Programme for Government 2026-31: Impact Assessments

Programme for Government 2026-31: Consumer Duty Compliance Statement

The Scottish Ministers have been designated as a relevant public authority for the purposes of the consumer duty by the Consumer Scotland Act 2020 (Relevant Public Authorities) Regulations 2024. This means that the Scottish Government must meet the following four requirements in sections 21-23 of the Consumer Scotland Act 2020:

• When making decisions of a strategic nature, have regard to the impact those decisions have on consumers in Scotland
• When making decisions of a strategic nature, have regard to the desirability of reducing harm to consumers in Scotland
• Publish information about the steps taken to meet the duty
• Have regard to any Consumer Scotland guidance about the duty

The consumer duty seeks to ensure that consumers are at the heart of all strategic decisions within the Scottish Government.

The Programme for Government (PfG) collectively constitutes a ‘strategic decision'. In meeting the duty, the Scottish Ministers have considered the overall potential impact of commitments and the cumulative expected impact of the PfG.

The Scottish Ministers have complied with the requirements of the 2020 Act in deciding on the PfG for 2026-2031. This statement sets out the steps taken to comply with the duty.

Stage 1 – Planning

1. Is this a decision of a strategic nature?

Yes

The Programme for Government 2026-2031 (PfG) is an outline of actions that the Scottish Government intends to take to meet the four priorities determined by the First Minister. These four priorities span across portfolios and therefore contain actions from a range of directorates within Scottish Government. The priorities and their aims are as follows:

• Eradicating Child Poverty – The aim of this priority is to outline actions which will contribute to increasing household income from employment, maximise the support people are entitled to, and bring down costs for families to keep children out of poverty.
• Growing the Economy – The aim of this priority is to outline actions which will Accelerate economic growth, improving job opportunities and supporting communities to thrive.
• Tackling the Climate Emergency – The aim of this priority is to outline actions which will ensure a credible pathway to net zero by 2045.
• Delivering a Stronger NHS and Public Services – Public service reform will be a key focus in this parliamentary term. The PfG sets out the first steps in delivering a simpler public sector landscape which is easier for service users to navigate.

As a key, high-level decision taken by the Scottish Ministers that sets out the Scottish Government’s proposed actions to deliver on their priorities over the coming Parliamentary term, the PfG is a decision of a strategic nature.

2. Is the strategic decision likely to have an impact on any/all consumers? Yes

Consideration has been given to whether the PfG is likely to have an impact on any or all consumers. As the PfG is a collation of proposed actions to deliver on the Scottish Ministers’ priorities, including as to the allocation of resources to public services, it will have an impact on the users of those public services. Users of public services are consumers for the purposes of the consumer duty.

Stage 2 – Evidence Gathering

3. What is the proposal trying to achieve?

As above, the PfG presents a suite of actions that, when taken collectively, are intended to address the four priorities of the Scottish Government.

Internal processes supported engagement across all DG families within the Scottish Government. Each area was provided with information on the consumer duty, and a commission was issued to gather evidence. The commission contained specific questions on the evidence gathered that informed the decision making around and content of a portfolio’s package of PfG commitments, and any specific instances of potential harm to consumers.

Particular emphasis was placed on the impact of strategic decisions on consumers in vulnerable circumstances, and the desirability of avoiding harm to these groups where appropriate.

The information received from this commission forms the basis of the analysis of impact set out below.

4. What are the impacts on consumers?

PfG comprises many proposed actions. The PfG will impact public engagement with public services; how consumer data is used; consumer protections in place; the availability of information available to consumers; and making it easier for consumers to seek advice or raise complaints. Commitments to streamline and join up public services, including for vulnerable families, may have implications for how consumers interact with those services and we will continue to assess how this will impact consumers as the policy is further developed. The following examples illustrate how consumers will be impacted and have been considered in the overall assessment of the potential impacts.

The PfG commits to reducing everyday costs and will introduce measures to address the cost-of-living crisis including delivering a £2 bus fare cap across the Strathclyde Partnership for Transport area. Reducing everyday costs, including public transport costs, is expected to have a positive impact on consumers.

Consumers include retail customers and small businesses, and evidence has demonstrated increasing levels of shoplifting and offences against retail workers across Scotland. The commitment to provide £10million over the next three years to tackle retail crime through Police Scotland’s Retail Crime Taskforce will support consumers through reducing criminality within consumer settings.

Health and Care commitments have been developed with a focus on improving outcomes for service users, patients, families and carers. Positive outcomes are expected to be experienced by consumers as a result of the PfG aim to deliver a stronger NHS and public services. Health and Care commitments to expand community and home-based services, reduce waiting times, and ensure digital channels are offered alongside telephone and face-to-face access are expected to have an overall positive impact on consumers.

Consumers of electric vehicle (EV) charging infrastructure will benefit from our commitment to engage with stakeholders to identify changes that could be made through our planning reform programme to make it easier to install public EV chargers.

The PfG also includes commitments focused on benefitting vulnerable consumers, for example, investing £205 million to continue delivering winter heating payments to pensioners, families with disabled children and other family households struggling the most.

5. Is it likely that harm will be experienced by consumers as a result of this proposal?

It is not considered likely that harm will be experienced by consumers because of the overall commitments contained within the PfG. In relation to our commitments in the Health portfolio, potential risks have been identified relating to digital exclusion, accessibility, communication barriers and service transitions. These risks are being mitigated through maintaining alternative access routes, including telephone and face-to-face services, inclusive design principles, accessibility testing and ongoing monitoring. This will ensure consumers maintain access to vital health services.

Stage 3 – Assessment and Improvement of Proposal

6. What is the expected impact of the strategic decision on consumers in Scotland?

Based on an analysis of the cumulative impact of all of the proposals comprising the PfG, it is expected that the impact of PfG will be positive for consumers.

7. Has Scottish Government had due regard to the desirability of reducing harm to consumers in Scotland?

As part of preparation of the PfG, the Scottish Government has had due regard to the desirability of reducing harm to consumers and considered whether the commitments included meet the criteria required in the guidance.

8. Is there a need for further engagement with consumers?

We do not anticipate further engagement to be required to assess the overall PfG package. However, further engagement with consumers will be undertaken by individual policy areas, where determined necessary and relevant.

Stage 4 – Decision

9. Has Scottish Government met the consumer duty for this decision?

The consumer duty has been met by the Scottish Government.

10. If yes to above, explain how?

In the process of carrying out this impact assessment, the cumulative package of commitments included in the PfG has been examined for potential impacts on consumers in Scotland. We have given regard to the impact of the PfG on consumers in Scotland, and to the desirability of reducing harm to them.

Stage 5 – Publication and Review

11. Section 23 of the 2020 Act requires public authorities to publish information about the steps which they have taken to meet the duty. The authority must publish the information no later than 12 months after the end of period to which it relates.

This statement will be published www.gov.scot on 2 October 2026

12. How will the process carried out be reviewed and evaluated?

The impact assessment carried out will be subject to review and evaluation within 12 months of publication using the template found at the Consumer Scotland website.