Ref.: OL GBR 12/2025

Mandates of the Special Rapporteur on the rights of persons with disabilities and the Special

Rapporteur on extreme poverty and human rights

Ref.: OL GBR 12/2025

(Please use this reference in your reply)

4 September 2025

Excellency,

We have the honour to address you in our capacities as Special Rapporteur on

the rights of persons with disabilities and Special Rapporteur on extreme poverty and

human rights, pursuant to Human Rights Council resolutions 53/14 and 53/10.

In this connection, we would express the following concerns over the reform

process related to health and disability benefits, including the “Pathways to Work:

Reforming Benefits and Support to Get Britain Working” Green Paper and the

Universal Credit Bill. We fear that this process may have put fiscal considerations

before the duties of the United Kingdom of Great Britain and Northern Ireland under

the international human rights instruments it has ratified, with a disproportionate impact

on the rights of persons with disabilities, particularly the right to an adequate standard

of living and social security and the right to be closely consulted and involved in

policymaking on issues that concern them. We are deeply concerned at the freezing and

cuts to health and disability benefits that have been proposed before the content and

mitigating impacts of other proposed measures are known, thus signalling further

retrogression in the availability and accessibility of social security for those at

heightened risk of poverty.

Background

At the outset, we wish to acknowledge that one of the stated objectives of the

reforms was to provide bettersupport for persons with disabilities and people with long-

term health conditions to access and maintain employment. We recognize that, as

everywhere in the world, persons with disabilities are at higher risk of poverty including

due to a lack of equal employment opportunities. However, we are concerned that

instead of pursuing a rights-based approach to the right to work and to an adequate

standard of living, fiscal considerations and negative perceptions of benefit claimants

appear to be the driving rationale behind reforms. We recall that your Excellency’s

government is bound by international human rights standards under the Convention on

the rights of persons with disabilities (CRPD) and the International Covenant on

Economic, Social and Cultural Rights (ICESCR), ratified by the United Kingdom on

8 June 2009 and 20 May 1976 respectively.

We are alarmed that these reforms are proceeding in the context of significant

gaps in the protection of the human rights of persons with disabilities, as documented

in the 2017 inquiry conducted by the Committee on the rights of persons of persons with

disabilities (CRPD/C/15/4). The Committee notably observed failures to guarantee the

rights of persons with disabilities to live independently and be included in the

community; to work and employment; and to an adequate standard of living and social

protection. In the 2024 follow-up to the inquiry, the Committee found that no significant

progress has been made and reiterated its earlier recommendations

PALAIS DES NATIONS • 1211 GENEVA 10, SWITZERLAND

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(CRPD/C/GBR/RFIR/1). Similarly, in March 2025, the Committee on Economic,

Social and Cultural Rights warned that reforms over the past decade, including benefit

cuts, have eroded the rights to social security and to an adequate standard of living with

a disproportionate effect on persons with disabilities and stigmatization of benefit

claimants (E/C.12/GBR/CO7).

We note that barriers in accessing disability benefits in the United Kingdom

have been extensively documented, including difficulties to access information about

their eligibility and entitlements, the high level of complexity of application forms,

limited access to guidance and support to navigate the procedures, unprofessional and

demeaning communication from assessors occasionally questioning the validity of

mental health needs, compounded by long waiting list for related health services.

Moreover, the inadequacy of existing social security schemes to meet the needs of

persons with disabilities and ensure an adequate standard of living has been widely

reported, putting persons with disabilities and their families at disproportionate risks of

poverty, debt, food insecurity, and mental health issues.

Regressive proposals to cut, freeze and restrict eligibility to health and

disability benefits

In March 2025, the government published a Green Paper entitled “Pathways to

Work: Reforming Benefits and Support to Get Britain Working,” announcing changes

to health and disability benefits to decrease government spending by £4.8 billion by

2029/2030. The government asserted that the existing incapacity and disability benefits

system disincentivizes employment and that, moreover, the number of claimants of

disability and health benefits rose significantly since the COVID-19 pandemic creating

unsustainable financial expenditures. The increase in mental health conditions was

highlighted as driving the increase in claiming health and disability benefits.

