Scottish Welfare Fund statutory guidance amendments - April 2026: equality impact assessment

Stage 1: Framing

1.4 Results of framing exercise

• The SWF annual statistics are released each year. An equalities summary was last published alongside this in 2025 which includes a breakdown of applications and awards per protected characteristic, including age, gender, ethnicity, religion and disability.
• Recent data from the equalities summary published alongside the SWF 2024-25 annual statistics tells us that most applicants to the fund are between 30 and 39 years old. This has remained consistent since the SWF launched in 2013. The proportion of applicants under 30 has declined over the last 5 years and this has been mirrored by an increase in applications from those over 40. The distribution of applicants by age declines steeply until the mid-sixties, then flattens.^[3]
• The 2024-25 SWF equalities summary provided information on the prevalence of disabilities (‘physical or mental health condition or illness lasting or expected to last 12 months or more’), amongst applicant household members.^[4] However, data quality was variable across local authorities: 16 were excluded from analysis for this reason. Amongst the remaining local authorities, around half of applicants reported disabilities. This proportion was consistent since April 2020 and similar for Community Care and Crisis Grant applications. Where a disability was reported, these applications had slightly higher award rates than those with no disabilities recorded – but with smaller awards than those with no disabilities noted.^[5]
• In 2024-25, more than half of SWF applicants were female, which has been consistent over the last 5 years. This pattern was similar by grant type with 57% of Community Care Grant applicants and 51% of Crisis Grant applicants being female. There is currently very little data available on people who identify as non-binary, although this was only an option to select for applicants towards the end of 2023/24.^[6]
• Information was also collected on the ethnicity of applicants, although around 46% of responses were ‘Refused’. White ethnicities made up 90% of Crisis Grant applications and 89% of Community Care Grant applications in 2024-25, which is similar to the average for the lifetime of the fund. The second largest ethnic group was ‘other’, making up 8% for both grants. This was followed by Black, Caribbean or African (1%) and Asian (1%). The average award values for both Community Care Grants and Crisis Grants were higher for all ethnic minority compared to the White ethnic group.^[7]
• The 2025 equalities summary highlighted that applicants of mixed heritage had the largest amount of younger applicants with 75% under 40. This group of people also have the largest proportion of under-25 (24%).^[8]
• Data provided on the religion of applicants had variable data quality across local authorities. Of the available dataset of 1,284,530 applications from 22 local authorities (448,414 applications were not counted in this figure as it was assumed these had conflated ‘none’ and ‘refused’), 59% of these were ‘refused’ and not counted in subsequent religion question analysis. The most common response to the religion question for Community Care Grants and Crisis grants was ‘none’ at 69% and 73%. The most common religion mentioned was Christian (26% and 23%) then Muslim (3% and 2%) and other (2%).^[9]
• Award rates were quite consistent across religious groups, with a slightly lower award rate among Christian Community Care Grant applicants during 2024-25 and Muslim applicants over a 5 year period.^[10]

1.5 Extent/Level of EQIA required

Does your policy/strategy/plan/project impact people?

Yes

Stage 2: Data and evidence gathering, involvement and consultation

Include the results of your evidence gathering, including qualitative and quantitative data and the source of that information, whether national statistics, internal surveys, workforce data or consultation with Unions or engagement with diversity networks or external equality organisations.

Equality Group: Age

Evidence gathered and strength/quality of evidence:

• The data coverage for this protected characteristic is nearly 100% across all 32 local authorities.^[11]
• In the majority of local authorities, most applicants to the SWF are in the 30-39 age group (29% for Community Care Grants and 34% for Crisis Grants).^[12] This has been consistent since 2013.
• The average Community Care Grant award amount decreases by age. The average Crisis Grant award value peaks in the 30-39 group then decreases gradually in the older groups.^[13]
• In the last 5 years, there has been a decline in SWF applications from people under 30. This has been mirrored by an increase in applications from those over 40.^[14]
• Those aged 60 or over apply for more Community Care Grants than they do Crisis Grants.^[15]
• The number of SWF applicants declines steeply by age until the mid-sixties, at which rates flatten.^[16]
• There is a correlation between age and rate of award. In general, the older an applicant, the more likely they are to succeed with their application (both Community Care Grants and Crisis Grants).^[17]
• For declared ethnicities, mixed heritage applicants showed the largest proportion of younger applicants, with 75% being under 40. This group also have the largest proportion of applicants under 25 at 24%.^[18]

Data gaps identified and action taken: N/A

Equality Group: Disability

Evidence gathered and strength/quality of evidence:

• There appears to be mixed use of the ‘no disability’ and ‘refused’ categories on application forms.
• In 2023-24, the number of applicants reporting a ‘physical or mental health condition or illness lasting or expected to last 12 months’ or more varied by local authority, sitting at fewer than 10% of applicants in two local authorities to 75% in another.^[19]
• In the same year, some local authorities were over 50% in this area, with the Scotland average sitting at 33%.^[20]
• Across both Community Care Grants and Crisis Grants in 2024-25, around half of applications came from households where someone had a disability. This has been consistent over time.^[21]
• Where a disability was reported, these applications have received slightly higher award rates than those without disabilities, but smaller awards.^[22]
• There has been a slight increase in people who report a disability since the fund began in 2013.^[23]
• 2023-24 data showed that disability appears to be less significant with relation to award rates than other protected characteristics. 63% of those who declared a disability received awards, compared to 63% who declared no disability and 67% of those who refused to provide this information.^[24]

Data gaps identified and action taken: The data coverage for this protected characteristic for SWF applicants is low from all 32 local authorities. Further work is required to explain the wide range of disability reporting among local authorities as some report a high level, while others are quite low^[25].

