref48" id="_edn48"><sup>[48]</sup></a> Foreign National Offenders in UK Prisons: Powers to Deport – House of Lords Library (<a href="https://lordslibrary.parliament.uk/foreign-national-offenders-in-uk-prisons-powers-to-deport/">link</a>)</p>



<p class="wp-block-paragraph"><a href="#_ednref49" id="_edn49"><sup>[49]</sup></a> Immigration (Removal of Foreign National Offenders) Regulations 2025 (SI 2025/9780348273168, 23 September 2025) – UK legislation (<a href="https://www.legislation.gov.uk/ukdsi/2025/9780348273168/introduction/2025-09-23">link</a>)</p>



<p class="wp-block-paragraph"><a href="#_ednref50" id="_edn50"><sup>[50]</sup></a> In brief: Deportation and early removal of foreign national offenders – House of Commons Library, 2 February 2024 (Debate Pack / Research Briefing) (<a href="https://commonslibrary.parliament.uk/research-briefings/cdp-2024-0023/">link</a>).</p>



<p class="wp-block-paragraph"><a href="#_ednref51" id="_edn51"><sup>[51]</sup></a> Foreign National Offenders in UK Prisons: Powers to Deport – House of Lords Library (<a href="https://lordslibrary.parliament.uk/foreign-national-offenders-in-uk-prisons-powers-to-deport/">link</a>)</p>



<p class="wp-block-paragraph"><a href="#_ednref52" id="_edn52"><sup>[52]</sup></a> Foreign National Offenders in UK Prisons: Powers to Deport – House of Lords Library (<a href="https://lordslibrary.parliament.uk/foreign-national-offenders-in-uk-prisons-powers-to-deport/">link</a>)</p>



<p class="wp-block-paragraph"><a href="#_ednref53" id="_edn53"><sup>[53]</sup></a> Ministry of Justice returns summary table 2010–2024 – Ministry of Justice (<a href="https://www.gov.uk/government/statistical-data-sets/immigration-system-statistics-data-tables#returns">link</a>)</p>



<p class="wp-block-paragraph"><a href="#_ednref54" id="_edn54"><sup>[54]</sup></a> Immigration System Statistics: “How many people are returned from the UK?” – Home Office, year ending June 2025 (<a href="https://www.gov.uk/government/statistics/immigration-system-statistics-year-ending-june-2025/how-many-people-are-returned-from-the-uk#s-5">link</a>)</p>



<p class="wp-block-paragraph"><a href="#_ednref55" id="_edn55"><sup>[55]</sup></a> Deportation of foreign national offenders – House of Commons Library Research Briefing, 2 August 2024 (Briefing Paper 8062) (<a href="https://researchbriefings.files.parliament.uk/documents/CBP-8062/CBP-8062.pdf">link</a>)</p>



<p class="wp-block-paragraph"><a href="#_ednref56" id="_edn56"><sup>[56]</sup></a>&nbsp; Deportation of foreign national offenders – House of Commons Library Research Briefing, 2 August 2024 (Briefing Paper 8062) (<a href="https://researchbriefings.files.parliament.uk/documents/CBP-8062/CBP-8062.pdf">link</a>)</p>



<p class="wp-block-paragraph"><a href="#_ednref57" id="_edn57"><sup>[57]</sup></a> Immigration System Statistics: “How many people are returned from the UK?” – Home Office, year ending June 2025 (<a href="https://www.gov.uk/government/statistics/immigration-system-statistics-year-ending-june-2025/how-many-people-are-returned-from-the-uk#s-5">link</a>)</p>



<p class="wp-block-paragraph"><a href="#_ednref58" id="_edn58"><sup>[58]</sup></a> Immigration System Statistics: “How many people are returned from the UK?” – Home Office, year ending June 2025 (<a href="https://www.gov.uk/government/statistics/immigration-system-statistics-year-ending-june-2025/how-many-people-are-returned-from-the-uk#s-5">link</a>)</p>



<p class="wp-block-paragraph"><a href="#_ednref59" id="_edn59"><sup>[59]</sup></a> “UK and Albania agree groundbreaking new arrangement on prisoner transfers” – UK Government / Home Office news release (<a href="https://www.gov.uk/government/news/uk-and-albania-agree-groundbreaking-new-arrangement-on-prisoner-transfers">link</a>)</p>



<p class="wp-block-paragraph"><a href="#_ednref60" id="_edn60"><sup>[60]</sup></a> “UK and Albania agree groundbreaking new arrangement on prisoner transfers” – UK Government / Home Office news release (<a href="https://www.gov.uk/government/news/uk-and-albania-agree-groundbreaking-new-arrangement-on-prisoner-transfers">link</a>)</p>



<p class="wp-block-paragraph"><a href="#_ednref61" id="_edn61"><sup>[61]</sup></a> Foreign National Offenders: appeals lodged and allowed on human rights grounds, 2008 to 2021 – Home Office (<a href="https://www.gov.uk/government/publications/foreign-national-offenders-appeals-on-human-rights-grounds-2008-to-2021/statistical-note-fno-appeals-lodged-and-allowed-on-human-rights-grounds-2008-to-2021">link</a>)</p>



<p class="wp-block-paragraph"><a href="#_ednref62" id="_edn62"><sup>[62]</sup></a> Foreign National Offenders: appeals lodged and allowed on human rights grounds, 2008 to 2021 – Home Office (<a href="https://www.gov.uk/government/publications/foreign-national-offenders-appeals-on-human-rights-grounds-2008-to-2021/statistical-note-fno-appeals-lodged-and-allowed-on-human-rights-grounds-2008-to-2021">link</a>)</p>



<p class="wp-block-paragraph"><a href="#_ednref63" id="_edn63"><sup>[63]</sup></a> Human Rights Act 1998, Schedule 1 Part I, Chapter 7 – UK legislation (<a href="https://www.legislation.gov.uk/ukpga/1998/42/schedule/1/part/I/chapter/7">link</a>)</p>



<p class="wp-block-paragraph"><a href="#_ednref64" id="_edn64"><sup>[64]</sup></a> “Criminality: Article 8 ECHR cases” (Article 8 public interest / exceptions guidance) – Home Office guidance (<a href="https://www.gov.uk/government/publications/criminality-guidance-in-article-8-echr-cases/criminality-article-8-echr-cases-accessible#:~:text=The%20Article%208%20exceptions%20to,3">link</a>)</p>



<p class="wp-block-paragraph"><a href="#_ednref65" id="_edn65"><sup>[65]</sup></a>&nbsp; “Criminality: Article 8 ECHR cases” (Article 8 public interest / exceptions guidance) – Home Office guidance (<a href="https://www.gov.uk/government/publications/criminality-guidance-in-article-8-echr-cases/criminality-article-8-echr-cases-accessible#:~:text=The%20Article%208%20exceptions%20to,3">link</a>)</p>



<p class="wp-block-paragraph"><a href="#_ednref66" id="_edn66"><sup>[66]</sup></a> Coates J., “Criminal’s deportation case halted over son’s dislike for chicken nuggets”, <em>The Independent</em> (<a href="https://www.independent.co.uk/news/uk/home-news/albania-deportation-chcken-nuggets-home-office-b2695233.html">link</a>)</p>



<p class="wp-block-paragraph"><a href="#_ednref67" id="_edn67"><sup>[67]</sup></a> Cornell Law School, <em>Withdrawal of application for admission</em>, (<a href="https://www.law.cornell.edu/cfr/text/8/1235.4">link</a>).</p>



<p class="wp-block-paragraph"><a href="#_ednref68" id="_edn68"><sup>[68]</sup></a> Catholic Legal Immigration Network, Inc., ‘The Unlawful Presence Bars: Do They Continue to Run After Reentry to the United States?’ 2020 (<a href="https://www.cliniclegal.org/resources/ground-inadmissibility-and-deportability/unlawful-presence-bars-do-they-continue-run">link</a>)</p>



<p class="wp-block-paragraph"><a href="#_ednref69" id="_edn69"><sup>[69]</sup></a> United States Government Accountability Office, <em>Border Patrol: Actions Needed to Improve Oversight of Post-Apprehension Consequences</em> 2017 (<a href="https://www.gao.gov/assets/gao-17-66.pdf">link</a>)</p>



<p class="wp-block-paragraph"><a href="#_ednref70" id="_edn70"><sup>[70]</sup></a> “Expulsion of foreigners and case law” – Border Criminologies Blog, Centre for Criminology, University of Oxford, February 2020 (<a href="https://blogs.law.ox.ac.uk/research-subject-groups/centre-criminology/centreborder-criminologies/blog/2020/02/expulsion">link</a>)</p>



<p class="wp-block-paragraph"><a href="#_ednref71" id="_edn71"><sup>[71]</sup></a> “Sustitución de la pena de prisión por expulsión” (substituting prison sentences with expulsión) – Consejo General de la Abogacía Española (<a href="https://www.abogacia.es/en/publicaciones/blogs/blog-derecho-penitenciario/sustitucion-de-la-pena-de-prision-por-expulsion/">link</a>)</p>



<p class="wp-block-paragraph"><a href="#_ednref72" id="_edn72"><sup>[72]</sup></a> “More foreign criminals to be deported under expanded scheme” – BBC News (<a href="https://www.bbc.co.uk/news/articles/cyvnnj301l3o">link</a>); Home Office NS (<a href="https://www.gov.uk/government/news/more-foreign-criminals-to-be-deported-before-appeals-heard#:~:text='Deport%20Now%20Appeal%20Later'%20scheme,from%20overseas%20using%20video%20technology.">link</a>)</p>



<p class="wp-block-paragraph"><a href="#_ednref73" id="_edn73"><sup>[73]</sup></a> Legal Aid Crime Higher: total expenditure and workload volume (<a href="https://data.justice.gov.uk/legalaid/legal-aid-crime-higher#legal-aid-crimehigher-total-expenditure-value">link</a>); Litigator Graduated Fee Scheme workload and spend – Ministry of Justice data (<a href="https://data.justice.gov.uk/legalaid/legal-aid-crime-higher#legal-aid-crime-litigatorgraduatedfeescheme-workload-volume">link</a>)</p>



<p class="wp-block-paragraph"><a href="#_ednref74" id="_edn74"><sup>[74]</sup></a> Crown Prosecution Service Annual Report and Accounts 2024–2025 – Crown Prosecution Service (<a href="https://assets.publishing.service.gov.uk/media/6880fa32...n_Prosecution_Service_annual_report_and_accounts_2024_-_2025.pdf">link</a>); CPS Annual Report 2023–2024 – Crown Prosecution Service (<a href="https://www.cps.gov.uk/sites/default/files/documents/publications/CPS-Annual-Report-2023-2024.pdf">link</a>)</p>



<p class="wp-block-paragraph"><a href="#_ednref75" id="_edn75"><sup>[75]</sup></a> Reducing the Crown Court Backlog – House of Lords Library, 13 March 2025 (<a href="https://lordslibrary.parliament.uk/reducing-the-crown-court-backlog">link</a>)</p>



<p class="wp-block-paragraph"><a href="#_ednref76" id="_edn76"><sup>[76]</sup></a> Sentencing types and criminal justice system statistics – Sentencing Council for England and Wales (<a href="https://sentencingcouncil.org.uk/about-sentencing/types...justice%20system%20%20statistics%20%20quarterly%20%20publication">link</a>)</p>



<p class="wp-block-paragraph"><a href="#_ednref77" id="_edn77"><sup>[77]</sup></a> Typical starting wage for nurses – Nurses.co.uk (<a href="https://www.nurses.co.uk/blog/what-s-the-typical-starti...#:~:text=Claire%20Carmichael,rise%20announced%20in%20May%202025">link</a>)</p>



<p class="wp-block-paragraph"><a href="#_ednref78" id="_edn78"><sup>[78]</sup></a> Teacher pay and benefits – Get Into Teaching (Department for Education) (<a href="https://getintoteaching.education.gov.uk/life-as-a-teacher/pay-and-benefits/teacher-pay">link</a>)</p>



<p class="wp-block-paragraph"><a href="#_ednref79" id="_edn79"><sup>[79]</sup></a> Metropolitan Police starting salary information (<a href="https://www.met.police.uk/police-forces/metropolitan-po...20will%20receive%20a%20starting,the%20longer%20you%20work%20here">link</a>); Metropolitan Police FOI disclosure on lifetime cost per police officer (<a href="https://www.met.police.uk/foi-ai/metropolitan-police/di...20officer%20over%20the,period%20is%20approximately%20%C2%A3210k">link</a>)</p>



<p class="wp-block-paragraph"><a href="#_ednref80" id="_edn80"><sup>[80]</sup></a> HM Prison &amp; Probation Service, <em>Prison Officer Pay</em> (<a href="https://prisonandprobationjobs.gov.uk/roles-at-hmpps/prison-officer/prison-officer-pay/#:~:text=When%20you%20start%20your%20career,you%20earn%20will%20depend%20on:">link</a>).</p>
<p>The post <a href="https://ukonward.com/reports/the-cost-of-strangers/">The Cost of Strangers</a> appeared first on <a href="https://ukonward.com">Onward</a>.</p>
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		<title>Britain isn’t working</title>
		<link>https://ukonward.com/onward-corner/britain-isnt-working/</link>
		
		<dc:creator><![CDATA[Joanna Marchong]]></dc:creator>
		<pubDate>Thu, 13 Nov 2025 15:22:53 +0000</pubDate>
				<category><![CDATA[Reshaping the State]]></category>
		<category><![CDATA[Welfare]]></category>
		<guid isPermaLink="false">https://ukonward.com/?post_type=onward-corner&#038;p=41051</guid>

					<description><![CDATA[<p>Columns are the author&#8217;s own opinion and do not necessarily reflect the views of Onward. &#8212;&#8212;&#8212; “Our welfare system is broken, it is indefensible, economically and morally, and we must and we will reform it.”  Not the words of a Conservative, but those of the Prime Minister back in March. Yet, weeks later, he was [&#8230;]</p>
<p>The post <a href="https://ukonward.com/onward-corner/britain-isnt-working/">Britain isn’t working</a> appeared first on <a href="https://ukonward.com">Onward</a>.</p>
]]></description>
										<content:encoded><![CDATA[
<p class="has-small-font-size wp-block-paragraph"><em>Columns are the author&#8217;s own opinion and do not necessarily reflect the views of Onwar</em>d.</p>



<p class="wp-block-paragraph">&#8212;&#8212;&#8212;</p>



<p class="wp-block-paragraph"><br><em>“Our welfare system is broken, it is indefensible, economically and morally, and we must and we will reform it.” </em></p>



<p class="wp-block-paragraph">Not the words of a Conservative, but those of the Prime Minister back in March. Yet, weeks later, he was forced to abandon minor changes to the disability benefits system by Labour backbenchers. Now the Government’s attempts at meaningful reform and reducing spend have been abandoned altogether. It turns out that soundbites were never going to be enough to enable the serious analysis that is needed for our welfare system to be reformed in a way that provides support for those that need it, and helps those who don’t get into work.&nbsp;</p>



<p class="wp-block-paragraph">Our welfare system, originally designed to help those in need live normal fulfilling lives, has evolved, becoming something almost unrecognisable. There is a growing recognition that we have created a system that actively disincentivises millions of people from work. Conversations with employers, charities and those claiming benefits reveal a pattern that is becoming hard to ignore. For many, the welfare system no longer provides a route back to work. Instead, it encourages people to not even try. It is disastrous for those individuals whose life chances are affected &#8211; and catastrophic for the country’s finances.</p>



<p class="wp-block-paragraph">There are examples everywhere. Businesses say they cannot fill apprenticeship places despite the fact that those who succeed could earn salaries of £50,000 within a few years. The roles remain unfilled despite unemployment rising over the past year. Why? Because, for many potential applicants, sickness benefits offer a higher income than the minimum wage, and once someone is signed off, it can be far easier, and in some cases better paying, to stay in the system than to step out of it. The result is wasted potential on both sides: employers desperate for workers and young people who never get the incentive to try.&nbsp;</p>