We are concerned that the rationale for significant changes to health and

disability benefits seems to be largely based on financial expenditures linked to

increased numbers of benefit claimants without a comprehensive analysis and response

to the causes behind the increased prevalence of disability and long-term health

conditions, as well as the challenges persons with disabilities experience to access the

labour market, the adequacy and accessibility of social security schemes, quality

community-based support services, and health services. Such an approach seems to

contradict the spirit of the CRPD which recognizes persons with disabilities as rights-

holdersrather than mere recipients ofsocialsupport. We recall that the United Kingdom

is bound to adopt all appropriate measures to implement the whole range of rights set

out in the CRPD (art. 4(1)(b)), requiring a comprehensive and coordinated policy

approach.

We note that the Green Paper outlined 22 policy measures, including changes

to two social security benefits: the health element of the Universal Credit and the

Personal Independence Payment.

Universal Credit (UC) is a non-contributory means-tested income replacement

benefit to help cover costs of living. It comprises a standard allowance and other

benefits, such as the UC health element for individuals with a health condition or

disability and who have been assessed as having limited capability for work and work

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related activity (based on the “Work Capability Assessment”). The announced changes

included freezing the amount of the benefit and cutting it nearly by half for new

claimants from £97 a week to £50 a week. The government outlined that the freeze and

cuts to the UC health element would be partially offset by increasing the UC standard

allowance, for example with an increase of £7 per week for single persons above

25 years old.

The Personal Independence Payment (PIP) is a non-contributory non-means

tested benefit to help cover extra-costs related to disability and long-term health

conditions. PIP is available in England, Wales, and Northern Ireland. It contains two

components; the daily living component supports people with everyday tasks, while the

mobility component helps people to go out and move around. The Green Paper outlined

plans to curb spending on PIP by tightening eligibility and requiring higher scores in

the functional PIP assessment. The changes would have meant that people who needed

assistance to wash, dress and undress their lower body, to get in and out of bath or

shower, and needed supervision to use the toilet might have no longer been eligible.

The changes to the UC health element and PIP were central elements of the

Universal Credit and Personal Independence Payment Bill introduced by the

government to the Parliament on 18 June 2025. Following opposition from a group of

parliamentarians, the government revised the Bill to ensure majority support. In

particular, the PIP-related changes and freezing of the UC health element were

withdrawn. The Bill was renamed the “Universal Credit Bill,” with the halved rate of

the UC health element for new claimants remaining its core provision. The full rate

would continue applying to current beneficiaries, those terminally ill, and those with

“severe conditions” defined as conditions that are permanent and do not fluctuate. The

revised bill was approved by the House of Commons on 9 July and the House of Lords

on 22 July. It is due for Royal Assent in early September to become Law.

We welcome that some of the most problematic elements of the Bill were

withdrawn, particularly in relation to PIP. Nevertheless, we remain concerned that the

Bill contains a regressive clause for accessing a benefit for those in particularly

vulnerable situations. On its face, the new two-tier system for the UC health element

whereby new claimants will receive a significantly lower amount of the same benefit

solely because of the date of their application appears discriminatory and unjustified. It

is incompatible with the principle of non-discrimination under art. 5 of the CRPD.

Further, we are concerned that such retrogressive measures are being put

forward and adopted without careful consideration of all alternatives and other

requirements under the criteria adopted by the Committee on Economic, Social and

Cultural Rights in its general comment No. 3. We recall that both the CRPD (art. 4(2))

and ICESCR (art. 2(1)) require States to take measures, to the maximum of their

available resources, in order to progressively achieve the full realization of economic,

social and cultural rights. This duty entails a strong presumption against retrogression

in the protection in economic, social and cultural rights.

