Research and analysis

Equality analysis for Winter Fuel Payments 2025

Published 22 August 2025

Abbreviation	Definition
AA	Attendance Allowance
CRPD	United Nations Convention on the Rights of Persons with Disabilities
DLA	Disability Living Allowance
DWP	Department for Work and Pensions
EA	Equality Analysis
FRS	Family Resources Survey
HMRC	HM Revenue and Customs
HMT	HM Treasury
IRB	Income-Related Benefit
PC	Pension Credit
PIP	Personal Independence Payment
PSED	Public Sector Equality Duty
WFP	Winter Fuel Payment

1. Introduction

1. This document records the analysis undertaken by the department to enable DWP to consider the needs of individuals in their day to day work – in shaping policies, making secondary legislation, delivering services, and in relation to their own employees to fulfil the requirements placed on them by the Public Sector Equality Duty (PSED) as set out in section 149 of the Equality Act 2010.

2. The PSED requires a public authority to have due regard to the need to:

• eliminate unlawful discrimination, harassment and victimisation and other conduct prohibited by the Act

• advance equality of opportunity between people who share a protected characteristic and those who do not

• foster good relations between people who share a protected characteristic and those who do not

3. The above requirements apply to eight of the nine protected characteristics – age, disability, gender reassignment, pregnancy and maternity, race, religion or belief, sex and sexual orientation. The protected characteristic of marriage and civil partnerships are slightly different in that the requirement is only in respect to have due regard to the need to eliminate discrimination.

4. In undertaking the analysis that underpins this document, where applicable, the department has also taken into account the United Nations Convention on the Rights of Persons with Disabilities (CRPD).

2. Brief outline of policy or service and main aims and outcomes

5. In England and Wales Winter Fuel Payments (WFPs) are currently an annual payment of £200 to households with people aged 66 to 79 and £300 to people aged 80 or over who are in receipt of pension credit, universal credit, income support, income-based jobseeker’s allowance and income-related employment and support allowance.  They are paid in November or December each year.  One payment is payable to each benefit unit entitled to the income-related benefit, regardless of whether the claim is for a single person or a couple. It is not taxable.

6. Prior to winter 2024 to 2025, the WFP was not means-tested and was a universal payment of (normally) £200 or £300 per household (according to age). To give effect to the household nature of the payment, for those not receiving an income-related benefit, such as pensioners on State Pension, shared payments were made where someone lives in a household with another person who has entitlement to the payment. It was not taxable.

7. In Scotland and Northern Ireland this policy area is a devolved or transferred matter.

8. From winter 2025 to 2026, the policy in England and Wales will change to expand eligibility for WFP so that it is paid to people who have reached State Pension age in or before the end of the qualifying week, the third full week of September. We refer to this as a universal benefit in this Equality Analysis (EA)^{[footnote 1]}. However, the level of the means test will be increased so that the payment is recovered from those with annual income over £35,000. HMRC will introduce a new tax charge to recover the payment in full if the individual has an annual income over that threshold. For the purpose of this EA, we have assessed the potential impact of reclaiming the payment from individuals with an annual income above £35,000 per annum. This is addressed in this EA and compares the equality impact of the current policy with that of paying all pensioners but then reclaiming the payment from individuals with an annual income above £35,000.

9. Maintaining the current policy of linking eligibility for WFP to Pension Credit or other means-tested benefits would result in an estimated 1.5 million individuals receiving the WFP in winter 2025 to 2026. Moving to a universal benefit would increase the numbers entitled to WFP from 1.5 million to an estimated 10.9 million in England and Wales in 2025 to 2026. Reclaiming it from those above an annual income threshold of £35,000 could then reduce the number of net beneficiaries to 8.9 million. This would mean 7.4 million people would gain compared to the current policy, and 3.5 million people would see no change – 1.5 million who would have been entitled under the current policy, and 2 million whose payment will be fully recovered via a tax charge.

3. Evidence and Analysis Impacts

3.1 Analytical approach to the Equality Analysis

10. For the purposes of this Equality Analysis (EA), the current policy in place for winter 2024 to 2025 is used as a baseline; where Winter Fuel Payment (WFP) is a means tested benefit paid only to customers in receipt of Pension Credit and other qualifying means-tested benefits.

11. The EA then compares those currently receiving a WFP to those that would keep their WFP from the new policy and those that would not benefit from the new policy, as their income is over the £35,000 pa threshold. The WFP these individuals receive as a result of universal eligibility, is retrieved through the tax system. The EA also considers the protected characteristics of those whose WFP will be taken back.

