Scotland's Climate Change Plan – 2026-2040 - EQIA

2. Approach to assessment of impacts

2.1 Introduction

The Scottish Government has a legal duty when creating new plans and policies to pay due regard to the PSED. This assessment identifies potential impacts of the Climate Change Plan on people who share protected characteristics and assesses the extent to which the Scottish Government has paid due regard to the PSED. The analysis of available datasets has enabled the identification of potential impacts of policies and proposals set out in the Climate Change Plan under each of the different sectors:

• Business and Industrial Process,
• Energy Supply,
• Residential and Public (in relation to buildings in those sectors) (referred to within this impact assessment as ‘Heat in Buildings’),
• Agriculture,
• Land Use, Land Use Change and Forestry (separated within this impact assessment as ‘Peatland’ and ‘Forestry’),
• Transport (including international aviation and shipping), and
• Waste Management.

2.2 Approach

The approach to undertaking the assessment documented in this report has involved a three-stage process:

• Key Issues and evidence review – an evidence base was collated which reflected publicly available data and Scottish Government reports, information provided by Scottish Government officers and research into relevant policy, legislation, proposal documents and discussion papers,
• Assessment of potential impacts – informed by a consideration of the evidence assembled under 1, and
• Conclusions – a synthesis of key findings of the potential equality impacts of the Climate Change Plan with reference to the PSED.

2.3 Key issues and evidence

The Scottish Government conducted an initial review of the policies and proposals included within the Climate Change Plan. The subsequent evidence review included a set of sectoral scoping documents completed by Scottish Government policy leads, provided on the available evidence and impacts identified to date relating to the policies and proposals within the Climate Change Plan. The evidence was reviewed based on each climate change outcome contained within the plan and the policies and proposals which relate to each outcome.

The evidence reviews also included a review of relevant documentation related to the Climate Change Plan, including strategies and statements detailing respective key targets for each sector.

2.3.1 Consultation, scrutiny and engagement

The draft plan was laid in Parliament on 6 November 2025. This began a statutory scrutiny period of 120 days through which the Scottish Government sought the views of parliament on the overall trajectory of decarbonisation, the package of policies and proposals being put forward, and the wider impacts of both of these.

The Scottish Government also conducted a 12 week public consultation and engaged with key stakeholders throughout the scrutiny period to seek wider views on the draft Plan and its associated documents. This generated over 500 responses from organisations and individuals, capturing views from a broad cross section of stakeholder organisations and members of the public. This activity was supplemented by 112 engagement events delivered by the Scottish Government’s partners, reaching more than 1,800 participants. Several of these events focused on targeted groups to ensure inclusion of perspectives from communities of interest with specific needs or backgrounds. The key themes and outputs of each of these strands of scrutiny have been considered in this impact assessment.

Throughout the scrutiny period the Scottish Government also engaged with a number of organisations with a particular interest in ensuring equality is a central in the overall Climate Change Plan. The Scottish Government engaged with these groups to gain feedback on what the Plan means to their members and the people that they represent, and to seek suggestions on how people with protected characteristics can be considered in the final Plan, including groups such as:

• Poverty Alliance,
• Business in the Community,
• Scotland’s Enterprise Agencies,
• Prosper,
• Nesta (formerly National Endowment for Science, Technology and the Arts);
• Local authorities,
• Just Transition Commission,
• Just Transition Partnership, and
• COSLA.

2.4 Assessment of potential impacts

The assessment of equality impacts takes into account the information gathered through the above activities. A judgement is made as to how the proposals pay due regard to the duty to advance equality, eliminate discrimination and promote good relations as further defined in the Equality Act 2010.

Informed by a consideration of key issues and evidence and feedback from Scottish Government officers, this section considers how the Climate Change Plan policy package might impact certain groups in either a positive, negative or neutral manner.

2.4.1 Potential Positive Impacts

As per the PSED, consideration on whether where certain policies or proposals in the Climate Change Plan might create positive impacts has taken place and/or whether each policy might present opportunities for:

• Eliminating discrimination, for example, by incorporating measures to mitigate or minimise the risk of less favourable treatment or indirect discrimination,
• Advancing equality of opportunity, for example, by removing or minimising disadvantages suffered by people who share a relevant protected characteristic, meeting the needs of different groups or by encouraging increased participation of particular groups, and/or
• Fostering good relations between persons who share a relevant protected characteristic and persons who do not share it, in particular by tackling prejudice and promoting understanding.

2.4.2 Potential Negative Impacts

The assessment considers whether certain protected groups might experience both disproportionate and differential impacts as the results from policies and proposals in the Climate Change Plan policy package.

A disproportionate impact experienced by protected groups could be, for example, an instance in which a policy could impact on a resource which is predominantly used by certain groups. To further illustrate, converting homes to a low or zero carbon heating system could involve upfront costs for households. Certain protected groups are more likely to live within lower income households, such as disabled people and lone parents, who are predominantly female. The costs of conversion could create a disproportionate impact for these protected groups, for example.

A differential impact is one which affects individuals from a particular group differently from the rest of the general population because of specific needs, or a recognised vulnerability associated with their protected characteristic. For instance, banning priority single use items could adversely impact older people, disabled people and carers (who are predominantly female) as these groups may have specific needs, and/or may depend on how they use single use items to meet an essential daily need, and alternatives such as biodegradable products can be more expensive and less secure for their individual circumstances.

2.4.3 Potential Neutral Impacts

These have no direct or indirect positive or negative effects on protected characteristics.

2.5 Conclusions

The final section of this report sets out conclusions on the equality impacts of the Climate Change Plan policies and proposals.