Finally, the introduction of the “severe conditions” category for claimants of the 

UC health element is problematic as the narrow criteria exclude many persons with

disabilities and are not aligned with the concept of disability under the CRPD, which

relates to those with long-term physical, mental, intellectual or sensory impairments4

that can evolve and fluctuate over time (art. 1). This is particularly problematic for

people with psychosocial disabilities and mental health conditions. We are concerned

that the definition of “severe conditions” disregards functional capacities and individual

support needs that different people require, and as such penalizes people who are at

particular risk of poverty while experiencing significant barriers to employment.

Stigmatising language targeting benefits claimants, including persons with

disabilities

We are dismayed that throughout the reform process, senior governmental

officials and politicians used language that stigmatizes benefits claimants and suggests

that claimants are abusing and cheating the system, especially considering that official

statistics show near nonexistent overpayments for PIP and UC extra elements due to

fraud. We are gravely concerned that such language normalizes and encourages a

hostile and stigmatizing environment for persons with disabilities, in which they are

considered “fakers” and a drain on society. This is particularly troubling as the reforms

and reviews of existing support schemes are expected to continue. The targeting of

persons with psychosocial disabilities and mental health conditions is especially

alarming given that the rhetoric around “overdiagnosis” of mental health conditions

enables negative and erroneous perceptions of people pretending or exaggerating

mental health problems to avoid work, particularly young people. We underscore that

under art. 8 CRPD, the government is required to actively combat stigma and negative

stereotypes relating to persons with disabilities.

Lack of meaningful consultations and limited parliamentary scrutiny

The Green Paper indicated that the government would carry out public

consultations on only 10 out of the 22 proposed policy measures. It appears that no

consultations were carried out on some of the key changes, such as those related to

freezing the UC health element and tightening eligibility for PIP, where the government

announced it would legislate directly. Furthermore, consultations held on the remaining

proposals were limited, with inadequate accommodations and opportunities to

meaningfully consult persons with disabilities.

We recall that close consultation and active involvement of persons with

disabilities, through their representative organizations, in the development and

implementation of legislation and policies concerning issues that directly impact on

their lives is a mandatory requirement under art. 4(3) CRPD. Lack of any consultations

on law and policy changes to social security benefits that are essential to protect the

right to an adequate standard of living of persons with disabilities are a glaring violation

of this right. We particularly wish to draw attention to general comment No. 7 of the

Committee on the rights of persons with disabilities which provides clear guidance on

how to ensure participation of persons with disabilities in line with the CRPD

requirements.

The lack of meaningful consultations is even more alarming given the unusually

swift parliamentary proceedings of the Universal Credit Bill. The House of Commons

adopted the Bill after three readings compressed into three weeks, without the

possibility for parliamentary committees to organise consultations with experts and

interest groups, including persons with disabilities. Moreover, the government 5

designated the Bill as a “Money Bill” (i.e. laws only concerned with national taxation,

public money or loans). As such, the upper house of Parliament, the House of Lords,

could not amend or delay the Bill which will become law after one month with or

without approval of the House of Lords.

Impact assessments of planned reforms, including compliance with

international human rights obligations

Earlier this year, the government published an impact assessment of some of the

measures outlined in the Green Paper. It estimated that by 2029/2030, 370,000 current

PIP beneficiaries would lose their entitlements upon review and 430,000 future PIP

recipients would not qualify under the stricter criteria. Some 2.25 million of current

recipients would be impacted by the freeze of the UC health element and 730,000 future

recipients by its reduction. Overall, in 2029/2030, 3.2 million families (both current and

future recipients of health and disability benefits) were estimated to lose out financially

(on average £1,720 per year), while 3.8 million families would gain (£420 per year on

average). The vast majority (98%) of families on the losing end have a person with

disabilities in their household. Additional 250,000 people, including 50,000 children,

would be exposed to relative poverty.