<p class="wp-block-paragraph">This experience reflects a broader structural issue in the welfare system: rather than simply providing a safety net, a swathe of benefits and support schemes have created conditions where staying on benefits is more attractive. The Personal Independence Payment traps people into inactivity. Examples of this are not hard to find, there are plenty of stories of people turning down courses and training that could have helped them build careers due to fear that it would be taken as evidence that he no longer needed extra support.&nbsp;</p>



<p class="wp-block-paragraph">Worse still, there is an entire commercial ecosystem for advisers who profit from advising vulnerable claimants: “sickfluencers”, paid for advice guides, application coaches &#8211; all helping applicants game the system to maximise the chances of claims being accepted.&nbsp;</p>



<p class="wp-block-paragraph">The same pattern exists for fit notes. GPs are being asked to make judgements about a person’s capacity for work that they often feel unqualified to make. Fit notes are sometimes issued after brief phone calls and often renewed without review. Some patients have even been asked how long they would like to be signed off. What should be a temporary measure has become, for many, a gateway to long-term absence from work.</p>



<p class="wp-block-paragraph">These examples show how far the welfare system has strayed from its purpose. Work is not only a means of earning; it provides routine, confidence and connection. For people managing long-term health conditions, being in work can often improve wellbeing rather than harm it. Yet the system is structured in ways that reinforce dependency. The focus remains on incapacity rather than on the adaptations that could make employment possible. A welfare state that truly reflects compassion would support people in rebuilding their independence, not assume that their limitations define them.</p>



<p class="wp-block-paragraph">There are practical steps that could begin to repair this. Initial benefit assessments should return to being face to face, allowing for a more accurate understanding of what claimants can do. Sick notes should involve proper medical review, with responsibility shared across health and employment services rather than resting solely with GPs. Benefits for minor or short-term conditions should be replaced with targeted support to help people back into work. Schemes offering discounted products and services should be limited only to those with serious medical conditions. Most importantly, disability benefits should only be available for those with serious conditions.</p>



<p class="wp-block-paragraph">Reform will require a shift in attitude, one that sees work as part of recovery and welfare as a means to restore independence. The welfare system can still be a source of pride if it once again rewards effort, encourages aspiration and ensures that help is reserved for those who truly need it.</p>



<p class="wp-block-paragraph">I have seen how an effective system can work. A friend of mine has autism and ADHD and struggles in conventional workplaces. The noise, the interruptions, and the unspoken social rules make it almost impossible for her to function in an office. Yet when she is given the chance to work from home, to set her own hours, and to concentrate during the quiet of the night, she thrives. She does not need a subsidised BMW through Motability, nor coaching on how to navigate a PIP form. What she needs is flexibility and minor adjustments in workplaces that allow her to contribute at her best. That is what genuine support should mean: removing practical barriers and creating conditions where people can succeed, rather than providing perks that do nothing to address the real challenges of disability.</p>



<p class="wp-block-paragraph">Britain’s strength has always come from the willingness of its people to work hard and build a future. The task now is to design a welfare system that reflects that same spirit, one that enables the maximum number of people who can work to do so.</p>
<p>The post <a href="https://ukonward.com/onward-corner/britain-isnt-working/">Britain isn’t working</a> appeared first on <a href="https://ukonward.com">Onward</a>.</p>
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		<title>The quiet collapse of Welsh education</title>
		<link>https://ukonward.com/press/the-quiet-collapse-of-welsh-education/</link>
		
		<dc:creator><![CDATA[Joanna Marchong]]></dc:creator>
		<pubDate>Tue, 09 Sep 2025 15:50:08 +0000</pubDate>
				<category><![CDATA[Reshaping the State]]></category>
		<category><![CDATA[Education]]></category>
		<guid isPermaLink="false">https://ukonward.com/?post_type=press&#038;p=40540</guid>

					<description><![CDATA[<p>"For more than a quarter of a century, the Welsh Labour government has presided over the slow betrayal of its own children."</p>
<p>The post <a href="https://ukonward.com/press/the-quiet-collapse-of-welsh-education/">The quiet collapse of Welsh education</a> appeared first on <a href="https://ukonward.com">Onward</a>.</p>
]]></description>
										<content:encoded><![CDATA[<p>The post <a href="https://ukonward.com/press/the-quiet-collapse-of-welsh-education/">The quiet collapse of Welsh education</a> appeared first on <a href="https://ukonward.com">Onward</a>.</p>
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		<title>Wales could fall behind Romania in education standards</title>
		<link>https://ukonward.com/press/wales-could-fall-behind-romania-in-education-standards/</link>
		
		<dc:creator><![CDATA[Joanna Marchong]]></dc:creator>
		<pubDate>Sun, 07 Sep 2025 10:14:09 +0000</pubDate>
				<category><![CDATA[Reshaping the State]]></category>
		<category><![CDATA[Devolution and Local Government]]></category>
		<guid isPermaLink="false">https://ukonward.com/?post_type=press&#038;p=40975</guid>

					<description><![CDATA[<p>That is the warning from a new report by the think tank Onward, which compared the performance of Welsh students to international benchmarks.</p>
<p>The post <a href="https://ukonward.com/press/wales-could-fall-behind-romania-in-education-standards/">Wales could fall behind Romania in education standards</a> appeared first on <a href="https://ukonward.com">Onward</a>.</p>
]]></description>
										<content:encoded><![CDATA[
<p class="wp-block-paragraph">That is the warning from a new report by the think tank Onward, which compared the performance of Welsh students to international benchmarks.</p>
<p>The post <a href="https://ukonward.com/press/wales-could-fall-behind-romania-in-education-standards/">Wales could fall behind Romania in education standards</a> appeared first on <a href="https://ukonward.com">Onward</a>.</p>
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		<title>Wales set to be overtaken by Romania in education by 2040 &#8211; new report</title>
		<link>https://ukonward.com/press/wales-set-to-be-overtaken-by-romania-in-education-by-2040-new-report/</link>
		
		<dc:creator><![CDATA[Joanna Marchong]]></dc:creator>
		<pubDate>Mon, 01 Sep 2025 14:29:49 +0000</pubDate>
				<category><![CDATA[Reshaping the State]]></category>
		<guid isPermaLink="false">https://ukonward.com/?post_type=press&#038;p=40482</guid>

					<description><![CDATA[<p>“Wales has the lowest education outcomes in the UK – and the gap is set to grow."</p>
<p>The post <a href="https://ukonward.com/press/wales-set-to-be-overtaken-by-romania-in-education-by-2040-new-report/">Wales set to be overtaken by Romania in education by 2040 &#8211; new report</a> appeared first on <a href="https://ukonward.com">Onward</a>.</p>
]]></description>
										<content:encoded><![CDATA[<p>The post <a href="https://ukonward.com/press/wales-set-to-be-overtaken-by-romania-in-education-by-2040-new-report/">Wales set to be overtaken by Romania in education by 2040 &#8211; new report</a> appeared first on <a href="https://ukonward.com">Onward</a>.</p>
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		<title>Statejacket</title>
		<link>https://ukonward.com/reports/statejacket/</link>
		
		<dc:creator><![CDATA[Joanna Marchong]]></dc:creator>
		<pubDate>Fri, 29 Aug 2025 01:00:00 +0000</pubDate>
				<category><![CDATA[Reshaping the State]]></category>
		<guid isPermaLink="false">https://ukonward.com/?post_type=reports&#038;p=40403</guid>

					<description><![CDATA[<p>Foreword &#160;“How did you go bankrupt?” Bill asked “Two ways”, Mike said.&#160; “Gradually, then suddenly.” Ernest Hemingway, The Sun Also Rises (1926) ***** Political debate operates at different levels. Much of ours focuses on proximate issues &#8211; a ministerial scandal, a surge in small boats, a particularly horrific crime. But there are also long-term trends, [&#8230;]</p>
<p>The post <a href="https://ukonward.com/reports/statejacket/">Statejacket</a> appeared first on <a href="https://ukonward.com">Onward</a>.</p>
]]></description>
										<content:encoded><![CDATA[
<h3 class="wp-block-heading">Foreword</h3>



<p class="wp-block-paragraph">&nbsp;<em>“How did you go bankrupt?” Bill asked</em></p>



<p class="wp-block-paragraph"><em>“Two ways”, Mike said.&nbsp; “Gradually, then suddenly.”</em></p>



<p class="wp-block-paragraph">Ernest Hemingway, The Sun Also Rises (1926)</p>



<p class="wp-block-paragraph">*****</p>



<p class="wp-block-paragraph">Political debate operates at different levels. Much of ours focuses on proximate issues &#8211; a ministerial scandal, a surge in small boats, a particularly horrific crime. But there are also long-term trends, which may burn more slowly, but ultimately scorch the deepest.&nbsp; Chief amongst these in modern Britain is the size and affordability of the state, and the severe risk to the public finances it now represents.</p>



<p class="wp-block-paragraph">This paper, and the <em>Reshaping the State</em> programme it launches, is incredibly important.&nbsp; It is a deeply sobering read. Britain is going bankrupt, and has been for a long time. We are now at grave risk of entering the “suddenly” phase of Hemingway’s words a century ago. &nbsp;</p>



<p class="wp-block-paragraph">It is now over 25 years since the budget was last in surplus, let alone bearing down on the debt. By 2030, public sector net debt (PSND) is projected to have quintupled since the 2008 financial crisis. Even using the Chancellor’s preferred measure in her fiscal rules of public sector net financial liabilities (PSNFL) rather than PSND, the figure may be lower, but the trajectory is broadly similar. &nbsp;</p>



<p class="wp-block-paragraph">We are not alone among western societies in facing these challenges. In August 2025, the German Chancellor Friedrich Merz warned, “The welfare state that we have today can no longer be financed by what we produce in the economy.” But Britain’s challenges of an overmighty state and an underperforming economy are particularly acute, testified to most eloquently by the fact we now pay more than any G7 economy to finance our debt – a risk premium priced in by the financial markets. &nbsp;</p>



<p class="wp-block-paragraph">Worse still, we now have a Parliament dominated by Labour MPs who are apparently totally unable to countenance any reductions in public spending. When the Government tried to make welfare reforms earlier this year, ministers were forced into humiliating retreat, and ended up in the ludicrous position of actually increasing the total cost to the taxpayer.</p>



<p class="wp-block-paragraph">I served as Chief Secretary to the Treasury 2021-22, and it is my sincere conviction that if anything, the financial markets still underprice the risks to Britain’s fiscal sustainability. As Caroline Elsom sets out in this paper, the estimate of debt relative to GDP by the 2070s reaching 270% in the OBR’s Fiscal Sustainability report is based on an optimistic assumption of productivity growth at around 1.5% per year: a rate which has not been achieved since before the global financial crisis. In other words, the extent of the sheer unsustainability of our public finances is almost certainly being understated.</p>



<p class="wp-block-paragraph">Much of our political discourse is still oblivious to this ticking timebomb. Government ministers have spent the summer airily opining about scrapping the two child benefit cap, while Reform – currently leading in the polls – rank this as just one of a number of hugely expensive policy commitments. The public largely believe that the Conservative Government 2010-24 implemented deep austerity. The reality is that it did nothing of the kind: some parts of the state, like local government, suffered deep cuts, but others continued to grow apace, and the Covid pandemic then destroyed all spending discipline.</p>



<p class="wp-block-paragraph">We are now in a very dangerous place. We need radical, comprehensive reform to restore not only financial sustainability, but also to end the deep dysfunctionality that now characterises much of the operation of the British state. It is a sickening irony that government in this country has never cost more to achieve less.</p>



<p class="wp-block-paragraph">There is a way out of this situation, but it will be a long and hard one, and will involve very frank and difficult conversations with the public. If we fail to act, the spectre of 1976 looms large again in our national story. Arthur Miller warned, “An era can be said to end when its basic illusions are exhausted.” Now is the time for an end to illusion. It is time to reshape the state.&nbsp;</p>



<h5 class="wp-block-heading"><strong>Sir Simon Clarke</strong></h5>



<h5 class="wp-block-heading"><strong><em>Director, Onward</em></strong></h5>



<h5 class="wp-block-heading">August 2025</h5>



<h3 class="wp-block-heading">Introduction</h3>



<p class="wp-block-paragraph">A fiscal crisis looms in Britain’s future. Heading into the autumn, the Chancellor is facing a range of unpalatable choices if she is to maintain the confidence of the country’s creditors. Barely a year into power, having won a landslide majority in the 2024 General Election, the Labour Government already appears out of options and political capital. &nbsp;</p>



<p class="wp-block-paragraph">The coming crisis is the product of a state that has been growing in scope and scale for decades. Expansion has been driven by politically expedient largesse. It has delivered an NHS the size of Portugal’s entire economy, but one that ranks poorly for avoidable excess deaths. It provides a welfare system that is due to grow by a fifth in the next five years, while a fifth of working-age people are not looking for work.&nbsp; &nbsp;</p>



<p class="wp-block-paragraph">The path and composition of public spending today, and therefore the state itself, is fundamentally unsustainable, uncontrollable and unfair. Unsustainable due to an aging population that is set to draw on further health and welfare spending. Uncontrollable due to the scale of spending decisions that are treated as non-discretionary or ceded ever further away from those who should be making them. And unfair to those who pay taxes to fund the services of today that they may never benefit from themselves.&nbsp; &nbsp;</p>



<p class="wp-block-paragraph">While it should be evident to any politician that drastic action is needed to alter this trajectory, they choose instead to remain bound by a bureaucratic, legal and political straitjacket of the status quo: the “statejacket”. The statejacket sees ministers come and go, only able to pursue a tinkering approach to reform which they know will be insufficient to avert the crisis. It is the height of insanity &#8211; continuing to do the same thing but hoping for a different outcome. But there is still time to recover with an intensive course of treatment. &nbsp;</p>



<p class="wp-block-paragraph">Onward’s new research programme, <em>Reshaping the State, </em>will make the case for a fundamental re-think of the state’s functions and composition. Together with Onward’s programmes on <em>Rebuilding our Economy</em> and <em>Renewing our Social Contract</em>, these three new areas of focus confront the most significant challenges facing Britain today, launching with <em>The Turnaround </em>and <em>The AntiSocial Contract </em>respectively<em>. </em>&nbsp;</p>



<p class="wp-block-paragraph"><em>Statejacket </em>starts by confronting the scale of the problem and the incentives that have led to the current situation at a national and local level, and the state’s relationship to individuals. This diagnosis does not seek to apportion blame, but to understand how the narrow range of policy decisions are leading to ever more perverse outcomes.&nbsp;</p>



<p class="wp-block-paragraph">The research stream it launches will uncover areas of policy that have been woefully neglected, recommending whether some state functions would be better delivered entirely differently &#8211; or not at all. In the work that follows, <em>Reshaping the State </em>will set out the difficult and urgent trade-offs that must be made for the country to break free of the current constraints and thrive.</p>



<h3 class="wp-block-heading">1. National level</h3>



<p class="wp-block-paragraph"><strong>The Prime Minister is grappling with the same challenges as his predecessors: public services which require ever more resources to sustain, whilst struggling at the same time to deliver the quality and range of services that the public has been led to expect. Meanwhile, tax rates, already at record highs, are unable to raise enough revenue while low growth and high inflation persist. As the situation continues unaddressed, debt costs will account for an ever-greater share of spending while delivering no public good. </strong>&nbsp;</p>



<h4 class="wp-block-heading">The state on steroids</h4>



<p class="wp-block-paragraph">Over the last 75 years, the state’s share of the UK economy has generally fluctuated at around 40% of GDP. The COVID-19 pandemic saw a dramatic period of state expansion that took its share of GDP to levels only previously exceeded during the Second World War.<a href="https://docs.google.com/document/d/1bmRN50xTycjXFrdDChykaGSlfvlCEV2jkU2zv7Irhlo/edit#bookmark=id.kho6zmsgk2zj"><sup>1</sup></a><a href="https://docs.google.com/document/d/1bmRN50xTycjXFrdDChykaGSlfvlCEV2jkU2zv7Irhlo/edit#bookmark=id.kho6zmsgk2zj"> </a>&nbsp;</p>



