Research and analysis

International Comparisons of Disability Benefits and Disability Employment: Literature Review Technical Report

Published 26 February 2026

Department for Work and Pensions (DWP) research report no. 1123

A report of research carried out by the National Centre for Social Research on behalf of the Department for Work and Pensions.

Crown copyright 2026.

You may re-use this information (not including logos) free of charge in any format or medium, under the terms of the Open Government Licence. To view this licence, visit: Open Government Licence or write to:

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First published February 2026.

ISBN: I978-1-78659-957-5

Views expressed in this report are not necessarily those of the Department for Work and Pensions or any other government department.

Technical Report

The review involved 2 phases: first, a review of comparative literature to provide an overview of the range of international approaches; and second, the development of 4 case studies on Denmark, Australia, Norway, and the Netherlands, to provide more detailed findings. This report provides a detailed description of the methodology for both phases.

Phase One: broad comparisons

Scoping phase

The review began with a short scoping phase. An initial literature search used Scopus (a large multi-disciplinary database of academic literature) and Google Scholar. This involved engaging with subject-matter experts and representatives from DWP. A short series of conversations were conducted with 3 subject-matter experts. These conversations guided the research team’s understanding of the research and policy landscape and informed the design of a longlist of relevant countries for inclusion in the review. This longlist included: Australia, Canada, Denmark, Germany, Sweden, the Netherlands, Switzerland, and Norway. The list below provides explanations for these decisions:

• Australia: often compared to the UK and recommended during discussions with subject matter experts
• Canada: known for having a well-developed social welfare system and various initiatives supporting disabled individuals in the workforce
• Denmark: featured regularly across initial desk research and agreed as a priority during project inception
• Germany: has an insurance-based system, providing a useful comparison to the UK
• Norway: has a comprehensive welfare state with significant emphasis on supporting disabled individuals in employment
• Sweden: known for its inclusive social policies and featured regularly across initial scoping desk research
• Switzerland: included based on discussion with subject matter experts due to a high rate of employment
• The Netherlands: featured regularly across initial scoping desk research

Search strategy

Our strategy for the initial phase was to search exclusively for comparative literature.

The search for involved 2 separate elements:

Academic literature was searched for using complex search strings developed in partnership with an evidence search specialist, which were run on Scopus.

Table 1 shows the search string that was run on the Scopus database, generating 723 results.

Table 1: Search Summary

Number	Search string	Results
1	TITLE-ABS(disability OR disabilities OR disabled OR “differently abled” OR ((chronic* OR “long term” OR persistent OR prolonged OR ongoing) W/1 (disease* OR condition* OR illness))) OR AUTHKEY(disability OR disabilities OR disabled OR “differently abled” OR ((chronic OR “long term” OR persistent OR prolonged OR ongoing) W/1 (disease* OR condition* OR illness*)))	990,729
2	TITLE-ABS(employ* OR work OR working OR workplace OR job* OR labor OR labour OR income OR volunteer* OR occupation* OR “vocation* rehabilitat”) OR AUTHKEY(employ OR work OR job* OR labor OR labour OR income OR volunteer* OR occupation* OR “vocation* rehabilitat*”)	12,922,680
3	TITLE-ABS(comparative OR comparison* OR international* OR cross-country OR cross-national* OR “best practice” OR “case study” OR “case studies”) OR AUTHKEY(comparative OR comparison OR international* OR cross-country OR cross-national* OR “best practice*” OR “case study” OR “case studies”)	8,457,003
4	TITLE-ABS(government* OR country OR countries OR national* OR policy OR policies OR law OR regulation* OR regulate* OR politic) OR AUTHKEY(government OR country OR countries OR national* OR policy OR policies OR law OR regulation* OR regulate* OR politic*)	10,199,841
5	TITLE-ABS-KEY(Australia* OR Canada* OR German* OR Sweden OR Swedish OR “Netherlands” OR dutch OR Norway OR Norwegian* OR scandinavia* OR Denmark OR Danish OR Swiss OR Switzerland OR OECD OR “united nations” OR “north america” OR europe OR EU)	5,315,761
6	#1 AND #2 AND #3 AND #4 AND #5 (Limited to 2021-present)	723

Grey literature was searched for by identifying relevant organisations and searching their websites using key terms. The following organisations were used in the grey literature search: Organisation for Economic Co-operation and Development (OECD); World Health Organisation (WHO); International Labour organisation; United Nations; European Commission; RAND; Google Scholar and official government websites for each country.

Screening

Inclusion and exclusion criteria

To be included in the review, sources had to meet the following inclusion criteria: they must include at least one of the following countries: Australia, Canada, Denmark, Germany, Sweden, the Netherlands, Switzerland, and Norway; they must discuss national-level policies for supporting relating to disability benefits or disability employment; they must compare policies between at least 2 countries; and they must be published after 2021 in English.