12. Winter Fuel Payment statistics for winter 2024 to 2025 (current year) are not available at the time of writing; publication of these statistics is planned for 16 September 2025. Analysis of protected characteristics for current WFP recipients is produced using current data on Pension Credit (PC) recipients, from Pension Credit official statistics, as a proxy for WFP receipts. This data is available at PC recipient level (1.3 million individuals in England and Wales)^{[footnote 2]}. We do not include pensioners in receipt of other Income-Related Benefits (IRBs) as this data is not readily available. They make up a small proportion of the current WFP eligible population.

13. The Family Resources Survey (FRS) has data on some additional protected characteristics compared to the Pension Credit official statistics. However, the survey underestimates the number of Pension Credit recipients by 29% and the associated sample sizes are small.  Therefore, there is a risk in using the FRS to estimate the number of pensioners receiving Pension Credit split by protected characteristics, particularly if there is any bias in the group who under-report their PC claims. Therefore, Pension Credit official statistics are used.

14. Analysis of protected characteristics for potential WFP-eligible individuals and those who may have their WFP reclaimed, under the new policy, is produced using the Family Resources Survey for individuals who were in receipt of WFP in England and Wales in 2023 to 2024.

15. Due to data availability, there will be overlap with individuals currently in receipt of Pension Credit (proxy for WFP receipts) and individuals that will be beneficiaries of the new policy (newly entitled to the WFP and not taken back).

16. Latest available data on the proportions of individuals affected, split by protected characteristics, are produced using the Family Resources Survey for 2023 to 2024 and covers individuals in England and Wales only. These proportions are applied to the latest available State Pension caseload data for England and Wales, to estimate the numbers of individuals affected for each protected characteristic.

3.2 Summary of conclusions

17. Across all protected characteristics for which data is available, this policy will increase the number of beneficiaries as the policy significantly increases the numbers that will receive WFP and not have it taken back via the tax system. There is no cash change for those that will have the WFP taken back via the tax system, but they are affected by the change because they will receive a payment which will then be taken back through the tax system. Those more likely to be affected by this tax being taken back are pensioners who are aged 66 to 79, men, in a couple, non-disabled and of white ethnicity as they are the most likely to have incomes above £35,000 per annum.

3.3 Age

18. This policy will only directly affect those aged 66 or over as entitlement to Winter Fuel Payment is limited to those over State Pension age. Younger partners in a mixed-age couple receiving Universal Credit, where the older partner is over State Pension age, may be indirectly affected.

19. For those on the PC caseload in November 2024 in England and Wales, 40% (0.51 million) were aged 80+ and will not be affected by the new policy and will continue to receive the WFP as now. For those with an income at or below £35,000, 23% (2 million) were aged 80+ and may be beneficiaries of the new policy (newly entitled to the WFP and not taken back). In comparison, 21% (0.41 million) of those with an income above £35,000 were aged 80+; there is no cash change for this group, but they are affected by the change because they will receive a payment which will then be taken back through the tax system.

20. For those on the PC caseload in November 2024 in England and Wales, 60% (0.75 million) were aged 66 to 79 and will not be affected by the new policy and will continue to receive the WFP. For those with an income at or below £35,000, 77% (6.8 million) were aged 66 to 79 and may be beneficiaries of the new policy (newly entitled to the WFP and not taken back). In comparison, 79% (1.6 million) of those with an income above £35,000 were aged 66 to 79; there is no cash change for this group, but they are affected by the change because they will receive a payment which will then be taken back through the tax system.

21. Therefore, more people in both age groups will be cash beneficiaries compared to the current policy. However, those aged 66 to 79 are more likely to be affected by the tax charge, because they are more likely than those aged 80+ to have higher incomes.

3.4 Sex

21. For those on the PC caseload in November 2024 in England and Wales, 34% (0.43 million) were male and will not be affected by the new policy and will continue to receive the WFP. For those with an income at or below £35,000, 41% (3.6 million) were male and may be beneficiaries of the new policy (newly entitled to the WFP and not taken back). In comparison, 70% (1.4 million) of those with an income above £35,000 were male; there is no cash change for this group, but they are affected by the change because they will receive a payment which will then be taken back through the tax system.

22. For those on the PC caseload in November 2024 in England and Wales, 66% (0.84 million) were female and will not be affected by the new policy and will continue to receive the WFP. For those with an income at or below £35,000, 59% (5.3 million) were female and may be beneficiaries of the new policy (newly entitled to the WFP and not taken back). In comparison, 30% (0.6 million) of those with an income above £35,000 were female; there is no cash change for this group, but they are affected by the change because they will receive a payment which will then be taken back through the tax system.