<p class="wp-block-paragraph"><strong>Figure 1 &#8211; Total managed expenditure as a % of GDP</strong></p>



<p class="wp-block-paragraph"><em>Source: OBR</em><a href="https://docs.google.com/document/d/1bmRN50xTycjXFrdDChykaGSlfvlCEV2jkU2zv7Irhlo/edit#bookmark=id.uar2obsmelns"><em><sup>2</sup></em></a></p>



<div class="flourish-embed flourish-chart" data-src="visualisation/24854106"><script src="https://public.flourish.studio/resources/embed.js"></script><noscript><img decoding="async" src="https://public.flourish.studio/visualisation/24854106/thumbnail" width="100%" alt="chart visualization" /></noscript></div>



<p class="wp-block-paragraph">Spending as a proportion of GDP hit 53% in 2020-21, far outstripping the previous post-war peaks reached during the 1976 IMF crisis and the 2008/09 global financial crisis. Crucially, the latest Office for Budget Responsibility (OBR) forecast indicates that the state is unlikely to contract back to 40% over the decade following the pandemic. Unlike previous less severe crises, the path back to normal looks longer and less certain &#8211; the big state seems here to stay.&nbsp;&nbsp;&nbsp;&nbsp;&nbsp;</p>



<p class="wp-block-paragraph">To understand why the post-Covid expansion persists, it is necessary to look at the radical change in the composition of spending. Since the end of the Cold War, declining defence spending has made way for significant relative increases in health and welfare.<sup>4</sup> Health spending was protected after the global financial crisis relative to welfare and education which saw their shares as a proportion of GDP fall. Much larger cuts fell outside of these areas, principally in local government. Public services like the NHS, schools and prisons now account for roughly two thirds of day-to-day spending.<sup>5</sup>&nbsp;&nbsp;&nbsp;</p>



<p class="wp-block-paragraph"><strong>Figure 2 &#8211; Components of total managed expenditure as a % of GDP</strong></p>



<p class="wp-block-paragraph"><em>Source: UK Public Spending</em><a href="https://docs.google.com/document/d/1bmRN50xTycjXFrdDChykaGSlfvlCEV2jkU2zv7Irhlo/edit#bookmark=id.q6a0tc6hy6uo"><em><sup>3</sup></em></a><a href="https://docs.google.com/document/d/1bmRN50xTycjXFrdDChykaGSlfvlCEV2jkU2zv7Irhlo/edit#bookmark=id.q6a0tc6hy6uo"><em> </em></a>&nbsp;</p>



<div class="flourish-embed flourish-chart" data-src="visualisation/24875879"><script src="https://public.flourish.studio/resources/embed.js"></script><noscript><img decoding="async" src="https://public.flourish.studio/visualisation/24875879/thumbnail" width="100%" alt="chart visualization" /></noscript></div>



<p class="wp-block-paragraph">The ambition to reach 2.6% of GDP on defence spending by 2027 and 3% by an indeterminate time in the next parliament, would bring a striking diversion away from previous reliance on the “peace dividend” if actively pursued. With further pressure from NATO to increase defence spending to 3.5% of GDP plus another 1.5% per year in related industries, this may well need to be revised up again at future fiscal events.</p>



<p class="wp-block-paragraph">The outlook for the relatively larger state remaining over the medium term reflects the deep growth crisis that is accompanying this fiscal crisis. As explained in Onward’s <em>The Turnaround</em>, real net GDP per head is barely higher in today’s prices than it was at the pre financial crisis peak.<a href="https://docs.google.com/document/d/1bmRN50xTycjXFrdDChykaGSlfvlCEV2jkU2zv7Irhlo/edit#bookmark=id.oj8f977krvgc"><sup>4</sup> </a>Sluggish growth has dampened living standards and eroded the tax yields available to pay for heightened spending. The state is now costing each person the equivalent of £3,000 in health spending, around £2,200 in welfare spending, £1,500 in education spending and £1,000 in debt interest, versus around £400 per person for each of these costs in 1955 in 2019 prices<a href="https://docs.google.com/document/d/1bmRN50xTycjXFrdDChykaGSlfvlCEV2jkU2zv7Irhlo/edit#bookmark=id.hdtx65uj8qhq">.<sup>5</sup></a><a href="https://docs.google.com/document/d/1bmRN50xTycjXFrdDChykaGSlfvlCEV2jkU2zv7Irhlo/edit#bookmark=id.hdtx65uj8qhq"></a></p>



<p class="wp-block-paragraph"><strong>Figure 3 &#8211; Spending per capita</strong></p>



<p class="wp-block-paragraph"><em>Source: UK Public Spending</em><a href="https://docs.google.com/document/d/1bmRN50xTycjXFrdDChykaGSlfvlCEV2jkU2zv7Irhlo/edit#bookmark=id.io5b9fw3qdsf"><em><sup>6</sup></em></a></p>



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<h4 class="wp-block-heading">Flighting the “flab”</h4>



<p class="wp-block-paragraph">The growing headline figures for individual departments masks the reality that the ministers are not directly in control of this spending. A convenient way to get around a political problem is for ministers to put distance between themselves and the final decision. Creating an arms-length body brings some protection for ministers by replacing their direct decisions with process. Re:State’s (formerly Reform think tank) recent report, <em>Quangocracy, </em>sets out the series of “wrong” reasons that mean ministers are strongly incentivised to set up ever more bodies to take on difficult or “stuck” challenges, especially after a crisis.<a href="https://docs.google.com/document/d/1bmRN50xTycjXFrdDChykaGSlfvlCEV2jkU2zv7Irhlo/edit#bookmark=id.j1gtnreybhem"><sup>7</sup></a><a href="https://docs.google.com/document/d/1bmRN50xTycjXFrdDChykaGSlfvlCEV2jkU2zv7Irhlo/edit#bookmark=id.j1gtnreybhem"> </a>&nbsp;</p>



<p class="wp-block-paragraph">The result is that over 60% of day-to-day spending now happens through arms-length bodies.<a href="https://docs.google.com/document/d/1bmRN50xTycjXFrdDChykaGSlfvlCEV2jkU2zv7Irhlo/edit#bookmark=id.jmz4wlltjwm"><sup>8</sup></a><a href="https://docs.google.com/document/d/1bmRN50xTycjXFrdDChykaGSlfvlCEV2jkU2zv7Irhlo/edit#bookmark=id.jmz4wlltjwm"> </a>Promises of a “bonfire of the quangos” or the Prime Minister’s new pledge to trim down the “flabby” state are easy rhetoric, but difficult in practice. In the last decade alone, the number of central government public bodies has increased from 474 to 603 (excluding those in the devolved nations).<a href="https://docs.google.com/document/d/1bmRN50xTycjXFrdDChykaGSlfvlCEV2jkU2zv7Irhlo/edit#bookmark=id.kbkeimfacue4"><sup>9</sup></a><a href="https://docs.google.com/document/d/1bmRN50xTycjXFrdDChykaGSlfvlCEV2jkU2zv7Irhlo/edit#bookmark=id.kbkeimfacue4"> </a>In its first six months in office, the new Labour Government had announced plans to create 18 new quangos.<a href="https://docs.google.com/document/d/1bmRN50xTycjXFrdDChykaGSlfvlCEV2jkU2zv7Irhlo/edit#bookmark=id.91amjw8w7ks1"><sup>10</sup></a><a href="https://docs.google.com/document/d/1bmRN50xTycjXFrdDChykaGSlfvlCEV2jkU2zv7Irhlo/edit#bookmark=id.91amjw8w7ks1"> </a>&nbsp;</p>



<p class="wp-block-paragraph"><strong>Figure 4 &#8211; Resource departmental expenditure limits (RDEL) for the largest arm’s-length bodies, 2023-24</strong></p>



<p class="wp-block-paragraph"><em>Source: Cabinet Office</em><a href="https://docs.google.com/document/d/1bmRN50xTycjXFrdDChykaGSlfvlCEV2jkU2zv7Irhlo/edit#bookmark=id.4ow0qccvl76s"><em><sup>11</sup></em></a></p>



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<p class="wp-block-paragraph">The Prime Minister has at least pledged to scrap the biggest and second biggest quangos of all &#8211; NHS England (NHSE) and the Education and Skills Funding Agency &#8211; while promising that every quango will face a review. While the savings from merging NHSE back into its parent department will be significant, estimated at £500 million per year, it is still only around 1% of its current total day-to-day spending. Greater savings will require the Government to start actively making choices about what the NHS will stop doing, not just business as usual under new management.&nbsp;</p>



<p class="wp-block-paragraph">NHSE is a perfect example of the cumulatively damaging impact that a quango can have on the talent pool of a parent department. Although many quangos are set up with the specific intention of providing expertise outside of civil service salary bandings, such as scientific or clinical roles, higher pay is often also awarded to those without such specialism. Pay across all quangos averages 20% more than departmental pay.<a href="https://docs.google.com/document/d/1bmRN50xTycjXFrdDChykaGSlfvlCEV2jkU2zv7Irhlo/edit#bookmark=id.fgf202lwvq3r"><sup>12</sup></a><a href="https://docs.google.com/document/d/1bmRN50xTycjXFrdDChykaGSlfvlCEV2jkU2zv7Irhlo/edit#bookmark=id.fgf202lwvq3r"> </a>&nbsp;</p>



<p class="wp-block-paragraph">A near carbon copy of policy teams exists in both NHSE and the Department of Health and Social Care for non-clinical roles. This results in an internal brain drain, with officials moving sideways from the department to NHSE for pay rises while essentially carrying out the same policy role. Across Whitehall, a melee of generalists rotate through the lower ranks of the civil service, awaiting their own opportunity to move to more lucrative quangos. This leaves ministers with less experienced staff from which they can garner advice to negotiate with ever more powerful quangos. At the same time, the ministers are blocked from bringing in their own experts by pay constraints that are unenticing to external senior leaders.&nbsp;</p>



<p class="wp-block-paragraph">Unchecked quangos can end up operating as stakeholders themselves, employing public affairs teams to lobby the government for expensive, unrealistic or interest-driven policies. This leads to nonsensical situations like two separate quangos each using taxpayers’ money to argue with each other, rather than the Government taking a unified position on the policy trade-off at hand. For example, the Agricultural and Horticultural Development Board advocates for expanding Britain’s meat and dairy industry while the Climate Change Committee recommends a radical reduction in meat and dairy consumption to meet net zero by 2050.<a href="https://docs.google.com/document/d/1bmRN50xTycjXFrdDChykaGSlfvlCEV2jkU2zv7Irhlo/edit#bookmark=id.bp4fmu2it7vv"><sup>13</sup></a><a href="https://docs.google.com/document/d/1bmRN50xTycjXFrdDChykaGSlfvlCEV2jkU2zv7Irhlo/edit#bookmark=id.bp4fmu2it7vv"> </a>&nbsp;</p>



<p class="wp-block-paragraph">The Office for the Pay Review Bodies &#8211; a quango &#8211; sets the parameters for a £100 billion public sector pay bill.<a href="https://docs.google.com/document/d/1bmRN50xTycjXFrdDChykaGSlfvlCEV2jkU2zv7Irhlo/edit#bookmark=id.ltgolyytlhqo"><sup>14</sup></a><a href="https://docs.google.com/document/d/1bmRN50xTycjXFrdDChykaGSlfvlCEV2jkU2zv7Irhlo/edit#bookmark=id.ltgolyytlhqo"> </a>Pay review bodies are notionally independent panels set up with the intention of providing the government with advice on how much to pay public sector workers. However, several of the pay review bodies have terms of reference that neither include a responsibility for setting pay in a way that improves public services nor in a way that is broadly comparable to pay in similar jobs.<a href="https://docs.google.com/document/d/1bmRN50xTycjXFrdDChykaGSlfvlCEV2jkU2zv7Irhlo/edit#bookmark=id.seybwr3l1kw8"><sup>15</sup></a><a href="https://docs.google.com/document/d/1bmRN50xTycjXFrdDChykaGSlfvlCEV2jkU2zv7Irhlo/edit#bookmark=id.seybwr3l1kw8"> </a>The value of pay review bodies as a useful arbiter between government and the unions has therefore been steadily eroded by the government having to repeatedly override unaffordable recommendations, fuelling deep distrust of the process by politicised unions.&nbsp;&nbsp;</p>



<p class="wp-block-paragraph">The state has engineered a system whereby ministers end up in public fights with the very bodies that were meant to solve a difficult issue on their behalf. While setting up a quango may send a helpful signal about “taking the politics out” of a serious issue, rationalising their number or their functions then comes at immense political expense. But the long term cost of not taking control of the decisions that attract such a large portion of government spending is even greater. And ministers will still face the blame for bad decisions quangos make along the way while the bodies claim the credit for any improvement.&nbsp;</p>



<h4 class="wp-block-heading">Ratcheting up</h4>



<p class="wp-block-paragraph">A further way in which ministers have constructed processes that cede control is by relying heavily on index-linked spending ratchets. Indexation may help to bring a degree of certainty that spending will keep up with prices, but it also avoids making necessary trade-offs on a yearly basis. When inflation spikes due to external events like global energy prices changes, damage becomes permanent. With inflation set to remain above the Bank of England’s 2% target until at least 2027, the Government is on course for huge spending increases without active policy change.<a href="https://docs.google.com/document/d/1bmRN50xTycjXFrdDChykaGSlfvlCEV2jkU2zv7Irhlo/edit#bookmark=id.4ki0hf4xoe2w"><sup>16</sup></a><a href="https://docs.google.com/document/d/1bmRN50xTycjXFrdDChykaGSlfvlCEV2jkU2zv7Irhlo/edit#bookmark=id.4ki0hf4xoe2w"> </a>&nbsp;</p>



<p class="wp-block-paragraph"><strong>Figure 5 &#8211; CPI inflation since 2016 with forecast</strong></p>



<p class="wp-block-paragraph"><em>Source: Bank of England</em><a href="https://docs.google.com/document/d/1bmRN50xTycjXFrdDChykaGSlfvlCEV2jkU2zv7Irhlo/edit#bookmark=id.6rcmnhd9blp8"><em><sup>17</sup></em></a></p>



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<p class="wp-block-paragraph">Benefits, the state pension and public sector pensions are all index-linked. After a 1% cap during its early rollout, Universal Credit (UC) rates (and most legacy benefits) were frozen from 2016 to 2020, but since then have ratcheted up quickly, now surpassing the temporary uplift levels during Covid. Personal Independence Payment (PIP) rates were uprated with CPI after the 1% cap was lifted in 2016. In 2023-24 alone, high inflation meant that all CPI-linked rates have increased by 10.1%.<a href="https://docs.google.com/document/d/1bmRN50xTycjXFrdDChykaGSlfvlCEV2jkU2zv7Irhlo/edit#bookmark=id.a3vv9f6fj39q"><sup>18</sup></a><a href="https://docs.google.com/document/d/1bmRN50xTycjXFrdDChykaGSlfvlCEV2jkU2zv7Irhlo/edit#bookmark=id.a3vv9f6fj39q"> </a>&nbsp;</p>



<p class="wp-block-paragraph">Since 2016, the UC standard allowance has increased by just over a quarter, while the PIP daily living standard component has increased by a third.<a href="https://docs.google.com/document/d/1bmRN50xTycjXFrdDChykaGSlfvlCEV2jkU2zv7Irhlo/edit#bookmark=id.t9uwnlfgxpd0"><sup>19</sup></a><a href="https://docs.google.com/document/d/1bmRN50xTycjXFrdDChykaGSlfvlCEV2jkU2zv7Irhlo/edit#bookmark=id.t9uwnlfgxpd0"> </a>Therefore, the cumulative effect of PIP remaining unfrozen and now also benefitting from high inflation means that its relative generosity of PIP has outstripped UC, continuing to strengthen the incentive to claim disability benefits.&nbsp;</p>



