Warm Scots Welcome programme: equality impact assessment

Key Findings

Protected characteristic: Age

Between March 2022 and March 2025, the highest proportion of Scottish Super Sponsor arrivals were in the 18-64 age group for both males (74%) and females (81%), with 78% of arrivals overall in this age category. Those under the age of 18 accounted for approximately 19% of all arrivals with a Super Sponsor visa, and around 3% of arrivals were over the age of 65^[9].

In 2023 16% of Scotland’s population was aged between 0 and 15 years of age; 64% of the population was aged 16-64; and 20% was aged 65 or older^[10].

Ukrainian arrivals to the UK under the Super Sponsor scheme between March 2022 and March 2025 were therefore younger than reflected in the wider Scottish population, with a much smaller proportion of adults over the age of 65.

Offers of Accommodation Policy

The impact on the protected characteristic of age is assessed as neutral, as there is no evidence that the introduction of the initial offers of accommodation policy, or its revision to a one offer approach, had any specific impacts based on the protected characteristic of age.

The policy was developed to ensure that people of all ages would be entitled to an offer that would consider their individual circumstances, including those that may relate to age. For example, offers of accommodation must consider any disability requirements that may be age-related, and include reasonable adjustments for caring responsibilities or other needs. Where a specific type of accommodation is required due to long-term illness or disability, offers must take this into account. This could include making an offer of sheltered housing, where additional support can be provided to older adults.

For children and young people, all offers of accommodation must consider educational needs, with school and nursery places available within the area of the offer, including for children with additional support needs. For households with children, receiving an offer of longer-term accommodation could mean leaving a school close to their welcome accommodation where they had been enrolled. Whilst changing schools can be challenging for both children and parents, it was assessed that the known benefits of settled housing, including on educational attainment^[11], would best support long-term outcomes for children and young people.

Changes to provision of concessionary meals

The impact of changes to the provision of concessionary meals on the protected characteristic of age is assessed as neutral.

Prior to implementation, it was identified that ceasing the provision of lunchtime meals and snacks could negatively affect children and young people by limiting access to a healthy and balanced diet essential for growth and development. However, this risk was assessed as relatively low because most children in welcome accommodation attend school during the day and therefore continue to receive lunch at school. Children in primary years 1-5 benefit from free school lunches, and children of all ages from households receiving qualifying benefits are also entitled to free school meals.

In addition, children attending funded early learning and childcare sessions receive a free meal, and families eligible for free school meals receive payments to cover lunch costs during school holidays. On this basis, the removal of concessionary lunches was assessed as unlikely to have any significant impact on children under 18 or on meeting their dietary requirements for healthy growth and development.

No other specific additional impacts were identified relating to age and removing concessionary lunches and snacks and there has been no evidence to date that there have been any specific impacts relating to this change and the protected characteristic of age.

When introducing the £3 dinner contribution charge, an assessment was undertaken to determine a sum that would be affordable for all displaced people in welcome accommodation. This was calculated using data on access to benefits and the average proportion of household income spent on food in the UK, as it was not possible to account for income from employment or savings. Based on this analysis, a charge of £3 was considered affordable for most displaced people.

However, it was identified that adults under the age of 25 who are not in employment and solely in receipt of benefits could face a greater impact. This is because the Universal Credit rate for adults under 25 is lower than for those over 25, meaning a higher proportion of their income would be spent on dinner charges.

To reduce the risk that dinner contribution charges could limit access to a nutritious evening meal for people of all ages, local authorities have discretion to waive the charge where it is assessed that doing so would mitigate risk to the individual and a safeguarding need has been identified. In addition, dinners are provided free of charge to displaced people of all ages for the first six weeks after arrival in Scotland, allowing sufficient time for any benefits they may be entitled to be processed and paid.