23. This means more men and women will be cash beneficiaries compared to the current policy. However, men are more likely to be affected by the tax charge than women, because they are more likely than women to have higher incomes.

3.5 Marriage or civil partnership

24. For those on the PC caseload in November 2024 in England and Wales, 87% (1.1 million) were single and will not be affected by the new policy and will continue to receive the WFP. For those with an income at or below £35,000, 40% (3.6 million) were single and may be beneficiaries of the new policy (newly entitled to the WFP and not taken back). In comparison, 23% (0.45 million) of those with an income above £35,000 were single; there is no cash change for this group, but they are affected by the change because they will receive a payment which will then be taken back through the tax system.

25. For those on the PC caseload in November 2024 in England and Wales, 13% (0.16 million) were in a couple and will not be affected by the new policy and will continue to receive the WFP. For those with an income at or below £35,000, 60% (5.3 million) were in a couple and may be beneficiaries of the new policy (newly entitled to the WFP). In comparison, 77% (1.5 million) of those with an income above £35,000 were in a couple; there is no cash change for this group, but they are affected by the change because they will receive a payment which will then be taken back through the tax system.

26. This means that more couples and single people will be cash beneficiaries compared to the current policy. However, pensioners in a couple are more likely to be affected by the tax charge than single people because they are more likely to have higher incomes.

3.6 Disability

27. In order to explore self-reported disability among the population, Family Resources Survey (FRS) disability data was used. The FRS uses the Government Statistical Service (GSS) harmonised standard definition of disability, broadly in line with the Equality Act core definition. This classifies an individual as disabled if they report any physical or mental health condition(s) or illness(es) that last or are expected to last 12 months or more, and which limit their ability to carry out day-to-day activities a little, or a lot.

28. Pension Credit caseload data does not contain information relating to disability of PC recipients. However, as a proxy it is possible to look at those in receipt of Pension Credit and whether or not they received a pensioner disability benefit (AA, DLA or PIP). For those in receipt of Pension Credit in November 2024 in England and Wales, 0.78 million (56%) were in receipt of a pensioner disability benefit and may not be affected by the new policy and will continue to receive the WFP. Using the FRS, for those with an income at or below £35,000, 37% (3.3 million) self-reported having a disability and may be beneficiaries of the new policy (newly entitled to the WFP). In comparison, 31% (0.6 million) of those with an income above £35,000 were self-reported as having a disability; there is no cash change for this group, but they are affected by the change because they will receive a payment which will then be taken back through the tax system.

29. For those in receipt of Pension Credit in November 2024 in England and Wales, 42% (0.61 million) were not in receipt of a pensioner disability benefit and may not be affected by the new policy and may continue to receive the WFP. Using the FRS, for those with an income at or below £35,000, 63% (5.6 million) were not self-reported as having a disability and may be beneficiaries of the new policy (newly entitled to the WFP). In comparison, 69% (1.4 million) of those with an income above £35,000 were not self-reported as having a disability; there is no cash change for this group, but they are affected by the change because they will receive a payment which will then be taken back through the tax system.

30. This means that more disabled and non-disabled people will be cash beneficiaries compared to the current policy. However, non-disabled individuals are more likely to be affected by the tax charge than disabled individuals because they are more likely to have higher incomes.

3.7 Race

31. The low sample size in the Family Resources Survey means that the level of analysis is restricted in relation to ethnic group.

32. For those with an income at or below £35,000, 95% (8.4 million) were white and may be beneficiaries of the new policy (newly entitled to the WFP and not taken back). In comparison, 97% (1.9 million) of those with an income above £35,000 were white; there is no cash change for this group, but they are affected by the change because they will receive a payment which will then be taken back through the tax system.

33. For those with an income at or below £35,000, 3% (0.26 million) were Asian or Asian British and may be beneficiaries of the new policy (newly entitled to the WFP). In comparison, 2% (0.04 million) of those with an income above £35,000 were Asian or Asian British; there is no cash change for this group, but they are affected by the change because they will receive a payment which will then be taken back through the tax system.

34. For those with an income at or below £35,000, 1% (0.05 million) were Other Ethnic Group and may be beneficiaries of the new policy (newly entitled to the WFP). In comparison, 1% (0.01 million) of those with an income above £35,000 were Other Ethnic Group; there is no cash change for this group, but they are affected by the change because they will receive a payment which will then be taken back through the tax system.

