Policy paper

HIV Action Plan for England, 2025 to 2030: equality impact assessment

Published 1 December 2025

Applies to England

Introduction

The public sector equality duty (PSED) that is set out in the Equality Act 2010 requires public authorities, in the exercise of their functions, 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

The PSED does not specify how public authorities should analyse the effect of their existing and new policies and practices on equality but doing so is an important part of complying with the duty.

HIV Action Plan 2025 to 2030

This equalities analysis examines the potential impact of the publication and implementation of the HIV Action Plan 2025 to 2030 (the plan), in accordance with the Equality Act 2010. This has considered the likely impact of the strategy on eliminating discrimination, advancing equality of opportunity and fostering good relations between people who share a protected characteristic and those who do not.

There has been significant progress in HIV prevention, treatment and care in England in the last 5 years, with increases in testing, uptake of preventative medication and access to treatment. Over the past 2 decades, England’s HIV epidemic has undergone profound changes. Following consistent declines in HIV diagnoses in the prior decade, the most recent data suggests a slowing down of progress. Between 2020 and 2024, new HIV diagnoses rose from 2,240 in 2020 to 2,838 in 2023, falling slightly to 2,773 in 2024.

However, while overall trends show progress they also mask variation and the data reveals that today’s HIV epidemic is broader, more complex and more geographically diffused than ever before. For example, among gay and bisexual, and other men who have sex with men (GBMSM), overall diagnoses are falling but there are persistent inequities for ethnic minority men. In White GBMSM, diagnoses fell by 11% from 517 in 2020 to 461 in 2024, but for ethnic minority GBMSM diagnoses rose by almost 50% from 194 to 285 in the same period.

Sharp increases are also being seen in diagnoses of Black African heterosexual men and women with new diagnoses more than doubling; from 109 to 265 for men and from 181 to 418 for women between 2020 and 2024.

Migration and mobility continue to shape patterns and new diagnoses are rising outside of London, in areas that once had low HIV prevalence. 

These shifts underline the importance of making progress for all. The changing epidemic demands an updated evidence-driven response that is inclusive, innovative and fair, ensuring every community benefits from prevention, care and the best possible outcomes.

The HIV Action Plan seeks to combine the efforts of government, local authorities, the NHS, the UK Health Security Agency (UKHSA), academia, industry, voluntary and community sectors, and people living with HIV, in support of the government’s bold ambition to end HIV transmissions by 2030. 

Over the next 5 years, we will build strong, collaborative structures nationwide, driving the transformation set out in the 10 Year Health Plan: from hospital to community; from analogue to digital; and from sickness to prevention.

The HIV Action Plan sets out 5 clear priorities to focus and co-ordinate our efforts, reduce HIV transmission and create a foundation for monitoring progress. These will help us to identify what’s working, highlight areas for improvement and ensure that no one is left behind. Actions underpinning these priorities will support everyone in England to remain HIV negative, or to live well with HIV. To ensure that progress is equitable and is reaching those with the greatest need, we will measure progress for 5 populations disproportionately affected.

Intended aims

The HIV Action Plan 2025 to 2030 aims to accelerate activities in support of the ambition to end new HIV transmissions by 2030 in England. It sets out a clear path forward, detailing clear priorities, identifying key populations and setting out the actions to be taken. It also describes how the plan will be implemented and adapted going forward, connecting local governance with national oversight and regular evaluation of progress.

The vision behind the HIV Action Plan is to support everyone in England to remain HIV negative, or to live well with HIV. This universal approach is designed to ensure that everyone has access to comprehensive prevention, testing, treatment and care, alongside efforts to raise awareness of HIV and reduce stigma.

To track progress, UKHSA will publish an annual monitoring and evaluation framework, focusing on 3 overarching ambitions aligned with the latest UNAIDS recommendations:

• reduce new HIV infections by 90% from 2010 and a continued 5% decline per year after 2030
• reduce AIDS-related deaths by 90% from 2010
• secure the sustainability of the HIV response through 2030 and beyond

Five populations

At its heart, the HIV Action Plan’s approach is based on equity and inclusion. It is clear that actions must reach those who are at increased risk, and people who are less likely to access sexual health services (SHSs). This means interventions must reach people who believe they are unlikely to acquire HIV, those with complex health and care needs, plus individuals who face HIV stigma, structural disadvantages and socioeconomic challenges.

