Pension Age Winter Heating Payment: Equality Impact Assessment

Executive Summary

1. This EQIA has considered the potential impact of extending the current means-tested eligibility for PAWHP. Currently, PAWHP is only paid to those of state pension age and in receipt of relevant benefits. However, following the UK Government’s decision to change its approach in June 2025 to winter fuel payments, the Scottish Government have decided to mirror the revised approach by the UK Government.

2. From this winter, those over State Pension Age (SPA) with an income of £35,000 or less will receive PAWHP. PAWHP replaced the Department for Work and Pensions (DWP) Winter Fuel Payment (WFP) in winter 2024/2025, and this assessment looks at how the policy change might impact people with protected characteristics as defined in section 4 of the Equality Act 2010.^[2]

3. The findings here are based on desk research, feedback from people with lived experience of the current social security system,^[3] and the PAWHP Consultation Analysis, which was based on our intended universal PAWHP prior to the UK Government cuts to Winter Fuel Payment announced in July 2024.^[4]

4. Given the UK Government’s late changes to its policies in July 2024 (WFP restricted to pensioners on certain benefits) and then again in June 2025 (everyone of state pension age receiving WFP, with payments being recovered through taxation from those with an income of over £35,000 per year) and the lack of prior consultation with the Scottish Government, it was not possible to conduct a further public consultation. 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.

5. The rationale for providing PAWHP to this group is to provide older people most in need with additional money to help towards meeting increased heating costs during the winter. Having additional financial support can encourage them to heat their homes for longer whilst also helping to tackle fuel poverty. In addition, cold temperatures can be particularly dangerous for those with pre-existing health conditions, and older people are likely to have a higher need to keep their home warm due to being older and less likely than younger people to regulate their temperature.^[5] Older people are also more likely to live in ‘colder’ and ‘harder to heat homes’^[6], and spend more time at home according to a survey carried out by Age UK.^[7] A recent inquiry into pensioner poverty by the House of Commons Work and Pensions Committee also highlighted the health impact of fuel poverty on older people, noting older people reluctant to go into debt taking pre-emptive action which may include considerable rationing of their energy use. Further the inquiry highlighted the link between cold and respiratory and heart disease and as a factor that can worsen conditions such as arthritis.^[8]

6. The policy aligns closely with the Scottish Government’s Wealthier and Fairer Strategic Objectives, but also links with the Scottish Government’s strategic priorities to support older people amid the cost-of-living crisis.

7. The policy contributes to the following National Outcomes:

• Economy: We have a globally competitive, entrepreneurial, inclusive and sustainable economy. This policy will provide continued investment in financial support for older people most in need of support with energy costs in Scotland.
• Communities: We live in communities that are inclusive, empowered, resilient and safe. This additional support recognises older people have particular needs in relation to heating and will help towards ensuring pensioner households on lower income, are living in a warm home.
• Health: We are healthy and active. The policy will provide reassurance to older people on a lower income that they will receive a contribution towards their heating costs, helping to maintain a safe temperature at home during the winter, reducing the health risks due to living in cold environments.
• Human Rights: We respect, protect and fulfil human rights and live free from discrimination. Social Security is a human right and through expansion of this benefit we help progress the support that is available.
• Poverty: We tackle poverty by sharing opportunities, wealth and power more equally. The policy intention of PAWHP is to provide financial support to people of pension age on lower income in Scotland, because they have a greater need for heat during the winter months. PAWHP in particular specifically targets pensioner households who, due to their age, may require an enhanced heating regime, and therefore may incur greater energy costs.