Equality Group: Sex

Evidence gathered and strength/quality of evidence:

• More than half of SWF applications were female in 2024-25. This has been consistent over time.^[26]
• 57% of Community Care Grant applicants and 51% of Crisis Grant applicants were female during 2024-25.^[27]
• The age profile of applicants in 2024-25 varied by gender. For both Community Care Grants and Crisis Grants, female applicants were more likely to be under 40 than male applicants.^[28]
• Very little data is currently available on people who identify as non-binary, although this is an option for people to select on application forms.
• There is little difference between males and females when it comes to award rates in the last year and across the past 5 years.^[29]
• However, average award differs by gender. The average Community Care Grant award was higher in 2024-25 where the main applicant was male than when the main applicant was female (£818 and £751).^[30]
• 1 in 3 working-age women without children were in poverty in 2024.^[31]
• Engender and Shelter published a joint report in October 2024. Within this, there were asks of the Scottish Government to create targeted streams of the fund to support marginalised women, including migrant women, women with no recourse to public funds and unpaid carers.^[32]
• Scottish Government officials have called on the UK Home Office to remove the SWF from the list of public funds for immigration purposes which would benefit women with no recourse to public funds.
• Updating the statutory guidance to ensure that it is clearer, easier to understand and more accessible could help further support marginalised women, such as those with no recourse to public funds or caring responsibilities.
• To ensure the lived experience of people living in poverty, we have engaged with the Poverty Alliance ‘Get Heard Scotland’ Citizen Panel. During phase one of this work, the panel was made up of 6 women, 4 men and one person who identified as non-binary. Phase two has focused on discussions between those with lived experience of poverty and practitioners from local authorities that deliver the fund, with a focus on areas such as communication and trust and improved signposting of longer term preventative support.
• Scottish Government statistics between 2021 – 2024 show that 19% of women and 19% of men were in relative poverty after housing costs.^[33]
• In 2021-2024, 23% of single female pensioners and 18% of single male pensioners were in relative poverty after housing costs.^[34]

Data gaps identified and action taken: There are some data gaps for this protected characteristic. There is limited SWF data available on people who identify as non-binary. The Scottish Government rely on local authorities to provide us with this data. There is further work being undertaken to improve data and strengthen reporting. External data has been sought to offer further context.

Equality Group: Pregnancy and maternity

Evidence gathered and strength/quality of evidence:

• Relative poverty rates have been historically higher for single mothers but have gradually declined to be comparable with other single household types.^[35]
• The poverty rate for single childless women and single mothers was 28% and 30% respectively.^[36]
• Households with children where the mother is under 25 are at a high risk of poverty.^[37]
• Pregnant young women and young mothers (under 21) make up about 1 in 25 of all applications for homeless assessments in Scotland.^[38]

Data gaps identified and action taken: N/A

Equality Group: Gender reassignment

Evidence gathered and strength/quality of evidence:

• A report published in July 2024 by Scottish Trans detailing trans and non-binary experiences highlighted that 44% of respondents felt the rising cost of food and fuel had impacted them a lot. A large majority of respondents (42%) felt this had affected them a little in the last 12 months.^[39]
• 11% of people had used a food bank or similar service in the last 12 months.^[40]
• A minority of respondents felt that their trans status or gender identity had a negative impact on their ability to claim benefits (13%).^[41]
• A third of people surveyed by Scottish Trans were currently claiming benefits.^[42]
• In Scotland’s 2022 Census, 19,973 people reported a trans status or history (0.44% of people over 16).^[43]

Data gaps identified and action taken: There are some data gaps for this protected characteristic. As such, external data has been sought. We will continue to consider impacts ahead of implementation

Equality Group: Sexual orientation

Evidence gathered and strength/quality of evidence:

• The poverty rate has been consistently higher for LGB+ adults compared to straight/heterosexual adults. Statistics from 2021-24 show that 28% of LGB+ adults were in poverty compared to 19% of straight adults.^[44]
• LGB+ people are more likely to live in the most deprived quintile.^[45]

Data gaps identified and action taken: There are some data gaps for this protected characteristic. As such, external data has been sought. We will continue to consider impacts ahead of implementation.