Protected characteristic: Disability

In terms of physical health, around three-quarters (74%) of respondents to a 2023 Office for National Statistics survey on visa holders entering the UK under the Ukraine Humanitarian Schemes reported their physical health as "good or very good"^[12]. This is comparable to data from the 2023 Scottish Health Survey in which 72% of adults in Scotland reported their health to be ‘very good/good’^[13].

In terms of mental health, 67% of Ukrainians who had entered the UK under the Ukraine Humanitarian Schemes surveyed in 2023 marked their mental health as "good or very good"^[14]. However, various studies have demonstrated an increased prevalence of mental health conditions including PTSD, anxiety and depression among displaced Ukrainians. Stigma around mental health may lead to an under-reporting of mental health difficulties in some cases, and in one small-scale study of displaced Ukrainians in Scotland, 55% experienced clinically significant stress and anxiety, including 30% with severe clinical distress^[15]. According to the most recent Scottish census, 11.3% of the population reported a mental health condition, suggesting that the prevalence of mental health conditions among Ukrainians in Scotland may be higher than among the wider Scottish population^[16].

According to the 2022 Scottish Health Survey, 37% of adults in Scotland reported a limiting long-term condition. There is no specific data available on the prevalence of disabilities among displaced Ukrainians in the UK, however as the rate of disability is generally higher amongst women than men^[17], there may be an overall higher prevalence of disabilities among the Ukrainian population in Scotland overall, due to the higher proportion of female arrivals compared to males.

Offers of Accommodation Policy

The introduction of the Offers of Accommodation Policy is assessed as having a slightly positive impact on individuals with the protected characteristic of disability. The policy aims to support displaced people living in welcome accommodation to transition into longer-term housing. Evidence shows that prolonged stays in temporary accommodation can negatively affect health and wellbeing^[18], whereas settled housing promotes integration and improves long-term outcomes for refugees and displaced people.

For individuals with disabilities, settled housing offers greater opportunities to meet specific needs, as appropriate adaptations can be made to the property. This ensures a safer, more accessible, and supportive living environment.

To guarantee that the needs of disabled people are fully considered, the definition of a reasonable offer under this policy requires that any accommodation provided must meet the disability-related requirements of the individual or household. Local authorities work closely with displaced people to gain a comprehensive understanding of the needs of all household members, including those related to disability, before making an offer.

Anecdotal feedback indicates that some disabled people in welcome accommodation may experience longer waiting times for offers of accommodation compared to non-disabled guests. This is primarily due to the limited availability of properties that meet specific accessibility requirements. For example, where a disability restricts mobility and a property on a single level is required, the pool of suitable housing options is significantly reduced. In such cases, this constraint can lead to delays in receiving an offer.

Local authority partners work closely with displaced people to understand their individual needs and, where necessary, make offers of suitable accommodation across different local authority areas. The Scottish Government continues to collaborate with local authorities to identify potential properties that meet accessibility requirements and to minimise delays wherever possible. In addition, the Scottish Government actively encourages applications to the Ukraine Long-Term Resettlement Fund for properties that could be adapted to accommodate disabled guests, thereby increasing the overall supply of suitable housing.

Changes to provision of concessionary meals

The impact of changes to the provision of concessionary meals on the protected characteristic of disability is assessed as neutral.

Before implementing any changes to concessionary lunch provision, the Scottish Government ensured that all welcome accommodation sites had a range of alternative food outlets within an accessible distance and that providers would continue to offer lunches to displaced people, where possible at a reduced rate. It was recognised that guests with disabilities affecting mobility or their ability to access food outside their hotel could be disproportionately impacted if concessionary lunches and snacks were removed and alternative options were not easily accessible.

To mitigate this risk, the Scottish Government worked with local authorities to assess accessibility at each welcome accommodation site and implement measures where needed, particularly in rural locations. Examples include providing shuttle buses for hotels with limited public transport to enable access to food outlets or relocating displaced people to alternative accommodation where necessary. These actions aimed to ensure that all displaced people, including those with disabilities, could continue to access a lunchtime meal.