Progress made towards ending new HIV transmissions by 2030 has not been experienced evenly across all population groups. Inequalities in access to HIV prevention, treatment, ongoing care, quality of life and stigma are widening across most demographic characteristics, in particular, ethnicity, gender identity, route of exposure and age.

The plan proposes an updated, equity driven approach, with a particular focus on people who are at greater risk of HIV and people living with HIV. To ensure fairness and equitable impact, the plan focuses on measuring progress for 5 populations, which data shows are disproportionately affected by HIV. These are:

• ethnic minority GBMSM (excludes men from White ethnic minorities and includes adult men of Black African ethnicity, Black Caribbean ethnicity, Black other ethnicity, Asian ethnicity, and other ethnicity or mixed ethnic background)
• White GBMSM (includes adult men of White British, White Irish and White other ethnicity)
• Black African heterosexual men (Black African populations refers to a self-identified ethnic group, not region of birth)
• Black African heterosexual women
• ethnic minority heterosexual adults, excluding Black Africans (excludes heterosexuals from White ethnic minorities and Black African ethnic minorities)

UKHSA will continue to monitor HIV across all populations and promptly identify any new trends to ensure England’s response remains agile and aligned to both national needs and changing global patterns.

Five priorities

The plan sets out 5 priorities. They have been designed to unite and align efforts nationally and locally, galvanise leadership at every level and to drive focused, co-ordinated action with measurable impact. By covering every stage of the HIV pathway, the priorities ensure inequalities are addressed head on - tackling barriers experienced by the 5 populations and other affected communities and creating a system where services work seamlessly together to improve outcomes. The 5 priorities are:

• priority 1: prevent - we will prevent HIV transmission through equitable access to HIV prevention services
• priority 2: test - we will scale up HIV testing to find everyone living with undiagnosed HIV
• priority 3: treat - we will rapidly link and retain people living with HIV in care, ensuring individuals can live healthy lives and cannot pass it on
• priority 4: thrive - we will address stigma and improve the quality of life of people living with HIV
• priority 5: collaborate - we will strengthen the healthcare system to improve HIV care and wider sexual health

Who will be affected

The plan is for everyone in England, going further to ensure those at most risk of acquiring HIV and those living with HIV receive the support they need. It acknowledges that progress toward ending new HIV transmissions by 2030 has been uneven across different groups, including a specific focus on measuring impact across 5 key populations who are disproportionately affected by HIV.

The updated plan continues to focus on GBMSM and Black African heterosexuals, while recognising the disproportionate impact and additional challenges among women, migrants from high HIV prevalence countries, ethnic minorities and younger GBMSM.

In line with the duties under the Equality Act 2010, there is a duty to consider the impacts of the strategy towards:

• eliminating unlawful (direct and indirect) discrimination
• advancing equality of opportunity
• fostering good relations

We have considered the impact of the plan across these 3 domains.

Evidence

Main sources of evidence

We have utilised the following sources of evidence to develop this assessment:

• national HIV surveillance and analysis on HIV provided by UKHSA, most recently highlighted in the 2025 official statistics release
• government and public health reports on HIV strategy and outcomes, including the HIV Action Plan monitoring and evaluation framework 2024 report
• the HIV positive voices 2022 survey report, a survey of patients attending HIV specialist care in England, Wales and Scotland
• evaluations examining the effectiveness of interventions, including the 2025 Public health evaluation of blood-borne virus (BBV) opt-out testing in emergency departments (ED) in England

We have also engaged with a wide range of stakeholders and people with lived experience and reflected their insights in development of the plan (see the Engagement and involvement section below). This is to ensure the actions in the plan meet the needs of people with different protected characteristics, eliminating unlawful discrimination, advancing equality of opportunity and fostering good relations between people who have a protected characteristic and those who do not.

Analysis of impacts

The following section assesses the impact of the strategy towards addressing the 3 aims of the PSED set out above. While this analysis has been completed for each protected characteristic, we know that there is significant interaction between different factors, which often compound the health risks and needs for individuals. This includes characteristics protected under the Equalities Act 2010 alongside other factors such as deprivation, education and income. Overlapping factors such as ethnicity, sex and socioeconomic status can combine to create unique barriers and experiences in accessing HIV prevention, testing and care.

Disability

Under schedule 1 of the Equality Act 2010, all people living with HIV are considered to have a disability under that law. However, it should be noted that despite this many people living with HIV do not self-identify as a disabled person.

