Pension Age Winter Heating Payment (PAWHP): equality impact assessment

Executive Summary

1. This EQIA has considered the potential impact of the introduction of universal eligibility to PAWHP, which replaced the Department for Work and Pensions Winter Fuel Payment (WFP) in winter 2024/2025, and how the policy might impact people with protected characteristics as defined in section 4 of the Equality Act 2010.^[3]

2. The findings here are based on desk research, feedback from people with lived experience of the current social security system,^[4] and the PAWHP Consultation Analysis, which was based on our intended universal PAWHP prior to the UK Government cuts to Winter Fuel Payment in July 2024.^[5]

3. Given the UK Government’s late change in policy in July 2024, and the lack of prior consultation with the Scottish Government, to ensure that there was no gap in provision for eligible individuals and that payments were made to pensioners in Scotland in winter 2024/2025, it was not possible to conduct a further public consultation on the restriction of PAWHP eligibility. Similarly, given the limited timescales available to lay regulations to ensure that universal payments are paid to every pensioner household in winter 2025/26, it has not been possible to consult further on the proposed introduction of universal eligibility prior to laying these amendment regulations.

4. The rationale for providing PAWHP to this group is to provide all older people 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.^[6] Older people are also more likely to live in ‘colder’ and ‘harder to heat homes’^[7], and spend more time at home according to a recent survey carried out by Age UK.^[8]

5. 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.

6. 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, with enhanced support for those on low incomes 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 all pensioner households, including those on low incomes, are living in a warm home.
• Health: We are healthy and active. The policy will provide reassurance to older people 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 all people of pension age 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 (around one million older people living in Scotland every year).