<p class="wp-block-paragraph">Meanwhile, the state pension triple lock has seen rates rise much faster than working age benefits and salaries. At the time of its introduction, it has been reported that it was only expected to cost £50 million per year.<a href="https://docs.google.com/document/d/1bmRN50xTycjXFrdDChykaGSlfvlCEV2jkU2zv7Irhlo/edit#bookmark=id.6fv43bwd58td"><sup>20</sup></a><a href="https://docs.google.com/document/d/1bmRN50xTycjXFrdDChykaGSlfvlCEV2jkU2zv7Irhlo/edit#bookmark=id.6fv43bwd58td"> </a>The Institute for Fiscal Studies projects that by 2050, the government will be spending an extra £18 billion per year due to the triple lock, which equates to adding roughly 2p to both basic and higher rate income tax.<a href="https://docs.google.com/document/d/1bmRN50xTycjXFrdDChykaGSlfvlCEV2jkU2zv7Irhlo/edit#bookmark=id.yjwfdeiwftge"><sup>21</sup></a><a href="https://docs.google.com/document/d/1bmRN50xTycjXFrdDChykaGSlfvlCEV2jkU2zv7Irhlo/edit#bookmark=id.yjwfdeiwftge"> </a>As set out in Onward’s <em>The AntiSocial Contract, </em>successive governments have become trapped by this policy that is unsustainable, uncontrollable and unfair, yet supported by both older and younger voters.<a href="https://docs.google.com/document/d/1bmRN50xTycjXFrdDChykaGSlfvlCEV2jkU2zv7Irhlo/edit#bookmark=id.i45prvah6moz"><sup>22</sup></a><a href="https://docs.google.com/document/d/1bmRN50xTycjXFrdDChykaGSlfvlCEV2jkU2zv7Irhlo/edit#bookmark=id.i45prvah6moz"> </a>&nbsp;</p>



<h4 class="wp-block-heading">Delay then repay</h4>



<p class="wp-block-paragraph">It is now over 25 years since the budget was last in surplus, let alone bearing down on the debt. By 2030, PSND is projected to have quintupled since the financial crisis. Even using the Chancellor’s preferred measure in her fiscal rules of public sector net financial liabilities (PSNFL) rather than the previously used public sector net debt (PSND), the figure may be lower, but the trajectory is broadly similar.&nbsp;</p>



<p class="wp-block-paragraph">Net debt interest had been falling prior to the pandemic, but is now back up too. This reflects PSND relative to GDP hovering between 90-100% since 2020 compared to around 80% in the 2010s.<a href="https://docs.google.com/document/d/1bmRN50xTycjXFrdDChykaGSlfvlCEV2jkU2zv7Irhlo/edit#bookmark=id.3hvdxkyws5wu"><sup>23</sup></a><a href="https://docs.google.com/document/d/1bmRN50xTycjXFrdDChykaGSlfvlCEV2jkU2zv7Irhlo/edit#bookmark=id.3hvdxkyws5wu"> </a>The OBR’s latest report on whether current policies are sustainable into the future indicate that debt could climb to</p>



<p class="wp-block-paragraph">270% of GDP in fifty year’s time.<a href="https://docs.google.com/document/d/1bmRN50xTycjXFrdDChykaGSlfvlCEV2jkU2zv7Irhlo/edit#bookmark=id.l4swsfz2k249"><sup>24</sup></a><a href="https://docs.google.com/document/d/1bmRN50xTycjXFrdDChykaGSlfvlCEV2jkU2zv7Irhlo/edit#bookmark=id.l4swsfz2k249"> </a>&nbsp;</p>



<p class="wp-block-paragraph">While countries across the world faced many of the same global shocks, the UK’s persistent inability to get a grip of borrowing has left it in a particularly vulnerable position. At the end of 2024, government debt had reached the sixth highest among advanced economies and the fourth highest in Europe.<a href="https://docs.google.com/document/d/1bmRN50xTycjXFrdDChykaGSlfvlCEV2jkU2zv7Irhlo/edit#bookmark=id.2ldsrawma4em"><sup>25</sup> </a>30-year gilts have since reached their highest rate since 1998, while 10-year gilts are at their highest level since 2008.<a href="https://docs.google.com/document/d/1bmRN50xTycjXFrdDChykaGSlfvlCEV2jkU2zv7Irhlo/edit#bookmark=id.ps665yba9kmq"><sup>26</sup> </a>&nbsp;</p>



<p class="wp-block-paragraph"><strong>Figure 6 &#8211; Borrowing across advanced economies</strong></p>



<p class="wp-block-paragraph"><em>Source: OBR, IMF</em><a href="https://docs.google.com/document/d/1bmRN50xTycjXFrdDChykaGSlfvlCEV2jkU2zv7Irhlo/edit#bookmark=id.ag4y7dna06a4"><em><sup>27</sup></em></a></p>



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<p class="wp-block-paragraph">Indeed, nine of the last 10 fiscal rules or frameworks since 1997 have included a measure of getting debt falling as a share of GDP, but across the same timeframe PSND (excluding the Bank of England) has risen from 28% of GDP to 90%.<a href="https://docs.google.com/document/d/1bmRN50xTycjXFrdDChykaGSlfvlCEV2jkU2zv7Irhlo/edit#bookmark=id.rmb1vneha87f"><sup>28</sup></a><a href="https://docs.google.com/document/d/1bmRN50xTycjXFrdDChykaGSlfvlCEV2jkU2zv7Irhlo/edit#bookmark=id.rmb1vneha87f"> </a>Almost all have followed the same predictable pattern: borrowing more in the next couple of years, then hoping debt will start falling. In reality, the future belt tightening is loosened, there is an economic shock or performance is worse than expected. When promising to delay then repay, inevitably the latter never comes.</p>



<h4 class="wp-block-heading">Less for more</h4>



<p class="wp-block-paragraph">Productivity and efficiency savings continue to be relied on heavily for future salvation. The estimate of debt relative to GDP by the 2070s reaching 270% in the OBR’s Fiscal Sustainability report is based on an optimistic assumption of productivity growth at around 1.5% per year: a rate which has not been achieved since before the global financial crisis.<a href="https://docs.google.com/document/d/1bmRN50xTycjXFrdDChykaGSlfvlCEV2jkU2zv7Irhlo/edit#bookmark=id.s0gip7bxre2j"><sup>29</sup></a><a href="https://docs.google.com/document/d/1bmRN50xTycjXFrdDChykaGSlfvlCEV2jkU2zv7Irhlo/edit#bookmark=id.s0gip7bxre2j"> </a>Based on the current productivity growth rate of 0.5%, PSND relative to GDP would hit almost 650% of GDP in the same timeframe.<a href="https://docs.google.com/document/d/1bmRN50xTycjXFrdDChykaGSlfvlCEV2jkU2zv7Irhlo/edit#bookmark=id.6nwcf3fieoiz"><sup>30</sup></a><a href="https://docs.google.com/document/d/1bmRN50xTycjXFrdDChykaGSlfvlCEV2jkU2zv7Irhlo/edit#bookmark=id.6nwcf3fieoiz"> </a>&nbsp;</p>



<p class="wp-block-paragraph">Public sector productivity is 20% lower than it was in 1995, whereas in the private sector it has increased by 50%.<a href="https://docs.google.com/document/d/1bmRN50xTycjXFrdDChykaGSlfvlCEV2jkU2zv7Irhlo/edit#bookmark=id.qzgtn2vqepmd"><sup>31</sup></a><a href="https://docs.google.com/document/d/1bmRN50xTycjXFrdDChykaGSlfvlCEV2jkU2zv7Irhlo/edit#bookmark=id.qzgtn2vqepmd"> </a>Slow growth in public sector productivity is estimated to cost the UK economy £80 billion annually, and this could rise to £170 billion by 2030 if left unaddressed.<a href="https://docs.google.com/document/d/1bmRN50xTycjXFrdDChykaGSlfvlCEV2jkU2zv7Irhlo/edit#bookmark=id.wfsmd1dyzmqn"><sup>32</sup></a><a href="https://docs.google.com/document/d/1bmRN50xTycjXFrdDChykaGSlfvlCEV2jkU2zv7Irhlo/edit#bookmark=id.wfsmd1dyzmqn"> </a>Yet the adoption of productivity-enhancing technology is inconsistent and often actively resisted. The average tenure length of a Secretary of State is just two years, when productivity savings are often years, sometimes decades away.<a href="https://docs.google.com/document/d/1bmRN50xTycjXFrdDChykaGSlfvlCEV2jkU2zv7Irhlo/edit#bookmark=id.49pugnrf2ebe"><sup>33</sup></a><a href="https://docs.google.com/document/d/1bmRN50xTycjXFrdDChykaGSlfvlCEV2jkU2zv7Irhlo/edit#bookmark=id.49pugnrf2ebe"> </a>Under these short time horizons, pushing for departmental reorganisation and internal capital spending is rarely a high priority when the public demand immediate improvements on the frontline.&nbsp;</p>



<p class="wp-block-paragraph">There appears to have been little attempt by the new Government to consider what would need to be implemented in individual departments in order to make them more productive. The 2025 Spending Review documents assume near uniform 15% administrative efficiencies across departments by 2029/30, despite their very different staffing mixes and functions.<a href="https://docs.google.com/document/d/1bmRN50xTycjXFrdDChykaGSlfvlCEV2jkU2zv7Irhlo/edit#bookmark=id.l31skmwy2nt"><sup>34</sup></a><a href="https://docs.google.com/document/d/1bmRN50xTycjXFrdDChykaGSlfvlCEV2jkU2zv7Irhlo/edit#bookmark=id.l31skmwy2nt"> </a>Several different departments received individual and cross-cutting funding allocations for digital investments, but many aspects remain ambitions without having clear implementation plans.&nbsp;</p>



<p class="wp-block-paragraph">Unrealistic efficiency drives can ultimately have the opposite effect intended by leading to multiple in-year reprioritisation exercises that result in raiding capital budgets &#8211; those often funding the most significant productivity improvements. Even in the longer term, the gains from productivity increases alone are not enough in isolation to save a government committed to still doing everything it is already doing now, let alone anything more. Hoping for better productivity in the future, while continuing the same reliance on capital transfers to plug day-to-day spending gaps, will not meet these needs.</p>



<h4 class="wp-block-heading">The capital doom loop</h4>



<p class="wp-block-paragraph">Capital budget raids to pay for day-to-day-spending are frequently framed as the worst kind of short-sighted decision by ministers. But the idea that these are the “easy option” mischaracterises the series of incentives that lead to this phenomenon. They often involve the most directly quantifiable political harm &#8211; cancelling building programmes in multiple constituencies, or destroying a transformational project that ministers want as their legacies after leaving office.&nbsp;</p>



<p class="wp-block-paragraph">Yet the last decade is littered with delays and U-turns on major infrastructures projects and technology upgrades. The current crisis in prison capacity is a prime example of the doom loop that can occur. It starts with the feast and famine approach to announcing capital funding that are an inevitable part of the political cycle, with the push committing to as many brand new facilities as possible in one go over a long time horizon. Nine new prisons were pledged in the 2015 Spending Review &#8211; just three have opened to date.<a href="https://docs.google.com/document/d/1bmRN50xTycjXFrdDChykaGSlfvlCEV2jkU2zv7Irhlo/edit#bookmark=id.qmac77bs0y4j"><sup>35</sup></a><a href="https://docs.google.com/document/d/1bmRN50xTycjXFrdDChykaGSlfvlCEV2jkU2zv7Irhlo/edit#bookmark=id.qmac77bs0y4j"> </a>&nbsp;</p>



<p class="wp-block-paragraph">Since then, costs have increased dramatically due to repeated planning delays, contractor failures and construction industry inflation.<a href="https://docs.google.com/document/d/1bmRN50xTycjXFrdDChykaGSlfvlCEV2jkU2zv7Irhlo/edit#bookmark=id.s8mouhq8szzb"><sup>36</sup></a><a href="https://docs.google.com/document/d/1bmRN50xTycjXFrdDChykaGSlfvlCEV2jkU2zv7Irhlo/edit#bookmark=id.s8mouhq8szzb"> </a>These factors lead to the repeated need to send business cases back through ever more lengthy value for money assurance processes as confidence in the delivery of the programme wanes. Major projects become caught in the need for the delivery department, its quangos (HM Prison and Probation Service in this case), Cabinet Office, HMT and No.10 all being involved in approvals at both senior civil service, special adviser and ministerial level.&nbsp;</p>



<p class="wp-block-paragraph">The inevitable outcome of so many different parts of the state being involved in the process is further delay and expense while the savings the service transformation was meant to deliver remain unrealised. When a decision is required at fiscal events as to how to cover higher-than-expected day-to-day running costs, the rational choice is to reallocate likely underspends from capital programme delays that would otherwise be reabsorbed by HMT.&nbsp;</p>



<h4 class="wp-block-heading">Information games</h4>



<p class="wp-block-paragraph">Chronic under-investment in technology and information systems within government has left it years behind the private sector in capability. While many companies have enhanced their back office systems and customer services with artificial intelligence (AI), “government by spreadsheet” still remains the norm across Whitehall. Even in parts of the state which have adopted new AI-enabled systems, like the federated data platform in acute NHS trusts, these systems often fail to realise all their possible quality improvement and cost savings by having to interact with archaic processes beyond their boundaries.&nbsp;</p>



<p class="wp-block-paragraph">Failure to exploit the full potential of unifying information systems across government leaves ministers making slower, suboptimal decisions. Rather than being able to draw information out almost instantaneously and then quickly iterate questions until the answer is found, ministers are forced into lengthy commissioning processes. Advice then arrives back with them months later, having not answered the question in the way intended, having failed to produce a saleable solution or having simply come too late to be viable anymore. This is exacerbated further when policy issues cut across multiple government departments or quangos with separate internal clearance processes.&nbsp;</p>



<p class="wp-block-paragraph">Information security concerns are often cited to caution against unleashing new technology in government. But a state forced to email spreadsheets between officials or left waiting for crucial information in a crisis is already one that is provably less secure. The same narrow policy choices will continue to be presented until the architecture propping up the state is modernised, revealing the “unknown unknowns” that were not previously possible at all.</p>



<h4 class="wp-block-heading">Politically trapped</h4>



<p class="wp-block-paragraph">The Conservatives have learned the hard way that credibility on the public finances matters, as outlined in Onward’s <em>Breaking Blue</em> following the Conservatives’ election defeat.<a href="https://docs.google.com/document/d/1bmRN50xTycjXFrdDChykaGSlfvlCEV2jkU2zv7Irhlo/edit#bookmark=id.y4arwcgot5i"><sup>37</sup></a><a href="https://docs.google.com/document/d/1bmRN50xTycjXFrdDChykaGSlfvlCEV2jkU2zv7Irhlo/edit#bookmark=id.y4arwcgot5i"> </a>The change of Government has seen opinion about whether the balance of taxes and spending is right worsen still. YouGov’s monthly tracker on whether the Government is taxing and spending the right amount has seen an uptick in those thinking both taxes and spending are too high since the General Election, with this figure remaining above 40% for 8 of the last 9 months &#8211; at least 5% higher than at any time in the last 5 years.<a href="https://docs.google.com/document/d/1bmRN50xTycjXFrdDChykaGSlfvlCEV2jkU2zv7Irhlo/edit#bookmark=id.izihdorwi9tu"><sup>38</sup></a><a href="https://docs.google.com/document/d/1bmRN50xTycjXFrdDChykaGSlfvlCEV2jkU2zv7Irhlo/edit#bookmark=id.izihdorwi9tu"> </a>&nbsp;</p>