By seeking to support all people in England to remain HIV negative, or to live well with HIV, this plan is likely to have a positive impact on those who have a disability in law due to living with HIV, including those who live with HIV but do not self-identify as a disabled person. Implementation of policies will consider the impact on disabled people and inform ongoing equalities analysis.

The plan aims to tackle stigma experienced by people living with HIV, contributing to eliminating unlawful discrimination, advancing equality of opportunity and fostering good relations between people living with HIV and those who do not. This may have a positive impact on their employment, relationships or physical activities. The plan aims to address the experience of self-stigma and stigma within communities through supporting local areas to develop culturally competent, gender-responsive public awareness campaigns. It also highlights the need to involve people with lived experience in service design and delivery.

UKHSA does not collect information directly on those living with HIV who experience other types of disability. However, disability information is collected in the positive voices survey, a regular survey that captures the lived experience of people living with HIV. This survey found that one in 15 people (6.8%) living with HIV were sick or disabled, compared to 4% of the general population in 2022.

The HIV Action Plan aims to improve access to testing, PrEP and support for people receiving care. The action to update guidance to support the integration of care for HIV and co-morbidities may lead to improved care for people living with HIV who are also experiencing other health conditions.

Sex

The Supreme Court has clarified that the term sex in the Equality Act 2010 refers to biological sex. Evidence shows an association between sex and HIV outcomes, as well as experience of different stages of the HIV care pathway.

UKHSA collects information on the sex of people through the following data systems:

• the HIV and AIDS reporting system (people accessing HIV care services)
• HANDD (HIV AIDS new HIV diagnoses and deaths)
• genitourinary medicine clinic activity data set (GUMCAD) (which collected information on people access SHSs including PrEP and HIV testing activity)

This data shows that in 2024, Black African women were less likely to accept an HIV test than Black African men when offered (78% compared to 93%), contributing to their later diagnosis and potentially poorer health outcomes (see table 6 in the HIV Action Plan monitoring and evaluation framework).

Additionally, the positive voices 2022 survey report assessed awareness of the fact that those who have an undetectable viral load cannot pass on HIV (referred to as the undetectable = untransmittable (U=U) concept). This was assessed by asking whether people living with HIV had heard the following: ‘A person on HIV treatment with undetectable viral load cannot pass on HIV through sex’. Overall, awareness of the concept of U=U was very high (92.3%) (see the conclusion of the positive voices 2022 survey report) but women had the lowest awareness among demographic groups (88.2%), compared to higher rates in men. Furthermore only 50.8% of women reported strongly believing in U=U compared to 56.3% of heterosexual men and 73% of gay and bisexual men.

The report also assessed how the U=U concept made them feel about their HIV status to evaluate whether understanding of the concept could reduce self-stigma. In total, 52.9% of women living with HIV reported that U=U made them feel much better about their HIV status, compared to 60.5% of men.

The HIV Action Plan is expected to have a positive impact on inequalities in testing in order to support equality of opportunity between men and women. The 2025 evaluation of the BBV ED opt-out testing programme showed that a higher proportion of people newly diagnosed through the programme were women, compared to people newly diagnosed in all other settings, such as sexual health services (25% compared to 30%). Continuation of the ED opt-out testing programme is therefore expected to address inequalities in testing rates between men and women.

The plan also seeks to have a positive impact on inequalities in awareness and stigma related to sex, contributing to eliminating unlawful discrimination, advancing equality of opportunity and fostering good relations between men and women. Nationally the plan will improve awareness of U=U through the new HIV Prevention England programme, and local areas are asked to include U=U promotion in their work to improve the quality of life of people living with HIV. The plan also aims to address gaps in awareness and experience related to self-stigma and stigma within communities through supporting local areas to develop culturally competent, gender-responsive public awareness campaigns. It also highlights the need to involve people with lived experience in service design and delivery.

Sexual orientation

There is evidence to show a relationship between sexual orientation and HIV outcomes, as well as experience of different stages of the HIV care pathway.

UKHSA collects information on sexual orientation through GUMCAD. Exposure to HIV is collected through HIV and AIDS reporting system (HARS) and HANDD - this categorises people with how HIV was likely acquired: sex between men, sex between men and women (in addition to other routes including injecting drug use and vertical transmission).

This information is not directly collected for new HIV diagnoses or for people accessing HIV care - it is collected to inform an assessment of HIV exposure because it is the sexual activity, and not the identity, that is the relevant information in relation to ascertaining transmission risk for HIV. For instance, a self-identified heterosexual man may have acquired HIV through sex with other men. For people who acquire HIV sexually, UKHSA place people into 3 categories, GBMSM, heterosexual men (including bisexual men who have had sex only with women) and heterosexual women (including women who have also had sex with women). It is not possible to acquire HIV through sex between women.

