Pension Age Winter Heating Payment: Business and Regulatory Impact Assessment

Consultation

27. Prior to the UK Government decision to restrict eligibility of WFP, we consulted on our policy proposals for PAWHP as a universal payment. Our public consultation on PAWHP ran between 23 October 2023 and 15 January 2024. We consulted on our policy proposals for the introduction of a universal benefit. The purpose of the consultation and associated stakeholder engagement was to gather views on the proposed delivery, eligibility criteria, the proposed payment format, to collect additional evidence for those who will receive PAWHP in rural and off-gas grid communities, and to identify any unintended consequences of introducing the new payment including the impact of expanding eligibility to this benefit on businesses and key stakeholders.

28. Given the UK Government’s late change in policy and the lack of prior consultation with the Scottish Government, to ensure payments were made to pensioners in Scotland in winter 2024/2025, it was not possible to consult further on the proposed eligibility changes to PAWHP prior to laying regulations for a restricted PAWHP. The UK Government decision to extend eligibility for WFP to pensioners earning £35,000 or less in June 2025 was also announced with no prior engagement with the Scottish Government, and Ministers and Officials within Scottish Government worked to understand the implications of the UK Government decision.

29. Similarly, given the limited timescales available to lay regulations to ensure that payments are paid to every pensioner household in winter 2025/26 that meets eligibility, it has not been possible to consult further on the proposed changes prior to laying these amendment regulations following the Scottish Governments announcement on 18 June 2025 mirroring the UK Governments approach.

30. Although we know from our previous consultation^[10] that there was broad support for maintaining a universal approach to eligibility for all who have reached state pension age, there were also some stakeholders who disagreed and called for the benefit to be targeted more effectively at those in fuel poverty. Some also advocated for a form of means testing of PAWHP, as it was argued that not all older people need this financial support, with a suggestion that alternative or additional income-based eligibility criteria could be used to identify and target the payment.

31. During our public consultation on PAWHP, some individuals commented on the potential impact on energy companies. Some people recognised energy companies could benefit as a result of PAWHP as people are likely to be able to pay their bills on time, stating that otherwise these businesses may lose out due to non-payment.