35. Pensioners in ethnic minority groups are more likely to be on lower incomes: white pensioners had an average gross weekly income of £697 per week in 2021 to 2022 and 2023 to 2024 compared to £583 for Asian or Asian British pensioners, £489 for African, Caribbean or Black British pensioners and £505 for pensioners of other ethnicity^{[footnote 3]}. Pensioners in ethnic minority groups are therefore more likely to be eligible for PC. However, Pension Credit caseload data does not include data on Pension Credit receipt by ethnicity.

36. The Family Resources Survey (FRS) estimates that 88% of PC claimants, where the head of the household (most likely the main PC claimant in a couple) is White, 7% Asian, 3% Black or African or Caribbean or Black British, 3% others. However, the FRS underestimates the number of PC recipients by 29% and the associated sample sizes are small. Therefore, there is a risk in using the FRS to estimate the number of pensioners who are non-white receiving PC, particularly if there is any bias in the group who under-report their PC claims.

37. This means that a larger number of White, Asian, Asian British and Other Ethnic Groups will be cash beneficiaries from the new policy. White individuals are more likely to be affected by the tax charge because they are more likely to have higher incomes.

38. The department has work in train to try and improve our ability to report on ethnicity, disability and other protected characteristics in the medium term through improved linking of datasets.

3.8 Gender reassignment

39. DWP does not hold information on gender reassignment on our systems as it is not required for the administration of WFP or PC and no appropriate survey data exists. However, we do not expect there to be a disproportionate impact on persons with this characteristic.

3.9 Pregnancy or maternity

40. Given that WFPs are only made to those over State Pension age, this policy is only likely to have an indirect impact on people with this characteristic, for example, where the younger partner in a mixed-age couple is female. In such a case an older partner over State Pension age would receive a WFP. Given the very small numbers likely to be affected, directly or indirectly, we do not expect there to be a disproportionate impact on persons with this characteristic.

3.10 Religion

41. DWP does not hold information on religion on our systems as it is not required for the administration of WFP or PC and no appropriate survey data exists. However, we do not expect there to be a disproportionate impact on persons with this characteristic as the change equally affects all religions.

3.11 Sexual orientation

42. DWP does not hold information on sexual orientation on our systems as it is not required for the administration of WFP or PC and no appropriate survey data exists. However, we do not expect there to be a disproportionate impact on persons with this characteristic as the change equally affects all sexual orientations.

4. Summary of analysis

43. Across all protected characteristics for which data is available, this policy will increase the number of beneficiaries as the policy significantly increases the numbers that will receive the Winter Fuel Payment (WFP) and not have it taken back via the tax system. There is no cash change for those that will have the WFP taken back via the tax system, but they are affected by the change because they will receive a payment which will then be taken back through the tax system. Those more likely to be affected by this tax being taken back are pensioners who are aged 66 to 79, men, in a couple, non-disabled and of white ethnicity as they are the most likely to have incomes above £35,000 per annum.

5. Plans to monitor and evaluate the equality decision

44. The approach to monitoring this legislation will be through the annual Winter Fuel Payment statistics that DWP publishes online. These will allow us to monitor the number of households receiving a Winter Fuel Payment on an annual basis.  HMRC will continue to monitor the tax system through information collected from Real Time Information and Self- Assessment returns.

6. Outcome of the evaluation

45. Ministers have decided to implement this increase in the level of the means test in the knowledge that pensioners who are aged 66 to 79, male, in a couple, non-disabled and of white ethnicity are more likely to have their Winter Fuel Payment taken back via the tax system and will not benefit in cash terms. This is an effect of the policy intent to provide annual one-off cash payments on a net means-tested basis to people with annual income of £35,000 or less. However, the government will need to have regard to the findings of the analysis in the way in which the policy is implemented, ensuring that HMT, HMRC and DWP establish a delivery system which is as smooth and automated as possible.

1. An individual must be ordinarily resident in England and Wales on the last day of the qualifying week (typically the third full week of September) to be eligible for WFP. There are some exemptions, namely individuals who throughout the qualifying week are in hospital receiving free treatment and who have been in hospital for a year, who are in prison serving a sentence, who do not have permission to enter UK and are without recourse to public funds, who are in receipt of income-related benefits and have lived in a care home from  22 June to 21 September 2025 (the 12 weeks before the qualifying week) ↩

2. Stat-Xplore - Home ↩

3. Pensioners’ Incomes: Background information and methodology - GOV.UK ↩