Positive voices collects information on sexual orientation for people living with HIV. In 2022, 47.9% of respondents identified as heterosexual with 46.1% reporting being gay and 4% reporting being bisexual. Of women living with HIV in 2022, 95.4% reported being heterosexual, 1.5% bisexual, with less than 1% as being gay or lesbian.

Preventative interventions are a key element of the HIV care pathway. On average, gay and bisexual men have higher uptake of testing and PrEP compared to heterosexual adults and have also experienced a decline in HIV diagnoses.

Although testing in SHSs has increased since the COVID-19 pandemic, the recovery has not been consistent across all groups. For example, 2024 saw the highest number of GBMSM ever tested. However, rates for heterosexual men and women have not risen much since pre-pandemic figures. Between 2019 and 2024, the number of heterosexual and bisexual women tested fell by 8%, and heterosexual men by 17%, while testing among GBMSM rose by 38%.

Inequalities in sexual orientation can also intersect with inequalities by sex and ethnicity. For example, test positivity rates in 2024 varied: ethnic minority gay and bisexual men had the highest positivity rate (0.4%, with 192 positive results from 45,800 tests), followed by Black African heterosexual women (0.4%, with 165 positive results from 39,674 tests), Black African heterosexual men (0.3%, with 96 positive results from 33,509 tests), White gay and bisexual men (0.2%, with 255 positive results from 154,790 tests), and other ethnic minority heterosexual adults (0.1%, with 139 positive results from 198,222 tests).

Timely access to treatment and support is vital for living well with HIV. The HIV Action Plan monitoring and evaluation framework found that in 2023, a greater proportion of men exposed to HIV through sex with men started treatment within 3 months of diagnosis compared to those exposed through heterosexual contact, with the lowest rates among people of Black ethnicity. The positive voices 2022 survey report found the use of HIV support services was reported by one in 10 (10.3%) people living with HIV and was more prevalent among minority ethnic groups (12.5% of Black African individuals, 11.1% of other non-White ethnicities) and women (11.8%).

The positive voices 2022 survey report examined how the concept of U=U affected self-stigma among people living with HIV. Three in 5 respondents (58.1%) said the U=U statement made them feel much better about their HIV status, with similar responses across age and ethnicity. However, a lower proportion of heterosexual men (57.3%) felt much better compared to gay and bisexual men (63.0%).

The positive voices 2022 survey report also emphasised the importance of exploring intersectionality, recognising how ethnicity, gender, sexuality, deprivation and HIV status intersect to shape experiences of stigma. The plan reflects these complexities by identifying 5 key groups as being central to the plan’s focus:

• White and ethnic minority GBMSM
• ethnic minority GBMSM
• Black African heterosexual men
• Black African heterosexual women
• ethnic minority heterosexual adults (excluding Black Africans)

The HIV Action Plan is expected overall to have a positive impact on inequalities in testing, supporting equality of opportunity between individuals of differing sexual orientation. The 2025 evaluation of the BBV ED opt-out testing programme showed that a higher proportion of people newly diagnosed through the programme had acquired HIV through heterosexual sex, compared to people newly diagnosed in all other settings (65% compared to 47%). Continuation of this programme is therefore expected to address inequalities in testing rates between individuals of differing sexual orientation.

The plan also aims to address inequalities in prevention of HIV, including PrEP, between people with different sexual orientation, which may contribute to equality of opportunity. The national HIV Prevention England programme will focus on improving awareness of HIV prevention among at-risk populations, alongside promotion of practising safe sex, testing and education.

By investing in retention and re-engagement in care at a national level, the plan seeks to address inequalities in access to treatment and support linked to sexual orientation, in order to support equality of opportunity.

The plan also aims to have a positive impact on inequalities in awareness and stigma related to sexual orientation, contributing to eliminating unlawful discrimination, advancing equality of opportunity and fostering good relations between individuals of differing sexual orientation. Nationally the plan will improve awareness of U=U through the new HIV Prevention England programme, and local areas are asked to include U=U promotion in their work to improve the quality of life of people living with HIV. It aims to address gaps in awareness and experience related to self-stigma and stigma within communities through supporting local areas to develop culturally competent, gender-responsive public awareness campaigns. It also highlights the need to involve people with lived experience in service design and delivery.