Equality Group: Race

Evidence gathered and strength/quality of evidence:

• While minority ethnic families make up just 1 in 10 children in Scotland between 2021 and 2024, they have the highest risk of child poverty among priority family groups, with nearly half (47%) living in poverty.^[46]
• Just 46% of applicants to the SWF across 29 local authorities have provided information about their ethnicity.^[47]
• White ethnicities made up 90% of Crisis Grant applications and 89% of Community Care Grant applications in 2024-25, which is similar to the average for the lifetime of the fund since it began in 2013.^[48]
• The second largest ethnic group was ‘other’, making up 8% for both grants. This was followed by Black, Caribbean or African (1%) and Asian (1%). The average award values for both Community Care Grants and Crisis Grants were higher for all ethnic minority compared to the White ethnic group.^[49]
• The Independent review into the SWF highlighted that there were some gaps in data received by the Scottish Government from local authorities, including on ethnicity.^[50]
• The 2023-24 SWF equalities summary showed there is a higher award rate among applicants who refuse to offer information on their ethnicity (67%) versus those from a white ethnic background (63%).^[51]
• Mixed heritage applicants showed the largest proportion of younger applicants, with 77% under 45. This group also have the largest proportion of under-25 applicants at 25% in 2023-24.^[52]
• 2023-24 data also showed applicants of Chinese ethnicity have the largest proportion of over-55 applications at 10%, no other groups have over 5%.^[53]
• According to Citizens Advice, 1.4 million people in the UK have No Recourse to Public Funds (NRPF), with the burden of restrictions falling on Black or Asian people, or people from other minority ethnic groups (82%).^[54]
• People with NRPF are not entitled to SWF grants. Scottish Government officials have engaged with the Home Office and Scottish Ministers have called for the removal of the SWF from the list of public funds for immigration purposes.
• People from non-white minority ethnic groups were more likely to be in relative poverty after housing costs compared to those from ‘white – British’ and ‘white-other’ groups.^[55]
• Over the five year period of 2019 – 2024, the poverty rate in Scotland for Asian or Asian British ethnic groups was 43% and 50% for Mixed, Black or Black British and other ethnic groups. The poverty rate for the White – Other group was 20% and for White – British, 18%.^[56]

Data gaps identified and action taken: N/A

Equality Group: Religion or Belief

Evidence gathered and strength/quality of evidence:

• The 2024-25 SWF equalities summary shows that there were issues with the collection of data on religion. Collection processes vary greatly among local authorities as some used ‘none’ and ‘refused’ interchangeably.^[57]
• Prior to analysis, all data from local authorities which had recorded less than 5% or more than 95% of applicants as either ‘Refused’ or ‘None’ for religion (ten local authorities and 448,414 applications excluded) was excluded.^[58]
• Of the available dataset of 1,284,530 applications from 22 local authorities (448,414 applications were not counted in this figure as it was assumed these had conflated ‘none’ and ‘refused’), 59% of these were ‘refused’ and not counted in subsequent religion question analysis, the most common response to the religion question for Community Care Grants and Crisis grants was ‘none’ at 69% and 73%.^[59]
• The most common religion mentioned was Christian (26% and 23%) then Muslim (3% and 2%) and other (2%).^[60]
• Of 307,000 people who have declared a religion in 2023-24, 90% are Christian, 3% Muslim, 1% Pagan, 1% Buddhist and 4% other religions. These all make up fewer than 1% of applications since the fund began.^[61]

Data gaps identified and action taken: N/A

Equality Group: Marriage and civil partnership

The Scottish Government does not require assessment against this protected characteristic unless the policy or practice relates to work, for example Human Resources policies and practices - refer to Definitions of Protected Characteristics document for details.

Evidence gathered and strength/quality of evidence:

• In 2021-24, the relative poverty rate after housing costs was highest for divorced or separated adults (28%) and single adults (29%). Married (14%) and cohabiting adults (15%) were the least likely to be in poverty.^[62]

Data gaps identified and action taken: N/A

Equality Group: Socio Economic Background

In the Fairer Scotland Duty we must actively pay due regard to how we can reduce inequalities of outcome caused by socio-economic disadvantage, when making strategic decisions.

Evidence gathered and strength/quality of evidence:

• The distribution methodology for the SWF is based on the income domain of SIMD (i.e. the numbers of people receiving low income benefits) and has been agreed in conjunction with CoSLA and the allocation is set out in the Scottish Local Government Finance ‘Green Book’.^[63]
• This allows the funding to be weighted more favourably to areas with the highest proportion of low income households where people in those communities may be less able to meet an unexpected financial crisis should it arise.
• The annual statistics for 2024-25 show that awards tend to go to applicants living in the most deprived areas of Scotland.^[64]
• Around 1 in 5 people in Scotland live in the 20% most deprived areas in Scotland, defined by the Scottish Index of Multiple Deprivation (SIMD). In 2024-25, around half of Community Acre Grants (50%) and Crisis Grants (48%) were awarded to people living in these areas.^[65]
• A Fairer Scotland Duty assessment has also been carried out on the proposed changes.

Data gaps identified and action taken: N/A