<p class="wp-block-paragraph">Once Labour’s new policy commitments and public sector pay rises are accounted for, many of the apparent uplifts in departmental budgets in the Spending Review 2024 are real terms cuts. Cutting budgets without cutting policy commitments leaves tax rises either means failure to deliver or inevitable tax rises to plug the gap further down the line. Even those on the furthest left of British politics struggle to find a combination of tax hikes which even begin to reach the revenue needed to sustain the public finances. Analysis by the CPS of the tax raising plans from Jeremy Corbyn 2019 manifesto or from the IPPR struggle to raise more than a fifth of the shortfall needed to fill the void, before accounting for their damaging impact on growth.<a href="https://docs.google.com/document/d/1bmRN50xTycjXFrdDChykaGSlfvlCEV2jkU2zv7Irhlo/edit#bookmark=id.pl1hd6xdr6tv"><sup>39</sup></a><a href="https://docs.google.com/document/d/1bmRN50xTycjXFrdDChykaGSlfvlCEV2jkU2zv7Irhlo/edit#bookmark=id.pl1hd6xdr6tv"> </a>&nbsp;</p>



<p class="wp-block-paragraph">The Reform party’s tax and spending commitments are equally alarming. Analysis by the Economist indicates that the tax cuts in their manifesto plus commitments made since the election total just under £200 billion.<a href="https://docs.google.com/document/d/1bmRN50xTycjXFrdDChykaGSlfvlCEV2jkU2zv7Irhlo/edit#bookmark=id.k6acke4dttrr"><sup>40</sup></a><a href="https://docs.google.com/document/d/1bmRN50xTycjXFrdDChykaGSlfvlCEV2jkU2zv7Irhlo/edit#bookmark=id.k6acke4dttrr"> </a>Planned spending rises approximately offset some tax rises and spending cuts. Their plans also include 5% in unspecified efficiency savings, but as discussed above, these are notoriously difficult to find at least in the short term and therefore cannot be automatically relied on now. This leaves the £200 billion in tax cuts largely unfunded. To give a sense of scale, this is roughly equivalent to the entire budget of the NHS and four times the size of the tax cuts planned in the 2022 “mini-Budget”.&nbsp;</p>



<h3 class="wp-block-heading">2. Local level</h3>



<p class="wp-block-paragraph"><strong>The shape of local government has been slowly evolving since the two-tier system was introduced in the 1970s. While spending on services at a national level has been growing, local government funding has been sharply reduced over the last 15 years. This change has been made alongside unprecedented growth in the statutory duties that local government is expected to discharge. Despite some of these additional responsibilities coming alongside devolution, the UK remains one of the most centralised democratic countries in the world.</strong></p>



<h4 class="wp-block-heading">Squeezed settlements</h4>



<p class="wp-block-paragraph">Since 2010, local authority spending power has been substantially diminished. Despite widespread council tax rises in part covering the shortfall, core spending power was down by about a fifth since over the decade to 2019/20.<a href="https://docs.google.com/document/d/1bmRN50xTycjXFrdDChykaGSlfvlCEV2jkU2zv7Irhlo/edit#bookmark=id.a2e5xk6f7r8n"><sup>41</sup></a> <a href="https://docs.google.com/document/d/1bmRN50xTycjXFrdDChykaGSlfvlCEV2jkU2zv7Irhlo/edit#bookmark=id.a2e5xk6f7r8n"></a>Between 2010/11 and 2015/16 core spending power fell by a quarter.<a href="https://docs.google.com/document/d/1bmRN50xTycjXFrdDChykaGSlfvlCEV2jkU2zv7Irhlo/edit#bookmark=id.pbggot5hey7"><sup>42</sup> </a>&nbsp;</p>



<p class="wp-block-paragraph"><strong>Figure 7 &#8211; Local authority core spending power per person</strong></p>



<p class="wp-block-paragraph"><em>Source: NAO</em><a href="https://docs.google.com/document/d/1bmRN50xTycjXFrdDChykaGSlfvlCEV2jkU2zv7Irhlo/edit#bookmark=id.4quh524fh7is"><em><sup>44</sup></em></a></p>



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<p class="wp-block-paragraph">While more central government grant funding has been made available in the last five years, core spending power still remains 14% below 2010/11 levels, with a gap of almost £12 billion nationally.<a href="https://docs.google.com/document/d/1bmRN50xTycjXFrdDChykaGSlfvlCEV2jkU2zv7Irhlo/edit#bookmark=id.ams3nenudyh0"><sup>43</sup></a><a href="https://docs.google.com/document/d/1bmRN50xTycjXFrdDChykaGSlfvlCEV2jkU2zv7Irhlo/edit#bookmark=id.ams3nenudyh0"> </a>This is part due to high-than-expected inflation eroding increases. Real term core spending power of local government per person decreased by 1% from 2015/16 to 2023/24, although it is now rising.</p>



<p class="wp-block-paragraph">The challenging funding backdrop for local authorities has coincided with the legal duties being greatly increased. A review in 2011 identified almost 1,300 statutory duties which local authorities were required to fulfil.<a href="https://docs.google.com/document/d/1bmRN50xTycjXFrdDChykaGSlfvlCEV2jkU2zv7Irhlo/edit#bookmark=id.d2d3g8cgcs19"><sup>45</sup></a><a href="https://docs.google.com/document/d/1bmRN50xTycjXFrdDChykaGSlfvlCEV2jkU2zv7Irhlo/edit#bookmark=id.d2d3g8cgcs19"> </a>In July this year it was reported that the Deputy Prime Minister was planning to deploy artificial intelligence to review the now 20,000 pieces of legislation that apply to local authorities.<a href="https://docs.google.com/document/d/1bmRN50xTycjXFrdDChykaGSlfvlCEV2jkU2zv7Irhlo/edit#bookmark=id.uubwug69lkjl"><sup>46</sup></a><a href="https://docs.google.com/document/d/1bmRN50xTycjXFrdDChykaGSlfvlCEV2jkU2zv7Irhlo/edit#bookmark=id.uubwug69lkjl"> </a>&nbsp;</p>



<p class="wp-block-paragraph">Since 2018, there have been a slew of high profile council bankruptcies that have focussed attention on the dire state of many councils’ finances. While many of the bankruptcies so far have been a consequence of specific risky investment decisions or historic legal issues, councils across the country and the political spectrum are now sounding the alarm about no longer being able to carry the growing burden of budgetary pressures within ever more squeezed financial settlements.&nbsp;</p>



<h4 class="wp-block-heading">Hidden precepts&nbsp;</h4>



<p class="wp-block-paragraph">Councils raise revenue largely through council tax, business rates and fees or charges. While councils can set their own rates, they are constrained by caps for increases in precepts for general services at 3% and adult social care at 2%. However, a growing number of additional precepts have been introduced that are levied through council tax but do not go to the council, including for Police and Crime Commissioners (PCCs), Fire and Rescue Authorities, mayoralties and Parish or Town Councils. The Spending Review 2025 assumes that all councils increase council tax by the maximum amount each year, meaning that those who do not face a compounding penalty.<a href="https://docs.google.com/document/d/1bmRN50xTycjXFrdDChykaGSlfvlCEV2jkU2zv7Irhlo/edit#bookmark=id.vrpwnkruugu7"><sup>47</sup></a><a href="https://docs.google.com/document/d/1bmRN50xTycjXFrdDChykaGSlfvlCEV2jkU2zv7Irhlo/edit#bookmark=id.vrpwnkruugu7"> </a>&nbsp;</p>



<p class="wp-block-paragraph">The array of precepts levied through council tax are poorly understood by the public. Non-council precepts are often increased by the maximum amount as those setting them have no incentive not to ask for as much as possible, when few voters will make the connection.</p>



<p class="wp-block-paragraph"><strong>Figure 8 &#8211; Annual percentage change in average Band D council tax (including</strong></p>



<p class="wp-block-paragraph"><strong>parish and adult social care precepts) in England </strong>&nbsp;</p>



<p class="wp-block-paragraph">Source: MHCLG, Onward analysis<a href="https://docs.google.com/document/d/1bmRN50xTycjXFrdDChykaGSlfvlCEV2jkU2zv7Irhlo/edit#bookmark=id.s0ae9zyq7bg3"><sup>48</sup></a></p>



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<p class="wp-block-paragraph">In some areas such as Wandsworth, the mismatch between the mayoral precept and the local precept is already so great that next year the mayoral precept alone is likely to exceed the council’s share of the average Band D household’s council tax bill. Labour’s Local Government White Paper proposes a series of reforms including ever more precepting powers for new mayoralties, which will confuse the issue even more unless bills are separated.<a href="https://docs.google.com/document/d/1bmRN50xTycjXFrdDChykaGSlfvlCEV2jkU2zv7Irhlo/edit#bookmark=id.oujufs9k8c4l"><sup>49</sup></a><a href="https://docs.google.com/document/d/1bmRN50xTycjXFrdDChykaGSlfvlCEV2jkU2zv7Irhlo/edit#bookmark=id.oujufs9k8c4l"></a></p>



<h4 class="wp-block-heading">Death by 1,000 grants</h4>



<p class="wp-block-paragraph">The incentive for councils, mayors, PCCs and others to act in the best interests of the community is further diminished by grant structures. Only half of business rates revenue is retained by councils, despite several attempts over the last decade to increase the proportion retained. This lessens the incentive for local authorities to promote local growth from which they could raise greater revenue. Instead, revenue is taken by central government and then gifted back (with a significant top-up) to local authorities but with conditions attached.&nbsp;</p>



<p class="wp-block-paragraph">Areas with lower revenue are topped up significantly, while those who raised more face a tariff. In the first half of the 2010s, less well-off areas struggled as all areas saw central government grant funding cut in flat percentage terms.<a href="https://docs.google.com/document/d/1bmRN50xTycjXFrdDChykaGSlfvlCEV2jkU2zv7Irhlo/edit#bookmark=id.aoaztuk7raae"><sup>50</sup></a><a href="https://docs.google.com/document/d/1bmRN50xTycjXFrdDChykaGSlfvlCEV2jkU2zv7Irhlo/edit#bookmark=id.aoaztuk7raae"> </a>Those who had relied more on grant funding therefore lost a greater proportion of their total budget. This trend has been reversed since Covid as the most deprived areas have seen greater increases than wealthier areas which generate more revenue.&nbsp;</p>



<p class="wp-block-paragraph">The rebalancing of funding settlements does not address the fundamentally broken link between local politicians and the local economy. This link is likely to weaken further still under the Labour Government’s plans outlined in the Fair Funding Review. The push for full equalisation, where local funding settlements are hypothecated on a notional maximum council tax level and a complex needs-based formula, lowers the cost of bad policy choices and reduces the incentives to grow the local economy. Experiencing higher deprivation, high delivery costs and growing numbers receiving support within a council’s boundaries risks becoming a tool for getting more funding from central government. This reduces the incentive to focus on delivering efficient services, local job opportunities and helping people to live independently.&nbsp;</p>



<p class="wp-block-paragraph"><strong>Figure 9 &#8211; Cash terms changes in funding by council type under full equalisation vs current average in England, 2025/26 to 2028/29</strong></p>



<p class="wp-block-paragraph"><em>Source: Institute for Fiscal Studies, Onward analysis</em><a href="https://docs.google.com/document/d/1bmRN50xTycjXFrdDChykaGSlfvlCEV2jkU2zv7Irhlo/edit#bookmark=id.35iwjmqdg378"><em><sup>51</sup></em></a></p>



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<p class="wp-block-paragraph">As block-grant funding has been reduced, some of the shortfall has been replaced by a growing number of competitive grants. In 2022-23 local government bodies received more than £10 billion in competitive grant funding across around 300 schemes with over 11,000 individual awards.<a href="https://docs.google.com/document/d/1bmRN50xTycjXFrdDChykaGSlfvlCEV2jkU2zv7Irhlo/edit#bookmark=id.5uh2vc97xo6v"><sup>52</sup> </a>These schemes create significant waste both centrally and locally, often for small amounts of money that are limited in duration. It is inevitable with competitive grants that some councils create entire new teams or divert resources from service delivery to bid for funding that they will never receive.&nbsp;</p>



<p class="wp-block-paragraph">The resultant waste from piecemeal schemes makes it more difficult to achieve ultimate objectives. For example, the Future High Streets Fund, the Levelling Up Fund, the Town Deals and the UK Shared Prosperity Fund all have similar goals.<a href="https://docs.google.com/document/d/1bmRN50xTycjXFrdDChykaGSlfvlCEV2jkU2zv7Irhlo/edit#bookmark=id.gi68bub1yii8"><sup>53</sup></a><a href="https://docs.google.com/document/d/1bmRN50xTycjXFrdDChykaGSlfvlCEV2jkU2zv7Irhlo/edit#bookmark=id.gi68bub1yii8"> </a>However, their differing terms, announcement times and timescales mean that local authorities are forced to satisfy separate requirements for each. This can lead to inefficient “double-dipping” for the same projects and also means that larger, more transformational projects that could have been achieved if the funding was rolled into a single pot never happen.</p>



<h4 class="wp-block-heading">Designed brinkmanship</h4>



<p class="wp-block-paragraph">Low costs to failure are already harming local democracy. Given the limited options for councils to raise revenue, a growing number are finding themselves on the brink of bankruptcy. The Exceptional Financial Support (EFS) framework was introduced in 2020-21 to provide financial support through capitalisation, whereby normal finance rules are relaxed so the local authority may borrow money or sell assets to balance day-to-day spending.&nbsp;</p>



<p class="wp-block-paragraph">The EFS system means that struggling councils need to descend further into crisis before they are allowed to raise council tax above the cap or make capital transfers. By then, options often involve borrowing more, rather than addressing the issue that led to the crisis in the first place. EFS deals are negotiated individually by councils with the Ministry of Housing, Communities and Local Government, making it difficult for the public to understand how seemingly punitive measures, including large council tax rises, have been decided or who is to blame. This damages the already weak link at local elections between voting for parties with meaningfully different policies when all are bound to the same centrally-set plan.&nbsp;</p>



<p class="wp-block-paragraph">A system that forces councils to the edge of ruin before allowing them flexibility incentivises risk-taking to cover structural deficits. With limited options to raise revenue, investment in financial schemes with high yields becomes a highly attractive option. However, a deeply dysfunctional audit market left many of these investment practices to continue unchecked. As of late 2024, only<sub> </sub>1% of councils had published externally audited 2022/23 accounts on time.<a href="https://docs.google.com/document/d/1bmRN50xTycjXFrdDChykaGSlfvlCEV2jkU2zv7Irhlo/edit#bookmark=id.cziaid21l1y6"><sup>54</sup></a><a href="https://docs.google.com/document/d/1bmRN50xTycjXFrdDChykaGSlfvlCEV2jkU2zv7Irhlo/edit#bookmark=id.cziaid21l1y6"> </a>At the same time, the increase in riskier investments, off-balance sheet liabilities and capitalisation has made the task of auditors more complex. In addition, one in five internal audit roles were also vacant.<a href="https://docs.google.com/document/d/1bmRN50xTycjXFrdDChykaGSlfvlCEV2jkU2zv7Irhlo/edit#bookmark=id.agvurs4uljdu"><sup>55</sup></a><a href="https://docs.google.com/document/d/1bmRN50xTycjXFrdDChykaGSlfvlCEV2jkU2zv7Irhlo/edit#bookmark=id.agvurs4uljdu"></a></p>



<h4 class="wp-block-heading">The social care stranglehold</h4>



<p class="wp-block-paragraph">The uneven balance of power and accountability is most apparent when considering how councils spend the majority of their funding. In 2023/24, local authorities in England spent an average of 58% of their budgets on adult and children’s social care, with some councils spending as much as 80% of their budget on these services.<a href="https://docs.google.com/document/d/1bmRN50xTycjXFrdDChykaGSlfvlCEV2jkU2zv7Irhlo/edit#bookmark=id.vygn3dg5am54"><sup>56</sup></a><a href="https://docs.google.com/document/d/1bmRN50xTycjXFrdDChykaGSlfvlCEV2jkU2zv7Irhlo/edit#bookmark=id.vygn3dg5am54"> </a>Looking ahead, to meet demand pressures and rising costs, the OBR projects that UK-wide public spending on adult social care would need to increase by 3.1% per year in real terms over the next decade.<a href="https://docs.google.com/document/d/1bmRN50xTycjXFrdDChykaGSlfvlCEV2jkU2zv7Irhlo/edit#bookmark=id.dgt6fdl65mw9"><sup>57</sup></a><a href="https://docs.google.com/document/d/1bmRN50xTycjXFrdDChykaGSlfvlCEV2jkU2zv7Irhlo/edit#bookmark=id.dgt6fdl65mw9"> </a>&nbsp;</p>