Race

The impact of ethnicity on health outcomes is complex and varied. UKHSA collects information on ethnicity of people through the following data systems:

• the HIV and AIDS reporting system
• HANDD
• GUMCAD

The HIV Action Plan monitoring and evaluation framework 2024 report showed a rise in new HIV diagnoses in England in 2023, with ethnic minorities disproportionately affected, both among men exposed through sex between men, and among people exposed through sex between men and women. In 2023, one in 3 diagnoses among men exposed through sex with men were in an ethnic minority group (excluding White ethnic minorities), while 2 in 3 diagnoses among people who acquired HIV through heterosexual contact were in an ethnic minority group (excluding White ethnic minorities).

Initiation or continuation of PrEP was lowest in GBMSM of Black Caribbean or Black other ethnicity (65.9%) and GBMSM of Black African ethnicity (66.3%), with the highest being GBMSM of other Asian (not Indian, Bangladeshi or Pakistani) ethnicities (80%) and GBMSM of White ethnicity (76%).

The estimated number of adults aged 15 years and over living with transmissible levels of virus in 2023 was between 15% and 18% of people estimated to be living with HIV in England. These include people living with undiagnosed HIV, plus people diagnosed but not linked to, or not seen for specialist HIV care, not on treatment or with no evidence of viral suppression. Over 25% of people with transmissible levels of virus were from a Black African background. Using lower-bound estimates in 2023, 29% were undiagnosed, 31% were not retained in care and 28% were on treatment but not virally suppressed.

The HIV Action Plan is expected to have some positive impacts on inequalities in testing, supporting equality of opportunity for people from different ethnic minority communities. The 2025 evaluation of the BBV ED opt-out testing programme showed that, compared to people newly diagnosed in all other settings, a higher proportion of people newly diagnosed through the programme were of Black Caribbean (6% compared to 3%), Black other (14% compared to 4%), or White British ethnicity (19% compared to 11%). Continuation of this programme is therefore expected to address some inequalities in testing rates related to people’s ethnicity.

The plan also aims to address inequalities in prevention of HIV, including PrEP, between people from different ethnic minority communities, which may contribute to equality of opportunity. The national HIV Prevention England programme will focus on improving awareness of HIV prevention among at-risk populations, alongside safer sex promotion, testing and education.

By investing in retention and re-engagement in care at a national level, the plan seeks to address inequalities in access to treatment and support linked to ethnicity in order to support equality of opportunity, because people of Black African ethnicity are overrepresented among those not in HIV care.

The plan also aims to have a positive impact on inequalities in awareness and stigma related to ethnicity, contributing to eliminating unlawful discrimination, advancing equality of opportunity and fostering good relations between people from different ethnic minority communities. It aims to address gaps in awareness and experience related to self-stigma, and stigma within communities, through supporting local areas to develop culturally competent, gender-responsive public awareness campaigns. It also highlights the need to involve people with lived experience in service design and delivery.

Age

It is important to understand the changing needs and demands across all age groups and take targeted action to address these. The data shows there are variations in risk levels and in access to testing and treatment services at different stages of people’s lives. 

UKHSA collects information on the age of people through the following data systems: the HIV and AIDS reporting system, HANDD and GUMCAD.

Between 2023 and 2024, there was a 7% decrease in the HIV testing rate in all SHSs in people aged 15 to 24 years; this compares to a continued increase in the HIV testing rate in all other age groups.

Between 2023 and 2024, new diagnoses of HIV among GBMSM declined across most age groups, yet men aged 65 and over saw a 115% increase (from 13 to 28). As the population living with HIV ages, the complexity of health needs will rise, requiring services that are resilient, flexible and equipped to address these needs.

The largest decreases in new diagnoses of HIV among GBMSM were observed among men aged 15 to 24 years, with an 11% decrease (from 123 to 110), and the 25 to 34 age group, with a 10% decrease (from 363 to 328). However, the number of diagnoses among these age groups is still high.

Despite progress in HIV treatment, significant age-related disparities persist. In 2024, treatment coverage was lowest among people aged 15 to 24 years at 96% (1,538 of 1,604) when compared with all adults at 99% (102,485 of 103,515). Positive progress has been made in treatment simplification, with the proportion of people on a single-tablet regimen rising from 35.7% in 2017 to 54.0% in 2022 (see the conclusion of the positive voices 2022 survey report). However, only 46.0% of those aged 65 and over benefit from a single-tablet regimen, compared to 63.8% of younger adults.