Regarding the introduction of the £3 dinner charge, this amount was based on evidence of the likely minimum income for displaced people in welcome accommodation. Additional benefits relating to disability were not included in this calculation, and it was therefore assessed that displaced people with disabilities would not be less financially able to afford the charge than other guests. However, to safeguard individuals who may be unable to pay, the policy allows local authorities to waive the charge for financial or safeguarding reasons. This exemption can apply where disability-related costs make the charge unaffordable.

Protected characteristic: Sex

Between March 2022 and March 2025 female Super Sponsor visa holders accounted for approximately 57% of arrivals and males accounted for 43% of arrivals. There was some variation across age groups, with women accounting for 60% of all arrivals between 18-64 and men accounting for 40%^[19]. This can be attributed to military conscription in Ukraine for men aged 25-60.

Offers of Accommodation Policy

The impact of introducing the Offers of Accommodation Policy on the protected characteristic of sex is assessed as neutral, as no gender-specific disadvantages have been identified. However, a higher proportion of women compared to men were expected to benefit from receiving offers of accommodation, reflecting the overall demographic of visa recipients, which includes more women than men. Consequently, more women are likely to have moved from welcome accommodation into longer-term housing, which is known to support stability, integration, and improved long-term outcomes.

In assessing the potential impact of the policy, consideration was given to mitigating barriers to moving on from welcome accommodation, including affordability-related barriers, which evidence suggests are more likely to affect women than men. These considerations informed the design of the policy to ensure equitable access to suitable housing for all displaced people.

The gender pay-gap means females earn proportionately less than males^[20] and that lone parent households, which are predominantly headed by women are more likely to work fewer hours than parents in couples, and to have a lower household income on average compared to households with two parents^[21],[22].

In terms of typical household composition of displaced people in welcome accommodation, it is known that there is a higher proportion of females overall, and a high proportion of lone parents and specifically lone mother households compared to the general population, due to military conscription. Data from a 2023 shows that 45% of respondents entering the UK under the Ukraine Humanitarian Scheme had at least one dependent child and around half of whom reported that childcare responsibilities limited their ability to work, with 78% reporting they could only work part-time^[23]. In the same survey, 45% of respondents reported that they were unable to afford rent with their income; 29% reported being unable to afford a deposit or other upfront payments; and 17% reported being unable to afford rent with the benefits they received^[24].

Concerns about affordability were strongly reflected in face-to-face stakeholder workshops on barriers to leaving welcome accommodation, particularly in relation to accessing housing in the private rented sector. To mitigate the risk that affordability-related challenges could lead displaced people to decline offers of longer-term accommodation, a risk more likely to affect women, especially lone mothers, a definition of a reasonable offer was agreed. This definition requires that all offers of accommodation must be affordable for the household based on available income and access to benefits.

Offers could include social housing provided by local authorities or Registered Social Landlords, private rented sector properties, or mid-market rentals, depending on the household’s financial circumstances. Local authorities also worked closely with displaced people to ensure awareness of benefit entitlements, including housing benefit, and to provide support with social benefit applications where required. Additionally, housing funded through the Ukraine Long-Term Resettlement Fund has increased the supply of affordable social housing across Scotland, creating an important pipeline of properties for displaced people leaving welcome accommodation.

In evaluating the impact of the Offers of Accommodation Policy since implementation, there is no evidence that offers are more likely to be declined by either sex, nor that the policy has had different or more significant impacts on men or women.

Changes to provision of concessionary meals

The impact of changes to the provision of concessionary meals on the protected characteristic of sex is assessed as neutral. No specific impacts were identified based on sex. However, affordability was recognised as a potential barrier to accessing nutritious meals if all meals and snacks were no longer provided. As outlined above, affordability-related concerns may be more likely to affect women than men, particularly lone mothers.