<p class="wp-block-paragraph"><strong>Figure 10 &#8211; Expenditure by local authorities on adult social care and children’s services</strong></p>



<p class="wp-block-paragraph"><em>Source: CIPFA, Onward analysis</em><a href="https://docs.google.com/document/d/1bmRN50xTycjXFrdDChykaGSlfvlCEV2jkU2zv7Irhlo/edit#bookmark=id.gnzi4wy245mt"><em><sup>58</sup></em></a></p>



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<p class="wp-block-paragraph">For adult social care, while councils can make some active choices about commissioning and investments in local care services, their options are limited. Demographics, wealth and the management of their local NHS services &#8211; all largely outside their control and responsibility &#8211; are likely to be the biggest determinants of how well social care functions in their area, not innovation in local policy. Despite this being such a significant area of local spending, there is little local policy choice to be made. They are simply delivering a nationally set policy that they cannot control while being accountable for the consequences at the ballot box.&nbsp;</p>



<p class="wp-block-paragraph">The Labour Government’s Casey Commission is likely to make this situation worse, at least in the short term.<a href="https://docs.google.com/document/d/1bmRN50xTycjXFrdDChykaGSlfvlCEV2jkU2zv7Irhlo/edit#bookmark=id.lv5mmocpeuw4"><sup>59</sup></a><a href="https://docs.google.com/document/d/1bmRN50xTycjXFrdDChykaGSlfvlCEV2jkU2zv7Irhlo/edit#bookmark=id.lv5mmocpeuw4"> </a>The first phase, due in 2026, is a “national care service” which has previously been referred to in trade union campaigns for a new pay structure similar to those that exist in the NHS.<a href="https://docs.google.com/document/d/1bmRN50xTycjXFrdDChykaGSlfvlCEV2jkU2zv7Irhlo/edit#bookmark=id.lobl93ez2ok4"><sup>60</sup></a><a href="https://docs.google.com/document/d/1bmRN50xTycjXFrdDChykaGSlfvlCEV2jkU2zv7Irhlo/edit#bookmark=id.lobl93ez2ok4"> </a>Implementing this would significantly raise the cost of care by increasing the rates paid to those working in the sector, which makes up the majority of care commissioning costs.<a href="https://docs.google.com/document/d/1bmRN50xTycjXFrdDChykaGSlfvlCEV2jkU2zv7Irhlo/edit#bookmark=id.pkk13pd1nla4"><sup>61</sup></a><a href="https://docs.google.com/document/d/1bmRN50xTycjXFrdDChykaGSlfvlCEV2jkU2zv7Irhlo/edit#bookmark=id.pkk13pd1nla4"> </a>For example, previous estimates of raising minimum pay in adult social care to the National Living Wage plus 65p put this at £600 million per year.<a href="https://docs.google.com/document/d/1bmRN50xTycjXFrdDChykaGSlfvlCEV2jkU2zv7Irhlo/edit#bookmark=id.7603wvq1xjov"><sup>62</sup></a><a href="https://docs.google.com/document/d/1bmRN50xTycjXFrdDChykaGSlfvlCEV2jkU2zv7Irhlo/edit#bookmark=id.7603wvq1xjov"> </a>&nbsp;</p>



<p class="wp-block-paragraph">The wider question about models of care will not be covered until the second phase of the Casey Commission. This phase is only expected to report on the eve of the next General Election. Calls for this process to create a consensus on a plan for social care risks missing the opportunity for radical change once again. Charging reform plans that were consistently delayed under the Conservatives only ever asked a limited question &#8211; how to protect people from having to sell their homes to pay for their care &#8211; and therefore only received a narrow answer on that particular aspect of the system. While public support for policy is important, the Casey Commission may fall into the same trap of prizing agreeability over outcomes. There is already no shortage of ideas around different options for delivering care, but there has been a shortage of those willing to take decisions in which there will always be winners and losers.&nbsp;</p>



<p class="wp-block-paragraph">In children’s social care too, there has been rapid rises in demand dictated by statutory duties without local authorities receiving enough from central government to cover the full costs. Key drivers of this are the numbers of children assessed as having special education needs and looked after children. Since 2014, the number of children and young people with education, health and care plans (EHCPs) has risen by 140%, from 240,183 in 2014/15 to 575,973 in 2023/24.<a href="https://docs.google.com/document/d/1bmRN50xTycjXFrdDChykaGSlfvlCEV2jkU2zv7Irhlo/edit#bookmark=id.qzvzvzu74yof"><sup>63</sup></a><a href="https://docs.google.com/document/d/1bmRN50xTycjXFrdDChykaGSlfvlCEV2jkU2zv7Irhlo/edit#bookmark=id.qzvzvzu74yof"> </a>The vast majority (88%) of these are for non-physical developmental or mental health needs. Council spending on school transport for children with</p>



<p class="wp-block-paragraph">SEND alone has almost doubled since 2018.<a href="https://docs.google.com/document/d/1bmRN50xTycjXFrdDChykaGSlfvlCEV2jkU2zv7Irhlo/edit#bookmark=id.zc00rdesiq6i"><sup>64</sup></a><a href="https://docs.google.com/document/d/1bmRN50xTycjXFrdDChykaGSlfvlCEV2jkU2zv7Irhlo/edit#bookmark=id.zc00rdesiq6i"> </a>&nbsp;</p>



<p class="wp-block-paragraph">A SEND reform plan has been promised in the autumn as part of the Schools White Paper, but its scope remains unclear. £760 million in additional funding has been allocated in the Spending Review for this , but for many councils this will not come soon enough.<a href="https://docs.google.com/document/d/1bmRN50xTycjXFrdDChykaGSlfvlCEV2jkU2zv7Irhlo/edit#bookmark=id.b8ffq87xde5w"><sup>65</sup></a><a href="https://docs.google.com/document/d/1bmRN50xTycjXFrdDChykaGSlfvlCEV2jkU2zv7Irhlo/edit#bookmark=id.b8ffq87xde5w"> </a>The statutory override, which keeps the cumulative impact of EHCP deficits off local authority books until March 2026, has masked part of the issue. A survey conducted by ISOS Partnership found that 25% of local authorities said that they would be insolvent within a year and another 25% would be insolvent within three years if the statutory override was removed.<a href="https://docs.google.com/document/d/1bmRN50xTycjXFrdDChykaGSlfvlCEV2jkU2zv7Irhlo/edit#bookmark=id.ce29mp8zlss5"><sup>66</sup></a><a href="https://docs.google.com/document/d/1bmRN50xTycjXFrdDChykaGSlfvlCEV2jkU2zv7Irhlo/edit#bookmark=id.ce29mp8zlss5"> </a>&nbsp;</p>



<h4 class="wp-block-heading">Overlapping boundaries diluting responsibility&nbsp;</h4>



<p class="wp-block-paragraph">Local authorities are not the only manifestations of the state at a local level. There is a tangle of overlapping administrative boundaries for services such as health and policing which further confuses lines of responsibility. The drive to devolve some services closer to home but not to place them under local government authority has led to an inefficient and opaque structure, with no mechanism for true local accountability for these services to voters.&nbsp;</p>



<p class="wp-block-paragraph">For instance, Integrated Care Board (ICB) areas vary wildly in size, with the largest ICB covering roughly six times as many people as the smallest.<a href="https://docs.google.com/document/d/1bmRN50xTycjXFrdDChykaGSlfvlCEV2jkU2zv7Irhlo/edit#bookmark=id.cxn7xskeooqu"><sup>67</sup></a><a href="https://docs.google.com/document/d/1bmRN50xTycjXFrdDChykaGSlfvlCEV2jkU2zv7Irhlo/edit#bookmark=id.cxn7xskeooqu"> </a>While some fit comfortably within a single local authority area, others have multiple different local authorities to contend with. In the North East and North Cumbria ICB area there are twelve different upper-tier authorities, each with their own priorities for spending key health-related budget lines like the Public Health Grant and the Better Care Fund.</p>



<p class="wp-block-paragraph">Cross-cutting services that require coordination between these layers and boundaries end up falling through the cracks. Mental health services for those with the most serious psychiatric conditions and those in crisis are a prime example of this. Not only do NHS mental health trusts have to coordinate services with different geographies for both policing and social care, they also cover different areas from the acute trusts. The Care Quality Commission’s most recent State of Care report highlighted instances of people having to wait several months, and in some cases years, for treatment in the community, which requires joint arrangement between trusts and the local authority.<a href="https://docs.google.com/document/d/1bmRN50xTycjXFrdDChykaGSlfvlCEV2jkU2zv7Irhlo/edit#bookmark=id.vvno27p0wsrr"><sup>68</sup></a><a href="https://docs.google.com/document/d/1bmRN50xTycjXFrdDChykaGSlfvlCEV2jkU2zv7Irhlo/edit#bookmark=id.vvno27p0wsrr"> </a>The end result is a system in which those who may pose a serious risk to themselves or others too often fall through the cracks.</p>



<h3 class="wp-block-heading">3. Individual level</h3>



<p class="wp-block-paragraph"><strong>The product of broken incentives in government at a national and local level is a state that makes it rational for individuals to act in a way that is neither in their best interests, nor the best interests of the country. Changes to ease of access and the relative generosity of state entitlements have tipped the balance further away from rewarding those contributing the most. People are left less free to provide the life that they may want for themselves and their children, making suboptimal decisions about work, family life and retirement. </strong>&nbsp;</p>



<h4 class="wp-block-heading">Contributors and recipients</h4>



<p class="wp-block-paragraph">Onward’s <em>The Turnaround </em>and <em>The Anti-Social Contract </em>document well the importance of maintaining the link between effort and reward, both for economic sustainability and basic fairness<em>. </em>Together they highlight how the median income in the UK at £37,430 is below the level needed to be a net fiscal contributor.<a href="https://docs.google.com/document/d/1bmRN50xTycjXFrdDChykaGSlfvlCEV2jkU2zv7Irhlo/edit#bookmark=id.ei9xu7kt21d1"><sup>69</sup></a><a href="https://docs.google.com/document/d/1bmRN50xTycjXFrdDChykaGSlfvlCEV2jkU2zv7Irhlo/edit#bookmark=id.ei9xu7kt21d1"> </a>&nbsp;</p>



<p class="wp-block-paragraph"><strong>Figure 11 – Individuals in households claiming more in benefits than tax paid </strong>&nbsp;<em>Source: ONS</em><a href="https://docs.google.com/document/d/1bmRN50xTycjXFrdDChykaGSlfvlCEV2jkU2zv7Irhlo/edit#bookmark=id.tghqtp33vegr"><em><sup>73</sup></em></a></p>



<div class="flourish-embed flourish-chart" data-src="visualisation/24837205"><script src="https://public.flourish.studio/resources/embed.js"></script><noscript><img decoding="async" src="https://public.flourish.studio/visualisation/24837205/thumbnail" width="100%" alt="chart visualization" /></noscript></div>



<p class="wp-block-paragraph">Those at the lower end of the income distribution are directly subsidised by Universal Credit which continues into work. Fiscal drag from the freezing of personal tax thresholds since 2021, has meant more people have entered high tax brackets by stealth.<a href="https://docs.google.com/document/d/1bmRN50xTycjXFrdDChykaGSlfvlCEV2jkU2zv7Irhlo/edit#bookmark=id.je6yj2z6wvh6"><sup>70</sup></a><a href="https://docs.google.com/document/d/1bmRN50xTycjXFrdDChykaGSlfvlCEV2jkU2zv7Irhlo/edit#bookmark=id.je6yj2z6wvh6"></a></p>



<p class="wp-block-paragraph">A shrinking tax base with those on higher incomes paying an ever-larger share distorts the incentive to work harder for higher reward or to progress to higher paid work. In 2000/01, just under 44% of households were net recipients from the state.<a href="https://docs.google.com/document/d/1bmRN50xTycjXFrdDChykaGSlfvlCEV2jkU2zv7Irhlo/edit#bookmark=id.wetq8lwyrdc7"><sup>71</sup></a><a href="https://docs.google.com/document/d/1bmRN50xTycjXFrdDChykaGSlfvlCEV2jkU2zv7Irhlo/edit#bookmark=id.wetq8lwyrdc7"> </a>The relationship has now reversed, with almost 54% of households being net recipients in 2023.<a href="https://docs.google.com/document/d/1bmRN50xTycjXFrdDChykaGSlfvlCEV2jkU2zv7Irhlo/edit#bookmark=id.r7zcd92fjlxz"><sup>72</sup></a><a href="https://docs.google.com/document/d/1bmRN50xTycjXFrdDChykaGSlfvlCEV2jkU2zv7Irhlo/edit#bookmark=id.r7zcd92fjlxz"> </a>This is in part a feature of the aging population who draw on the state pension and pensions credit, but this does not explain the whole of the shift.&nbsp;</p>



<h4 class="wp-block-heading">New cliff-edges</h4>



<p class="wp-block-paragraph">The stated aim of UC at its inception was to smooth the transition into work and to encourage people to take on more hours once in work. For example, the 16- and 30-hour thresholds in the legacy Tax Credit system had had a distortionary impact on working hours, with both under- and overpayment at the end of the year after retrospective calculations which often pushed claimants into debt. UC promised a tapered system where claimants would always be better-off working and increasing their hours. In reality, its implementation has created several new cliff-edges that work against the incentive to work.&nbsp;</p>



<p class="wp-block-paragraph">The taper itself currently takes away 55p of every £1 earned above the work allowance. Those earning above the income tax personal allowance and the national insurance contribution threshold start losing yet more income, with an effective marginal tax rate that could hit 87%. Some claimants will also lose more if their childcare costs are above the UC maximum reimbursement, although only 3% claim the maximum amount.<a href="https://docs.google.com/document/d/1bmRN50xTycjXFrdDChykaGSlfvlCEV2jkU2zv7Irhlo/edit#bookmark=id.e6zvarv66871"><sup>74</sup></a><a href="https://docs.google.com/document/d/1bmRN50xTycjXFrdDChykaGSlfvlCEV2jkU2zv7Irhlo/edit#bookmark=id.e6zvarv66871"> </a>&nbsp;</p>



<p class="wp-block-paragraph">A harder to quantify factor that lowers the incentive to work is the plethora of additional concessions that are available to those in receipt of certain benefits or below certain income thresholds. These range from free school meals and free prescriptions to legal aid and court fee remission. The Covid-19 pandemic also saw several significant new schemes rolled out nationally, including the Household Support Fund and the Holiday Activities and Food Programme. In addition, many councils operate their own discretionary schemes that provide everything from school uniform grants to leisure centre memberships and cultural passes, which taken together can amount to extensive extra entitlements.&nbsp;</p>



<p class="wp-block-paragraph">The cumulative effect of benefits passported via UC and other benefits is that it increases the fear of “losing everything” when coming off benefits. When the state offers support with almost every imaginable facet of life automatically for those remaining on benefits (or else has more complex or uncertain criteria if not on benefits) then the risk of trying work or working more is perceived as much greater. Most passported benefits and more, including the generous Motability scheme for new cars, are also available to those on disability benefits. This adds the additional incentive not just to stay on UC, but to eliminate risk even further through permanent entitlement passported by claiming PIP as well.&nbsp;</p>