Older individuals are more likely to conceal their HIV status (see the conclusion of the positive voices 2022 survey report), with 15.9% of those aged 65 and over not sharing their status with anyone - double the rate seen in men overall (8.8%). However, self-stigma is higher among those aged 18 to 34 (54.4%) compared to older adults (36.7%) (see table 6 of the HIV Action Plan monitoring and evaluation framework).

By investing in retention and re-engagement in care at a national level, the plan aims to address inequalities in access to treatment and support linked to age, in order to support equality of opportunity. Specifically, the action to update guidance to support the integration of care for HIV and co-morbidities seeks to improve care for people living with HIV who are also experiencing other health conditions, who are more likely to be in older age groups.

The plan also seeks to have a positive impact on inequalities in awareness and stigma related to age, contributing to eliminating unlawful discrimination, advancing equality of opportunity and fostering good relations between people of different ages. It aims to address gaps in awareness and experience related to self-stigma and stigma within communities through supporting local areas to develop culturally competent, gender-responsive public awareness campaigns. It also highlights the need to involve people with lived experience in service design and delivery.

Gender reassignment (including transgender)

Evidence suggests there may be an association between gender reassignment and experience of HIV-related stigma.

UKHSA collects information on gender re-assignment (through collecting the gender assigned at birth and gender identity) of people through the following data systems: the HIV and AIDS reporting system, HANDD and GUMCAD. However, evidence on this protected characteristic is limited due to the small sample size. The positive voices 2022 survey also collects information on this protected characteristic, but evidence is limited by sample size, given only 65 of those surveyed were people who identified as either trans, non-binary or in another way.

The limited information available suggests that people who identify as trans, non-binary, or in another way face challenges within the HIV care pathway. The positive voices 2022 survey report indicated that sharing HIV status with GPs was less common among trans and non-binary people. The survey also found that over half (56.0%) of trans, non-binary and other gender-diverse individuals living with HIV reported having had a mental health diagnosis at some point in their lives. Furthermore, the survey suggested that trans, non-binary and other gender-diverse individuals living with HIV experience the most stigma and unmet needs, reporting the lowest life satisfaction scores (5.7 out of 10).

The plan aims to have a positive impact on inequalities in awareness and stigma, contributing to eliminating unlawful discrimination, advancing equality of opportunity and fostering good relations between individuals who identify as trans, non-binary or in another way. It seeks to address gaps in awareness and experience related to self-stigma and stigma within communities through supporting local areas to develop culturally competent, gender-responsive public awareness campaigns. It also highlights the need to involve people with lived experience in service design and delivery.

The plan does not address the specific health needs that are unrelated to HIV, faced by trans or non binary individuals which are not experienced by the general population. These are being considered through wider government work, such as the review to tackle health inequalities experienced by LGBT+ people, the adult gender services review and the Cass Review.

Religion or belief

There is no evidence of poorer outcomes for HIV by religion, and no adverse impacts were identified from the plan on this protected characteristic.

UKHSA does not collect information on religion or belief through routine surveillance but does collect information through the positive voices survey, which captures the lived experience of people living with HIV. This showed that in 2022, 62% of respondents in the survey reported being religious, 9% spiritual but not religious and a further 30% being atheist or agnostic. Of people who reported being religious, 85% were Christian.

Pregnancy and maternity

There is no evidence of poorer outcomes for HIV by pregnancy or maternity status. UKHSA collects information on pregnancy as part of routine surveillance in HARS and HANDD. UKHSA does not routinely collect information on working arrangements and caring responsibilities but this information is collected through the positive voices survey.

The plan includes a commitment for DHSC to fund formula milk and sterilising equipment provision for infants born to women living with HIV, in line with updated British HIV Association (BHIVA) guidance (PDF, 112KB). This will reduce the risk of vertical transmission from women living with HIV to infants during maternity and therefore indicates a positive impact on women living with HIV during maternity. No other impacts were identified from the plan on this protected characteristic.

Marriage and civil partnership

There is no evidence of poorer outcomes for HIV by marriage and civil partnership status. HIV surveillance does not capture information on marriage and civil partnership. Since transmission in the UK is primarily sexual and HIV carries significant stigma, questions about marital or civil partner status may be perceived as judgmental as sexual behaviour, not marital status, is the relevant risk factor.

Analysis did not identify any equalities impacts from the plan relating to the protected characteristic of marriage or civil partnership.