In relation to the cessation of concessionary lunches and snacks, it was identified that single mothers may face greater affordability challenges when purchasing lunches for themselves and their children. Mitigation measures were considered, including the continued provision of free lunchtime meals for children in Primary 1–5 and for children of all ages in households receiving qualifying benefits. This reduces the risk for younger children and those from lower-income families. Children attending funded early learning and childcare sessions are also entitled to a free meal, and families receiving free school meals are eligible for payments to cover the cost of lunches during school holidays.

To date, there is no evidence that ceasing the provision of concessionary lunches and snacks has had an impact on the protected characteristic of sex.

As with the removal of concessionary lunches, affordability was identified as a potential barrier in relation to the introduction of a dinner contribution charge, which may be more likely to impact women, particularly lone mothers. To determine an affordable charge, the Scottish Government assessed likely minimum household income based on benefit entitlement, excluding other forms of income such as savings or employment, as it was not possible to assess these individually. A charge of £3 was set, based on evidence of the average proportion of household income spent on food by UK households.

To safeguard displaced people who may be unable to pay the charge, the policy allows local authorities to waive the contribution for financial or safeguarding reasons. This exemption can apply where disability, childcare responsibilities, or other circumstances create affordability challenges.

To date, there is no evidence that the dinner contribution charge has had differing or more significant impacts based on the protected characteristic of sex.

Protected characteristic: Pregnancy and Maternity

There is no data available on the number of Ukrainians under the Homes for Ukraine scheme living in Scotland or the rest of the UK that relate to pregnancy and maternity, or any available data on the number of Ukrainians in welcome accommodation relating to pregnancy and maternity.

Offers of Accommodation Policy

The impact of introducing the Offers of Accommodation Policy on the protected characteristic of pregnancy and maternity is assessed as neutral. There is no evidence that specific barriers exist in relation to pregnancy and maternity within the policy, nor that the impact differs or is more significant for people with this protected characteristic.

Where displaced people in welcome accommodation have been pregnant, local authority partners have worked closely with individuals to identify options for longer-term accommodation at the earliest possible opportunity. This approach aims to support positive outcomes for both the mother and child by ensuring timely access to suitable housing.

Changes to provision of concessionary meals

The impact of changes to the provision of concessionary meals on the protected characteristic of pregnancy and maternity is assessed as neutral.

During pregnancy, women may require an increased intake of key nutrients, making access to a healthy and balanced diet particularly important. Mitigations were put in place prior to any changes taking effect to ensure displaced people could continue to access a lunchtime meal and an affordable evening meal.

Before the cessation of concessionary lunches and snacks, the Scottish Government worked with welcome accommodation providers to ensure displaced people could purchase lunch directly from their accommodation wherever possible, ideally at a reduced price. For example, guests on the passenger ships MS Ambition and MS Victoria were able to purchase lunch for £3 from the ship’s restaurant. At the request of local authorities, shuttle buses were also provided where necessary to enable access to affordable food outlets. In some cases, welcome accommodation offered food storage facilities and basic preparation spaces, allowing displaced people to store and prepare light meals themselves.

Additionally, local authorities retain the ability to waive the dinner contribution charge for financial or safeguarding reasons. This includes circumstances where waiving the charge is necessary to support health and wellbeing during pregnancy or postpartum, ensuring that affordability does not become a barrier to adequate nutrition.

Protected characteristic: Gender Reassignment

There is no available data on gender reassignment among the Ukrainian population in Scotland or the UK. According to the 2022 Scottish Census, 0.44% of the population were trans or had a trans history^[25].

Offers of Accommodation Policy

The impact of introducing the Offers of Accommodation Policy on the protected characteristic of gender reassignment is assessed as neutral. There is no evidence that specific barriers exist in relation to gender reassignment within the policy, nor that the impact differs or is more significant for trans people compared to those who do not share this protected characteristic.

Changes to provision of concessionary meals

The impact of changes to the provision of concessionary dinners on the protected characteristic of gender reassignment is assessed as neutral. There is no evidence that any specific barriers exist for trans people in relation to these changes, nor that the impact differs or is more significant for trans people compared to those who do not share this protected characteristic.