<p class="wp-block-paragraph">Higher up the income distribution, cliff edges have been created in the system that present perverse incentives for families. The withdrawal of child benefit after £60,000 and the income tax personal allowance after £100,000 means that families experience wildly varying effective marginal tax rates as they earn more.<a href="https://docs.google.com/document/d/1bmRN50xTycjXFrdDChykaGSlfvlCEV2jkU2zv7Irhlo/edit#bookmark=id.q17td2xrre5i"><sup>75</sup></a><a href="https://docs.google.com/document/d/1bmRN50xTycjXFrdDChykaGSlfvlCEV2jkU2zv7Irhlo/edit#bookmark=id.q17td2xrre5i"> </a>While benefits are calculated at a household level, tax is calculated on an individual basis. This means that families are incentivised to have two lower earners rather than one higher one.&nbsp;</p>



<p class="wp-block-paragraph">Alongside the aging population, the end result of these penalties is the tax burden falling onto fewer people’s shoulders. Around 60% of income tax revenue in 2022/23 came from the top 10% of earners.<a href="https://docs.google.com/document/d/1bmRN50xTycjXFrdDChykaGSlfvlCEV2jkU2zv7Irhlo/edit#bookmark=id.a61mq7xtzwg8"><sup>76</sup></a><a href="https://docs.google.com/document/d/1bmRN50xTycjXFrdDChykaGSlfvlCEV2jkU2zv7Irhlo/edit#bookmark=id.a61mq7xtzwg8"> </a>As outlined in Onward’s <em>The Prosperity Package</em>, the top 1% of earners pay 28% of all income tax, a proportion which has risen by almost seven percentage points since 1999.<a href="https://docs.google.com/document/d/1bmRN50xTycjXFrdDChykaGSlfvlCEV2jkU2zv7Irhlo/edit#bookmark=id.o4xlr2ccuhj9"><sup>77</sup></a><a href="https://docs.google.com/document/d/1bmRN50xTycjXFrdDChykaGSlfvlCEV2jkU2zv7Irhlo/edit#bookmark=id.o4xlr2ccuhj9"> </a>Given that higher earners are more internationally mobile, revenue will continue to shrink as more people decide to leave the country, especially with recent changes to non-domiciled status. The 10,800 high net worth individuals who left the UK in 2024 are estimated to have paid as much income tax as 500,000 average households.<a href="https://docs.google.com/document/d/1bmRN50xTycjXFrdDChykaGSlfvlCEV2jkU2zv7Irhlo/edit#bookmark=id.xpylpqpa0g8l"><sup>78</sup></a><a href="https://docs.google.com/document/d/1bmRN50xTycjXFrdDChykaGSlfvlCEV2jkU2zv7Irhlo/edit#bookmark=id.xpylpqpa0g8l"> </a>The loss of this revenue is disastrous for an already low growth economy.&nbsp;</p>



<h4 class="wp-block-heading">The triple-lock delusion</h4>



<p class="wp-block-paragraph">The incentives the state imposes on older people are perhaps the most destructive of all. As discussed above, the triple lock on pensions is disastrous for the long-term sustainability of the public finances. But beyond that, it has embedded the illusion that the Government will provide a generous income for people later in life, while the NHS will pick up the rest of their needs should they fall ill.&nbsp;</p>



<p class="wp-block-paragraph">Despite auto-enrolment boosting uptake, still around 20% of private sector employees and 80% of self-employed workers are not saving into a private pension at all.<a href="https://docs.google.com/document/d/1bmRN50xTycjXFrdDChykaGSlfvlCEV2jkU2zv7Irhlo/edit#bookmark=id.z2cwzjcg6qld"><sup>79</sup></a><a href="https://docs.google.com/document/d/1bmRN50xTycjXFrdDChykaGSlfvlCEV2jkU2zv7Irhlo/edit#bookmark=id.z2cwzjcg6qld"> </a>According to a survey by the Alzheimer’s Society, half of the public incorrectly believe that dementia care costs are covered by the NHS, when these costs are largely borne by individuals and their families.<a href="https://docs.google.com/document/d/1bmRN50xTycjXFrdDChykaGSlfvlCEV2jkU2zv7Irhlo/edit#bookmark=id.1wiwz61m88xa"><sup>80</sup></a><a href="https://docs.google.com/document/d/1bmRN50xTycjXFrdDChykaGSlfvlCEV2jkU2zv7Irhlo/edit#bookmark=id.1wiwz61m88xa"> </a>While the triple lock has made the state pension more generous relative to average wages, its celebration has perpetuated misconceptions about a state-provided safety net for older people that lessens the perceived need to save through working life.&nbsp;</p>



<p class="wp-block-paragraph">As the characteristics of the cohort reaching retirement age each year changes with rises in the state pension age, the problem is only going to get worse. Healthy life expectancy &#8211; the number of years a person is expected to live in good health &#8211; has not kept pace with overall rises in life expectancy. Average healthy life expectancy is around 62 years in good health, which will leave many spending their final working years in poor health or early retirement.<a href="https://docs.google.com/document/d/1bmRN50xTycjXFrdDChykaGSlfvlCEV2jkU2zv7Irhlo/edit#bookmark=id.yztjqfjz5jgx"><sup>81</sup></a><a href="https://docs.google.com/document/d/1bmRN50xTycjXFrdDChykaGSlfvlCEV2jkU2zv7Irhlo/edit#bookmark=id.yztjqfjz5jgx"> </a>&nbsp;</p>



<p class="wp-block-paragraph">This in turn means starting to draw down their savings or starting a claim for UC and PIP, which at their higher awards are more generous than the state pension and higher rate of Attendance Allowance. Raising the state pension age to reduce the burden on the state therefore does not necessarily release the savings that might be expected and could even end up costing more as people drop out of the workforce before retirement and onto working age benefits.&nbsp;</p>



<p class="wp-block-paragraph">A further time-bomb is coming as more people reach retirement age without the financial asset of a home to rely on. The number of households aged 65 and over who are renting is projected to roughly double by 2033, surpassing a million.<a href="https://docs.google.com/document/d/1bmRN50xTycjXFrdDChykaGSlfvlCEV2jkU2zv7Irhlo/edit#bookmark=id.onbqo5rq5m7c"><sup>82</sup></a><a href="https://docs.google.com/document/d/1bmRN50xTycjXFrdDChykaGSlfvlCEV2jkU2zv7Irhlo/edit#bookmark=id.onbqo5rq5m7c"> </a>This has serious consequences not just for the housing benefit bill for those above state pension age but also for the ability of many to pay for their own social care needs, further exacerbating the burden on local authorities.</p>



<p class="wp-block-paragraph">All of these factors make it more important that the future sustainability of the triple lock is reviewed with urgency and considered alongside social care reform. The mismatch between expectations of a safety net paid into through tax that will be there in older age and the level of private savings needed for a comfortable retirement cannot continue to go unaddressed. And the sooner this is confronted, the longer those working now will have to adjust to the change.&nbsp;</p>



<h3 class="wp-block-heading">Conclusion&nbsp;</h3>



<p class="wp-block-paragraph">It will take difficult and decisive action to change the collective mindset that has led, at every level, to a state that actively limits, prescribes and involves itself in every part of family, community and work life, while taking away individuals’ means to live on their own terms. The result of these forces is the shape of the state seen today: spending commitments that politicians appear unable to prevent growing, let alone reverse. The state’s expanding reach has seen society become less free, dynamic and prosperous, while requiring ever more resources to sustain itself.&nbsp;</p>



<p class="wp-block-paragraph">The dire fiscal situation facing the country in the months ahead has not exclusively been made in the last year, nor just in the last 15 years, but it is one that has been exacerbated by recent decisions and indecision. Continuing to operate within the “statejacket” will carry on producing results that prize process before outcome. Time and opportunities to avoid what could become a truly uncontrollable crisis are running out.&nbsp;</p>



<h3 class="wp-block-heading">Endnotes&nbsp;</h3>



<p class="wp-block-paragraph">1.   Office for Budget Responsibility, <em>Public finances databank &#8211; August 2025, </em><a href="https://obr.uk/download/public-finances-databank-august-2025/?tmstv=1756373335" target="_blank" rel="noreferrer noopener">link</a>&nbsp;</p>



<p class="wp-block-paragraph">2.  Ibid&nbsp;</p>



<p class="wp-block-paragraph">3.  UK Public Spending, <em>Multiyear download of UK Government spending</em>, <a href="https://www.ukpublicspending.co.uk/download_multi_year_1930_2025UKp_17c1li011mcn_F0t40t10t20t90t30t" target="_blank" rel="noreferrer noopener">link</a>&nbsp;</p>



<p class="wp-block-paragraph">4.  Onward, <em>The Turnaround</em>, May 2025<em> </em><a href="https://www.ukonward.com/reports/the-turnaround/" target="_blank" rel="noreferrer noopener">link</a>&nbsp;</p>



<p class="wp-block-paragraph">5.  UK Public Spending, <em>Multiyear download of UK Government spending</em>, <a href="https://www.ukpublicspending.co.uk/download_multi_year_1930_2025UKp_17c1li011mcn_F0t40t10t20t90t30t" target="_blank" rel="noreferrer noopener">link</a>&nbsp;</p>



<p class="wp-block-paragraph">6.  Ibid&nbsp;</p>



<p class="wp-block-paragraph">7.  Re:state, <em>Quangocracy</em>, February 2025, <a href="https://re-state.co.uk/publications/quangocracy-the-future-of-public-bodies/" target="_blank" rel="noreferrer noopener">link</a>&nbsp;</p>



<p class="wp-block-paragraph">8.  Ibid&nbsp;</p>



<p class="wp-block-paragraph">9.  Institute of Chartered Accountants in England and Wales, <em>Chart of the Week,</em> March 2025, <a href="https://www.icaew.com/insights/viewpoints-on-the-news/2025/mar-2025/chart-of-the-week-quangos" target="_blank" rel="noreferrer noopener">link</a>&nbsp;</p>



<p class="wp-block-paragraph">10.  Financial Times, <em>The UK’s ‘quango’ state,</em> March 2025, <a href="https://www.ft.com/content/bc26ba21-3b7e-4dc4-b45f-d520f5d8164f" target="_blank" rel="noreferrer noopener">link</a>&nbsp;</p>



<p class="wp-block-paragraph">11.   Cabinet Office, ALB Landscape Data Explorer, <a href="https://civil-service-analysis.shinyapps.io/ALB_Landscape_Analysis_Explorer/" target="_blank" rel="noreferrer noopener">link</a>&nbsp;</p>



<p class="wp-block-paragraph">12.  Re:state, <em>Quangocracy</em>, February 2025, <a href="https://re-state.co.uk/publications/quangocracy-the-future-of-public-bodies/" target="_blank" rel="noreferrer noopener">link</a>&nbsp;</p>



<p class="wp-block-paragraph">13.  Aveek Bhattacharya, Social Market Foundation, <em>Why is there a £40 million quango to persuade people to eat meat and dairy?</em>, January 2025, <a href="https://www.smf.co.uk/commentary_podcasts/why-is-there-a-40-million-quango-to-persuade-people-to-eat-meat-and-dairy/" target="_blank" rel="noreferrer noopener">link</a>&nbsp;</p>



<p class="wp-block-paragraph">14.  Department for Business and Trade, <em>Office for the Pay Review Bodies</em>, <a href="https://www.gov.uk/government/organisations/office-for-the-pay-review-bodies#:~:text=The%20Office%20for%20the%20Pay%20Review%20Bodies%20provides%20an%20independent,Department%20for%20Business%20and%20Trade" target="_blank" rel="noreferrer noopener">link</a>&nbsp;</p>



<p class="wp-block-paragraph">15.  Institute for Government, <em>Pay Review Bodies,</em> <a href="https://www.instituteforgovernment.org.uk/explainer/pay-review-bodies" target="_blank" rel="noreferrer noopener">link</a>&nbsp;</p>



<p class="wp-block-paragraph">16.  Bank of England, <em>Monetary Policy Report &#8211; August 2025</em>, <a href="https://www.bankofengland.co.uk/-/media/boe/files/monetary-policy-report/2025/august/monetary-policy-report-august-2025.pdf" target="_blank" rel="noreferrer noopener">link</a>&nbsp;</p>



<p class="wp-block-paragraph">17.  Ibid&nbsp;</p>



<p class="wp-block-paragraph">18.  Department for Work and Pensions, <em>Benefits and pension rates 2024 to 2025</em>, <a href="https://www.gov.uk/government/publications/benefit-and-pension-rates-2024-to-2025/benefit-and-pension-rates-2024-to-2025" target="_blank" rel="noreferrer noopener">link</a>&nbsp;</p>



<p class="wp-block-paragraph">19.  Ibid; Department for Work and Pensions, <em>Benefits and pension rates from April 2016</em>, <a href="https://assets.publishing.service.gov.uk/media/5a7f6f3eed915d74e33f668c/benefit-and-pension-rates-from-6-april-2016.pdf" target="_blank" rel="noreferrer noopener">link</a>&nbsp;</p>



<p class="wp-block-paragraph">20.  Robert Colvile, The Times, <em>The triple lock isn’t a policy anymore, it’s a deranged cult, </em><a href="https://www.thetimes.com/comment/columnists/article/the-triple-lock-isnt-a-policy-any-more-its-a-deranged-cult-70fnldkmn" target="_blank" rel="noreferrer noopener">link</a>&nbsp;</p>



<p class="wp-block-paragraph">21.  Carl Emmerson, Institute for Fiscal Studies, <em>Pensioners deserve better than the triple lock</em>, <a href="https://ifs.org.uk/articles/pensioners-deserve-better-triple-lock" target="_blank" rel="noreferrer noopener">link</a>&nbsp;</p>



<p class="wp-block-paragraph">22.  Onward, <em>The Anti-Social Contract, </em>June 2025, <a href="https://ukonward.com/reports/the-anti-social-contract/" target="_blank" rel="noreferrer noopener">link</a>&nbsp;</p>



<p class="wp-block-paragraph">23.  Office for National Statistics, <em>Public sector finances &#8211; March 2025</em>, <a href="https://www.ons.gov.uk/economy/governmentpublicsectorandtaxes/publicsectorfinance/bulletins/publicsectorfinances/march2025" target="_blank" rel="noreferrer noopener">link</a>&nbsp;</p>



<p class="wp-block-paragraph">24.  Office for Budget Responsibility, <em>Fiscal risks and sustainability, </em>July 2025, <a href="https://obr.uk/frs/fiscal-risks-and-sustainability-july-2025/" target="_blank" rel="noreferrer noopener">link</a>&nbsp;</p>



<p class="wp-block-paragraph">25.  Ibid &nbsp;</p>



<p class="wp-block-paragraph">26.  United Kingdom Debt Management Office, <em>Historical average daily conventional gilt yields</em>, <a href="https://www.dmo.gov.uk/data/ExportReport?reportCode=D4H" target="_blank" rel="noreferrer noopener">link</a>  &nbsp;</p>



<p class="wp-block-paragraph">27.  Office for Budget Responsibility, <em>Fiscal risks and sustainability, </em>July 2025, <a href="https://obr.uk/frs/fiscal-risks-and-sustainability-july-2025/" target="_blank" rel="noreferrer noopener">link</a>&nbsp;</p>



<p class="wp-block-paragraph">28.  Ibid &nbsp;</p>



<p class="wp-block-paragraph">29.  Ibid &nbsp;</p>



<p class="wp-block-paragraph">30.  Institute for Economic Affairs, <em>The Death of British Prosperity,</em> August 2025, <a href="https://insider.iea.org.uk/p/the-death-of-british-prosperity-what" target="_blank" rel="noreferrer noopener">link</a>&nbsp;</p>



<p class="wp-block-paragraph">31.  McKinsey, <em>Improving government productivity</em>, January 2025, <a href="https://www.mckinsey.com/industries/public-sector/our-insights/improving-government-productivity-a-systemwide-approach" target="_blank" rel="noreferrer noopener">link</a>&nbsp;</p>



<p class="wp-block-paragraph">32.  EY, <em>Public sector productivity gap costs the UK economy £80bn a year</em>, August 2025, <a href="https://www.ey.com/en_uk/newsroom/2025/08/public-sector-productivity-gap-costs-uk-economy" target="_blank" rel="noreferrer noopener">link</a>&nbsp;</p>