Other identified groups

HIV also disproportionately affects people who now live in England but were born abroad. This includes people who were diagnosed with HIV before continuing care in England. The number of diagnoses in this population rose from 860 in 2020 to 1,729 in 2023 before decreasing to 1,669 in 2024. Most people were virally suppressed on arrival to England and rapidly connected to ongoing treatment and care, preventing ill health and onward transmission. In addition, people born abroad in high prevalence countries who are diagnosed with HIV in England may have acquired HIV while abroad or while living in England.

The HIV Action Plan is expected to have some positive impacts on people living with HIV who were born abroad. The 2025 evaluation of the BBV ED opt-out testing programme showed that, a higher proportion of people newly diagnosed through the programme were born in a country of high or intermediate HIV prevalence, compared to people newly diagnosed in all other settings (28% compared to 25%). Continuation of this programme is therefore expected to improve testing rates among people born abroad. The plan also commits to an action to update the migrant health guidelines to improve awareness of HIV prevention interventions among healthcare practitioners, when they are considering the needs of migrant patients.

Engagement and involvement

Evidence and testing

UKHSA undertakes a broad range of different user engagement activities to ensure the information produced meets the needs of key stakeholders and is understood. These activities include but are not limited to:

• an online survey of stakeholders in 2025
• regular meetings with key stakeholders including local authority commissioners
• regular meetings with the English Sexual Health and HIV Commissioners’ Group
• regular meetings with the British Association for Sexual Health and HIV (BASHH) and BHIVA
• regular care pathway workshops with local providers and their commissioners
• hosting an annual meeting with clinical stakeholders to discuss the epidemiology of HIV
• hosting an annual meeting for HIV data reporters highlighting the impact of uses of the data reported
• regular contact with various sexual health and HIV charities
• teaching at undergraduate and postgraduate level
• providing statistics for individual clinics
• completing data requests from academic researchers as well as internal and external stakeholders
• contributing to Parliamentary Questions and Chief Medical Officer briefings
• producing publicly available slide sets for educational use
• giving presentations at conferences such as the annual BASHH, BHIVA and UKHSA conferences

Shaping policy

Collaboration is at the core of the new HIV Action Plan. Therefore, we have engaged with a range of system partners as part of its development. In total, we held 10 roundtable discussions, hosted by Professor Kevin Fenton, the government’s chief advisor on HIV, with over 250 key system partners. We also held 2 engagement sessions in London and Manchester with more than 60 voluntary and community sector representatives. The following roundtables and engagement sessions were held:

• Fast Track Cities - 26 September 2024
• regional leadership - 7 November 2024
• professional bodies - 3 December 2024
• UKHSA - 23 January 2025
• primary care - 7 March 2025
• Association of Directors of Public Health (ADPH) - 13 March 2025
• industry - 20 March 2025
• place-based leadership - 28 March 2025
• integrated care board (ICB) leads - 11 April 2025
• people with lived experience - 6 May 2025
• voluntary and community sector (VCS) engagement: London - 9 May 2025
• VCS engagement: Manchester - 14 May 2025

The focus of the roundtables was to discuss with key system partners:

• the previous HIV Action Plan, including its principles, priorities and accomplishments
• the key priorities for the new HIV Action Plan at a national, regional and local level
• how leadership, partnership working and accountability can be strengthened for the delivery of the new HIV Action Plan
• what is the most effective approach to measure progress.

The VCS engagement sessions focused on specific changes to the objectives of the new HIV Action Plan and ways in which the VCS can continue to engage and hold government to account in the production and implementation of the new plan. 

Key outputs from this engagement included the need for:

• improved healthcare system integration, including clear governance, accountability and funding structures and strengthened multi-sector partnerships across NHS, local government, ICBs and VCS
• tailored approaches for different populations, culturally competent and accessible services and information
• expanded HIV testing and prevention, including importance of public education
• peer support services for retention and re-engagement in care
• tackling HIV-related stigma through training to address health care inequalities and improve continuity of care
• enhanced data collection, sharing and analysis

Engagement was also done through the Implementation Steering Group (ISG) Advisory Board, comprised of former HIV Action Plan Implementation Steering Group members from across the key stakeholder groups. The group met to discuss the proposed objectives and key population groups for the plan. Membership of the ISG Advisory Group includes:

• central government and arm’s length bodies and/or executive organisations (DHSC, UKHSA and NHS England)
• local government, including: ADPH; Local Government Association (LGA) and HIV and Sexual Health Commissioners Group for England
• professional organisations, including: BHIVA and BASHH
• VCS organisations represented by: National AIDS Trust; Terrence Higgins Trust and BHA (formerly known as Black Health Agency) for Equality

Further engagement was then carried out with local government and professional body stakeholders to help support the development of key actions within the plan. We also held some one-to-one conversations with key VCS charities to understand how the HIV Action Plan can better support underserved population groups. Eleven government departments have also been engaged to ensure alignment of strategies and optimise resources, where possible. 