Protected characteristic: Sexual Orientation

There is no available data on the sexual orientation of Ukrainians under the Homes for Ukraine scheme, or on Ukrainians living in welcome accommodation. According to one study by IPSOS, an average of 9% of adults in 30 countries identify as LGBT+.^[26]

Offers of Accommodation Policy

The impact of introducing the Offers of Accommodation Policy on the protected characteristic of sexual orientation is assessed as neutral. There is no evidence that any specific barriers exist in relation to sexual orientation within the policy, nor that the impact differs or is more significant based on sexual orientation.

Changes to provision of concessionary meals

The impact of changes to the provision of concessionary meals on the protected characteristic of sexual orientation is assessed as neutral. There is no evidence that any specific barriers exist in relation to sexual orientation, nor that the impact differs or is more significant based on sexual orientation.

Protected characteristic: Race

Data collected by the Home Office on Homes for Ukraine visa applicants or arrivals does not include either race or ethnicity. Eligibility criteria for the Homes for Ukraine scheme requires applicants to be a Ukrainian national, or the immediate family member of a Ukrainian national. Whilst most arrivals have been Ukrainian, presentations at the Welcome Hubs and to welcome accommodation have evidenced that visas have been granted to nationals from a wide range of countries under the Super Sponsor Scheme. As of December 2024, there have been 21,000 arrivals to the UK sponsored by the Scottish Government.

There are a number of different ethnic groups within the Ukrainian population with data suggesting the biggest ethnic group are Ukrainian (77.8%) followed by Russian (17.3%), Belarusian (0.6%), Moldovan (0.5%), Crimean Tatar (0.5%), Bulgarian (0.4%), Hungarian (0.3%) Romanian (0.3%), Polish (0.2%) and other ethnic groups comprising 1.8% of the population^[27]. According to the last census conducted in Ukraine in 2001, 67% of the population speak Ukrainian and 30% speak Russian at their first language. Other minority languages are also spoken including Romanian, Crimean Tatar, Bulgarian, and Hungarian^[28].

Offers of Accommodation Policy

The impact of introducing the Offers of Accommodation Policy on the protected characteristic of race is assessed as neutral. The policy applies specifically to those entitled to welcome accommodation, who are likely to be predominantly Ukrainian nationals; however, entitlement to offers applies equally to all displaced people in welcome accommodation, regardless of race or ethnicity.

While no specific barriers to accepting offers of accommodation based on race have been identified, limited English proficiency was recognised as a potential barrier for some displaced people in understanding offers and fully considering their options. To address this, the policy requires that offers be made in writing and provided in Ukrainian (or Russian when requested or where it is known that Russian is the displaced person’s first language), with interpreting services available to support discussions about accommodation offers.

Changes to provision of concessionary meals

The impact of changes to the provision of concessionary dinners on the protected characteristic of race is assessed as neutral. There is no evidence that any specific barriers exist based on race in relation to these changes, nor that the impact differs or is more significant for any racial group.

Protected characteristic: Religion or Belief

There is no available data on religion or belief for Ukrainians under the Homes for Ukraine scheme, or on Ukrainians living in welcome accommodation, however 30% of respondents to an Office for National Statistics survey of visa holders who had entered the UK under the Ukraine Humanitarian Schemes responded that they had attended a place of worship within the last 30 days^[29].

Offers of Accommodation Policy

The impact of introducing the Offers of Accommodation Policy on the protected characteristic of religion or belief is assessed as neutral. There is no evidence that any specific barriers exist in relation to religion or belief within the policy, nor that the impact differs or is more significant based on religion or belief.

Changes to provision of concessionary meals

The impact of changes to the provision of concessionary dinners on the protected characteristic of religion or belief is assessed as neutral. There is no evidence that any specific barriers exist based on religion or belief in relation to these changes, nor that the impact differs or is more significant for individuals of any particular religion or belief.