<p class="wp-block-paragraph">33.  Institute for Government, <em>Government reshuffles, </em>January 2020, <a href="https://www.instituteforgovernment.org.uk/sites/default/files/publications/government-reshuffles.pdf" target="_blank" rel="noreferrer noopener">link</a>&nbsp;</p>



<p class="wp-block-paragraph">34.  HMT, <em>Spending Review 2025, </em><a href="https://assets.publishing.service.gov.uk/media/68627094354985706f111adc/E03349913_HMT_Spending_Review_June_2025_TEXT_CS_Accessible__002_.pdf" target="_blank" rel="noreferrer noopener">link</a>&nbsp;</p>



<p class="wp-block-paragraph">35.  HMT,<em> Spending review and autumn statement 2015</em>, <a href="https://www.gov.uk/government/publications/spending-review-and-autumn-statement-2015-documents/spending-review-and-autumn-statement-2015" target="_blank" rel="noreferrer noopener">link</a>&nbsp;</p>



<p class="wp-block-paragraph">36.  Ministry of Justice, <em>10-year Prison Capacity Strategy, </em>December 2024, <a href="https://www.gov.uk/government/publications/10-year-prison-capacity-strategy" target="_blank" rel="noreferrer noopener">link</a>&nbsp;</p>



<p class="wp-block-paragraph">37.  Onward,<em> Breaking Blue,</em> September 2024, <a href="https://www.ukonward.com/reports/breaking-blue-2/" target="_blank" rel="noreferrer noopener">link</a>&nbsp;</p>



<p class="wp-block-paragraph">38.  YouGov, <em>Are we taxing and spending the right amount,</em> August 2025, <a href="https://yougov.co.uk/topics/politics/trackers/are-we-taxing-and-spending-the-right-amount?period=5yrs" target="_blank" rel="noreferrer noopener">link</a>&nbsp;</p>



<p class="wp-block-paragraph">39.  Centre for Policy Studies, <em>Justice for the young, </em>November 2023, <a href="https://cps.org.uk/wp-content/uploads/2023/11/CPS_JUSTICE_FOR_THE_YOUNG.pdf" target="_blank" rel="noreferrer noopener">link</a>&nbsp;</p>



<p class="wp-block-paragraph">40.  The Economist, <em>Nigel Farage’s economic plans are a disaster</em>, May 2025, <a href="https://www.economist.com/britain/2025/05/08/nigel-farages-economic-plans-are-a-disaster" target="_blank" rel="noreferrer noopener">link</a>&nbsp;</p>



<p class="wp-block-paragraph">41.  Institute for Government, <em>Fixing public services: Local Government, </em>July 2024, <a href="https://www.instituteforgovernment.org.uk/publication/fixing-public-services-labour-government/local-government" target="_blank" rel="noreferrer noopener">link</a>&nbsp;</p>



<p class="wp-block-paragraph">42.  National Audit Office, <em>Local government financial sustainability</em>, February 2025, <a href="https://www.nao.org.uk/wp-content/uploads/2025/02/local-government-financial-sustainability.pdf" target="_blank" rel="noreferrer noopener">link</a>&nbsp;</p>



<p class="wp-block-paragraph">43.  Institute for Government, <em>Fixing public services: Local Government, </em>July 2024, <a href="https://www.instituteforgovernment.org.uk/publication/fixing-public-services-labour-government/local-government" target="_blank" rel="noreferrer noopener">link</a>&nbsp;</p>



<p class="wp-block-paragraph">44.  National Audit Office, <em>Local government financial sustainability</em>, February 2025, <a href="https://www.nao.org.uk/wp-content/uploads/2025/02/local-government-financial-sustainability.pdf" target="_blank" rel="noreferrer noopener">link</a>&nbsp;</p>



<p class="wp-block-paragraph">45.  Department for Communities and Local Government, <em>Summary of the review of statutory duties placed on local government</em>, June 2011, <a href="https://assets.publishing.service.gov.uk/media/5a79d2ceed915d042206b4a4/1934356.pdf" target="_blank" rel="noreferrer noopener">link</a>&nbsp;</p>



<p class="wp-block-paragraph">46.  Local Government Lawyer, <em>Government to review local authority legislation and statutory duties in bid to reduce bureaucracy, </em>July 2025, <a href="https://www.localgovernmentlawyer.co.uk/governance/396-governance-news/61474-government-to-review-local-authority-legislation-and-statutory-duties-in-bid-to-reduce-bureaucracy" target="_blank" rel="noreferrer noopener">link</a>&nbsp;</p>



<p class="wp-block-paragraph">47.  HMT, <em>Spending Review 2025, </em><a href="https://assets.publishing.service.gov.uk/media/68627094354985706f111adc/E03349913_HMT_Spending_Review_June_2025_TEXT_CS_Accessible__002_.pdf" target="_blank" rel="noreferrer noopener">link</a>&nbsp;</p>



<p class="wp-block-paragraph">48.  Ministry of Housing Communities and Local Government,<em> Council Tax levels set by local authorities in England 2025 to 2026 (revised),</em> <a href="https://www.gov.uk/government/statistics/council-tax-levels-set-by-local-authorities-in-england-2025-to-2026/council-tax-levels-set-by-local-authorities-in-england-2025-to-2026" target="_blank" rel="noreferrer noopener">link</a>&nbsp;</p>



<p class="wp-block-paragraph">49.&nbsp; Ministry of Housing, Communities and Local Government, <em>English Devolution White Paper</em><em>​</em><em>: Power and partnership: Foundations for growth,</em> December 2024, <a href="https://www.gov.uk/government/publications/english-devolution-white-paper-power-and-partnership-foundations-for-growth" target="_blank" rel="noreferrer noopener">link </a>&nbsp;</p>



<p class="wp-block-paragraph">50.  Institute for Government, <em>Local government funding in England,</em> March 2020, <a href="https://www.instituteforgovernment.org.uk/explainer/local-government-funding-england" target="_blank" rel="noreferrer noopener">link</a>&nbsp;</p>



<p class="wp-block-paragraph">51.  Institute for Fiscal Studies, <em>Fair Funding Review 2.0: the impacts on council funding across England, </em>August 2025, <a href="https://ifs.org.uk/publications/fair-funding-review-20-impacts-council-funding-across-england" target="_blank" rel="noreferrer noopener">link</a>&nbsp;</p>



<p class="wp-block-paragraph">52.  National Audit Office, <em>Government’s general grant schemes, </em>July 2024, <a href="https://www.nao.org.uk/wp-content/uploads/2024/07/governments-general-grant-schemes.pdf" target="_blank" rel="noreferrer noopener">link</a>&nbsp;</p>



<p class="wp-block-paragraph">53.  Ibid&nbsp;</p>



<p class="wp-block-paragraph">54.  Ministry of Housing, Communities and Local Government, <em>Local audit reform: Government response to the consultation to overhaul local audit in England, </em>April 2025, <a href="https://www.gov.uk/government/consultations/local-audit-reform-a-strategy-for-overhauling-the-local-audit-system-in-england/outcome/local-audit-reform-government-response-to-the-consultation-to-overhaul-local-audit-in-england" target="_blank" rel="noreferrer noopener">link</a>&nbsp;</p>



<p class="wp-block-paragraph">55.  Institute of Chartered Accountants in England and Wales, <em>CIPFA urges action to tackle council finance staff shortages, </em>November 2024, <a href="https://www.icaew.com/insights/viewpoints-on-the-news/2024/nov-2024/cipfa-urges-action-to-tackle-council-finance-staff-shortages" target="_blank" rel="noreferrer noopener">link</a>&nbsp;</p>



<p class="wp-block-paragraph">56.  Public Accounts Committee, <em>Local Government Financial Sustainability, </em>June 2025, <a href="https://publications.parliament.uk/pa/cm5901/cmselect/cmpubacc/647/report.html" target="_blank" rel="noreferrer noopener">link</a>&nbsp;</p>



<p class="wp-block-paragraph">57.  Office for Budget Responsibility, <em>Economic and fiscal outlook – March 2025</em>, <a href="https://obr.uk/efo/economic-and-fiscal-outlook-march-2025/" target="_blank" rel="noreferrer noopener">link</a>&nbsp;</p>



<p class="wp-block-paragraph">58.  Chartered Institute of Public Finance and Accountancy, <em>Managing rising demand in adult and children’s social care</em>, July 2024, <a href="https://www.cipfa.org/-/media/files/cipfa-thinks/insight/managing-rising-demand-in-adult-and-children%E2%80%99s-social-care.pdf" target="_blank" rel="noreferrer noopener">link</a>&nbsp;</p>



<p class="wp-block-paragraph">59.  Department of Health and Social Care, <em>Independent commission into adult social care; terms of reference,</em> July 2025, <a href="https://www.gov.uk/government/publications/independent-commission-into-adult-social-care-terms-of-reference/independent-commission-into-adult-social-care-terms-of-reference" target="_blank" rel="noreferrer noopener">link</a>&nbsp;</p>



<p class="wp-block-paragraph">60.  Unison, <em>National Care Service, </em><a href="https://www.unison.org.uk/our-campaigns/lets-make-care-work/" target="_blank" rel="noreferrer noopener">link</a>&nbsp;</p>



<p class="wp-block-paragraph">61.  The King’s Fund,<em> Social Care 360: Expenditure,</em> March 2025, <a href="https://www.kingsfund.org.uk/insight-and-analysis/long-reads/social-care-360-expenditure" target="_blank" rel="noreferrer noopener">link</a>&nbsp;</p>



<p class="wp-block-paragraph">62.  UK Parliament, Written questions and answers, <em>Social services: pay,</em> February 2024, <a href="https://questions-statements.parliament.uk/written-questions/detail/2024-02-20/14881/" target="_blank" rel="noreferrer noopener">link</a>&nbsp;</p>



<p class="wp-block-paragraph">63.  ISOS Partnership, <em>Towards an effective and financially sustainable approach to SEND in England, </em>July 2024, <a href="https://static1.squarespace.com/static/5ce55a5ad4c5c500016855ee/t/669fcedacd1a1f608546f52b/1721749338168/SEND+report.pdf" target="_blank" rel="noreferrer noopener">link</a>&nbsp;</p>



<p class="wp-block-paragraph">64.  County Councils Network, <em>Councils call for reform of SEND school transport services as costs double for local authorities in county areas over the last five years, </em>March 2024, <a href="https://www.countycouncilsnetwork.org.uk/councils-call-for-reform-of-send-school-transport-services-as-costs-double-for-local-authorities-in-county-areas-over-the-last-five-years/" target="_blank" rel="noreferrer noopener">link</a>&nbsp;</p>



<p class="wp-block-paragraph">65.  Institute for Fiscal Studies, <em>What the Spending Review really means for schools, </em>July 2025, <a href="https://ifs.org.uk/articles/what-spending-review-really-means-schools" target="_blank" rel="noreferrer noopener">link</a>&nbsp;</p>



<p class="wp-block-paragraph">66.  ISOS Partnership, <em>Towards an effective and financially sustainable approach to SEND in England, </em>July 2024, <a href="https://static1.squarespace.com/static/5ce55a5ad4c5c500016855ee/t/669fcedacd1a1f608546f52b/1721749338168/SEND+report.pdf" target="_blank" rel="noreferrer noopener">link</a>&nbsp;</p>



<p class="wp-block-paragraph">67.  The King’s Fund, <em>Integrated Care Systems explained, </em>August 2022, <a href="https://www.kingsfund.org.uk/insight-and-analysis/long-reads/integrated-care-systems-explained" target="_blank" rel="noreferrer noopener">link</a>&nbsp;</p>



<p class="wp-block-paragraph">68.  Care Quality Commission, <em>The state of health and adult social care in England 2023/24, </em>October 2024, <a href="https://www.cqc.org.uk/publications/major-report/state-care/2023-2024/summary" target="_blank" rel="noreferrer noopener">link</a>&nbsp;</p>



<p class="wp-block-paragraph">69.  Onward, <em>The Turnaround</em>, May 2025<em> </em><a href="https://www.ukonward.com/reports/the-turnaround/" target="_blank" rel="noreferrer noopener">link</a>&nbsp;</p>



<p class="wp-block-paragraph">70.  Onward, <em>The Anti-Social Contract, </em>June 2025, <a href="https://ukonward.com/reports/the-anti-social-contract/" target="_blank" rel="noreferrer noopener">link</a>&nbsp;</p>



<p class="wp-block-paragraph">71.  Centre for Policy Studies, <em>The progressivity of UK taxes and transfers, </em>October 2012, <a href="https://cps.org.uk/wp-content/uploads/2021/07/121005151233-TheprogressivityofUKtaxesandtransfers.pdf" target="_blank" rel="noreferrer noopener">link</a>&nbsp;</p>



<p class="wp-block-paragraph">72.  Office for National Statistics, <em>Effects of taxes and benefits on UK household income: financial year ending 2023, </em>December 2024, <a href="https://www.ons.gov.uk/peoplepopulationandcommunity/personalandhouseholdfinances/incomeandwealth/bulletins/theeffectsoftaxesandbenefitsonhouseholdincome/financialyearending2023" target="_blank" rel="noreferrer noopener">link</a>&nbsp;</p>



<p class="wp-block-paragraph">73.  Ibid&nbsp;</p>



<p class="wp-block-paragraph">74.  Department for Work and Pensions, <em>Universal Credit childcare element statistics March 2021 to November 2024, </em>link&nbsp;</p>



<p class="wp-block-paragraph">75.  Resolution Foundation, <em>Inconsistent incentives, </em>December 2022, <a href="https://www.resolutionfoundation.org/publications/inconsistent-incentives/" target="_blank" rel="noreferrer noopener">link</a>&nbsp;</p>



<p class="wp-block-paragraph">76.  HM Revenue and Customs, <em>Bulletin &#8211; Commentary, </em>July 2025, <a href="https://www.gov.uk/government/statistics/income-tax-liabilities-statistics-tax-year-2022-to-2023-to-tax-year-2025-to-2026/bulletin-commentary" target="_blank" rel="noreferrer noopener">link</a>&nbsp;</p>



<p class="wp-block-paragraph">77.  Onward, <em>The Prosperity Package, </em>July 2025, <a href="https://ukonward.com/reports/the-prosperity-package/" target="_blank" rel="noreferrer noopener">link</a>&nbsp;</p>



<p class="wp-block-paragraph">78.  Ibid&nbsp;</p>



<p class="wp-block-paragraph">79.  Institute for Fiscal Studies, <em>The Pensions Review: final recommendations,</em> July 2025, <a href="https://ifs.org.uk/publications/pensions-review-final-recommendations#:~:text=This%20final%20report%20of%20the,proposals%20primarily%20focused%20on%20improving" target="_blank" rel="noreferrer noopener">link</a>&nbsp;</p>



<p class="wp-block-paragraph">80.  Alzheimer’s Society, <em>The case for the Dementia Fund, </em>May 2019,<em> </em><a href="https://www.alzheimers.org.uk/sites/default/files/2019-05/Dementia%20Fund%20Report.pdf" target="_blank" rel="noreferrer noopener">link</a>&nbsp;</p>



<p class="wp-block-paragraph">81.  Office for National Statistics, <em>Health state life expectancies in England, Northern Ireland and Wales: between 2011 to 2013 and 2021 to 2023,</em> <a href="https://www.ons.gov.uk/peoplepopulationandcommunity/healthandsocialcare/healthandlifeexpectancies/bulletins/healthstatelifeexpectanciesuk/between2011to2013and2021to2023" target="_blank" rel="noreferrer noopener">link</a>&nbsp;</p>



<p class="wp-block-paragraph">82.  Hamptons, <em>An upsurge in older renters</em>, July 2023, <a href="https://www.hamptons.co.uk/articles/june-2023-lettings-index" target="_blank" rel="noreferrer noopener">link</a></p>
<p>The post <a href="https://ukonward.com/reports/statejacket/">Statejacket</a> appeared first on <a href="https://ukonward.com">Onward</a>.</p>
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