Summary of analysis

Overall, the HIV Action Plan 2025 to 2030 is expected to have a positive benefit in terms of eliminating unlawful discrimination, advancing equality of opportunity and fostering good relations across the protected characteristics under the Equality Act 2010. The plan’s focus on key populations most disproportionately affected by HIV aims to address the inequalities that influence HIV outcomes and the degree to which the policies could benefit different groups. The plan also includes specific actions to support women living with HIV and educating young people about HIV, having a positive impact for these groups. Overall no adverse impacts on the protected characteristics were identified.

The plan is expected to have a positive impact on people with protected characteristics relating to race, sexual orientation, gender reassignment and age, as well as for people born abroad. No equalities impact was identified with respect to the protected characteristics of disability, religion, marital status and disability.

Overall impact

Equalities analysis indicates that the combined impact of the plan will be positive for people with protected characteristics, and that overall, the plan will reduce discrimination, advance equality of opportunity and foster good relations between those who share a protected characteristic and those who do not. Lack of evidence has been identified in some places, which requires careful consideration and mitigation to prevent the inadvertent widening of health inequalities.

Addressing the impact on equalities

While, as outlined above, no adverse impacts on equalities have been identified through the evidence, ongoing consideration of the impact of the plan on all the protected characteristics will continue. 

Monitoring and evaluation

Monitoring and evaluation are essential to achieving the objectives of the HIV Action Plan over the next 5 years. Local leaders will be supported to interpret and apply data effectively to improve outcomes, while communities will be actively involved in understanding who is affected, the underlying reasons and emerging trends. Equality impacts and considerations for protected characteristics will be carefully monitored throughout implementation of the HIV Action Plan.

UKHSA will maintain responsibility for monitoring and evaluation, including the annual publication of the monitoring and evaluation framework. This process will track progress towards ending new HIV transmissions, with particular attention to the 5 disproportionately affected populations previously mentioned. Progress measures will be developed using existing outcomes and performance indicators from previous frameworks. DHSC will continue to assess the equality implications of policy developments in line with the PSED under the Equality Act 2010.

Given the evolving nature of the epidemic, a flexible approach will be adopted. Routine surveillance data from UKHSA, combined with evidence and insights from partners, will inform adjustments to actions and interventions to address emerging trends, population needs and equality considerations. A comprehensive review will take place in 2028 to determine how the plan should adapt to maximise progress towards shared ambitions.

Conclusion

The equality impact assessment for the HIV Action Plan concludes that no adverse impacts have been identified for any protected groups under the Equality Act 2010. The plan is expected to deliver positive outcomes by eliminating unlawful discrimination, advancing equality of opportunity and fostering good relations across all protected characteristics.

The HIV Action Plan 2025 to 2030 is designed to ensure equitable access to HIV prevention, treatment and care, with a particular emphasis on populations disproportionately affected by HIV. By focusing on measuring progress for the 5 populations most impacted by HIV, the plan seeks to address systemic inequities and reduce health inequalities, ensuring that policies deliver meaningful benefits for those who need them most.

Additionally, it is important to acknowledge that many of the actions set out in the plan will be delivered by a range of local and regional partners, including local authorities, ICBs and NHS trusts. All organisations involved in HIV prevention, treatment and care will need to consider the PSED and be responsive to the needs of their local populations.

Robust monitoring and evaluation processes will underpin the plan, engaging local leaders and communities to interpret data and identify emerging trends. UKHSA will oversee the annual publication of monitoring frameworks, ensuring continuous assessment of equality implications in line with the PSED. This approach will remain flexible and evidence-driven, adapting to new insights and evolving needs. A comprehensive review is scheduled for 2028 to confirm that the plan continues to maximise progress towards ending new HIV transmissions.

In summary, the HIV Action Plan 2025 to 2030 represents a proactive and inclusive strategy that will help eliminate discrimination, promote equality and strengthen relationships across all protected characteristics.