We express strong concern that the government proposed measures which by its

own assessment would lead to increased poverty levels, especially impacting those

already at disproportionate risk of poverty such as persons with disabilities and their

families. We note that the impact assessment did not include analysis about mitigation

measures or the impact other planned measures, including the £1 billion annual funding

by 2029/2030 to support persons with disabilities and long-term health conditions into

employment. Interconnected issues, such as effects on access to food and housing were

also not considered. This raises questions about how the government is fulfilling its

obligations to guarantee the right to an adequate standard of living and social security

under ICESCR art. 9 and CRPD art. 28, including the prohibition of retrogressive

measures.

Moreover, no formal assessment of compatibility of the planned reforms and of

the Universal Credit and Personal Independence Payment Bill with human rights

obligations under ICESCR and CRPD had been conducted.

Future reforms related to the Green Paper

Further reforms to implement the Green Paper measures are expected to be

announced by the government in Autumn 2025. These may reportedly include

scrapping the “Work Capability Assessment” and replacing it by the PIP assessment;

extending conditionality (with the threat of sanctions for not following instructions

issued by advisors) to retain UC benefits to all recipients with limited capability for

work and work related capacity except the narrow category of “severe conditions

criteria;” investments up of up to £1 billion by 2029-2030 for additional employment,

health and skills support to help people start or stay at work; a new contributory

unemployment insurance; delaying access to the UC health element until the age of 22

instead of 18 with savings to be re-invested into work support and training opportunities

for this age group; and reforming the Access to Work grant scheme which supports

persons with disabilities with accessibility, personalised support and workplace 6

adjustments, including by more directly supporting employers to fulfil obligations

related to accommodations at work.

The government is also planning to conduct a review of the PIP system,

including the way assessments are conducted, and indicated it will consult persons with

disabilities. The outcomes of the review and expected changes to the system will be

published in Autumn 2026.

In light of these observations, we strongly urge your Excellency’s Government

to withdraw the Universal Credit Bill and pause planned measures in the Green Paper

until a comprehensive assessment of the adequacy and accessibility of social security

schemes for persons with disabilities and people with long-term health conditions is

conducted, in close consultations with persons with disabilities and all other concerned

groups.

As it is our responsibility, under the mandates provided to us by the Human

Rights Council, to seek to clarify all cases brought to our attention, we would be grateful

for your observations on the following matters:

1. Please provide any additional information and/or comment(s) you may

have on the above-mentioned analysis.

2. Please provide information on compliance of the Universal Credit Bill

and measures announced in the “Pathways to Work” Green Paper with

commitments under international human rights law, including the

International Covenant on Economic, Social and Cultural Rights and the

Convention on the Rights of Persons with Disabilities, and on any related

assessments conducted in this respect.

3. Please provide information on mechanisms and measures to ensure close

and meaningful consultations with persons with disabilities, including

their representative organizations, in the drafting and adoption of any

future law and policy reforms that impact on their lives, and particularly

on any future reforms associated with the Green Paper.

4. Please clarify what steps is your Excellency’s Government taking to

guarantee the right to an adequate standard of living and social security

to persons with disabilities and other groups at disproportionate risk of

poverty, without discrimination and retrogression.

5. Please provide information on measures to raise awareness and combat

stigma and negative attitudes towards benefit claimants and persons with

disabilities, particularly persons with psychosocial disabilities and

people requiring access to mental health care and support.

This communication, as a comment on pending or recently adopted legislation,

regulations or policies, and any response received from your Excellency’s Government

will be made public via the communications reporting website after 48 hours. They will

also subsequently be made available in the usual report to be presented to the Human

Rights Council.

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Please accept, Excellency, the assurances of our highest consideration.

Heba Hagrass

Special Rapporteur on the rights of persons with disabilities

Olivier De Schutter

Special Rapporteur on extreme poverty and human rights