Title and abstract screening

All academic papers identified by the database search were manually screened by reviewing the titles and abstracts against the inclusion criteria using Sysrev (an online systematic reviewing platform). The screening tool was piloted by the research team before titles and abstracts were screened independently.

Full text screening

Following this screening process a final round of screening involved reviewing the full text of each study to confirm that it met the inclusion or exclusion criteria. After full-text screening, 20 studies were included in phase one of the review, including 11 academic studies and 9 non-academic studies.

Quality appraisal

Quality appraisal was conducted alongside full text screening. We used a condensed version of our bespoke tool that builds on the Weight of Evidence framework^{[footnote 1]}. Studies were given an overall average score based on their individual scores (3 for Yes, 2 for Partial, 1 for No) on the following questions:

• is there a clear statement of the aims or objectives or clear research questions?
• is the data selection strategy clearly described and appropriate?
• is the method of data collection clearly described, and appropriate to answer the aims or research questions?
• does the study account for the comparability of measures from the included countries. For instance, do the authors consider contextual differences in their comparisons?
• Are there any concerns regarding accuracy (e.g. discrepancies within the report)?

Data extraction and reporting

We structured the extraction of data by research questions to enable a narrative synthesis of evidence relating to each question. Synthesis was conducted using a ‘framework method’ reflecting our aim of drawing out key international comparisons.

PRISMA chart

A Preferred Reporting Items for Systematic reviews and Meta-Analyses (PRISMA) flow chart depicts the different phases of an evidence review^{[footnote 2]}. It maps out the number of studies identified, included and excluded for phase one of the review.

Stage	Identification of studies via databases and registers	Identification of studies via other methods
Identification	Records identified from Scopus (n=723)	Records identified from grey literature searching (n=17)
Screening	Records screened at title and abstract (n=723) - Records excluded (n=685)	Records screened at full text (n=17) - Records excluded for not meeting the inclusion criteria (n=8)
Screening	Records screened at full text (n=38) - Records excluded for not meeting the inclusion criteria (n=27)	Blank cell
Included	Studies included in phase one of the review (n=20): 11 academic papers, 9 pieces of grey literature	Blank cell

Phase 2: case study design

Selection of case studies

We presented the interim findings from phase one of the review to DWP and the wider Steering Group. Following this meeting and further conversations with our subject matter experts, we reached a decision to select the following 4 countries as case studies: Denmark, Australia, Norway and the Netherlands. These countries were chosen based on analysis of the comparative literature and were selected based on overall relevancy to the research questions and to reflect a mix of systems that are broadly comparable to the UK as well as those offering contrasting approaches.

The list below provides explanations for these decisions:

• Denmark emerged as a successful example of a disability benefits model, featuring heavily within the comparative literature
• Australia was viewed as comparable to the UK context, enabling exploration into the impact of restrictions to eligibility and strict conditionality
• Norway emerged as useful for exploring employer responsibility with examples of strong vocational rehabilitation
• Netherlands emerged as a useful example of policies for young people with disabilities who may never have worked or have had long-term reduced capacity

Targeted gap-fill searching

We conducted supplementary searches to develop detailed case studies, including additional information on the policy or programme overview, the implementation process and key stakeholders involved, outcomes and impacts, and lessons learned. Literature was searched for iteratively by identifying relevant organisations and searching their websites using emerging key terms. The following organisations and websites were used in the grey literature search: Google Scholar, OECD; WHO; and various official government information pages for each country. We based inclusion on relevancy. The strength and quality of evidence was reported in each case study but not formally scored for each paper. The sources for phase 2 are cited in text and recorded within the references of the main report.

Data extraction and analysis

Data was extracted from all additional sources into a dedicated note document for each case study. This data was then analysed and synthesised thematically alongside the comparative data.

Additional case study

To better inform a UK policy audience, DWP produced an additional case study on the UK. This was written by DWP following the reporting phase. The structure of the case study was based on the 4 existing case studies. Published DWP statistics, government reviews and existing evaluations were used as the evidence base.

Evidence Overview for Phase One

Source	Study Description	Countries	Quality Score
Assmann, M.-L. & Broschinski, S., 2021. Mapping Young NEETs Across Europe: Exploring the Institutional Configurations Promoting Youth Disengagement from Education and Employment. Journal of Applied Youth Studies, Volume 4, pp. 95-117.	Quantitative analysis of secondary data	Italy, Finland, Portugal, Slovenia, Luxembourg, Spain, France, Sweden, Slovakia, Latvia, Denmark, Estonia, Greece, Netherlands, Belgium, Austria, Germany, Lithuania, Ireland, Poland, Hungary, Czechia, United Kingdom	2.6
Baptista, I. & Marlier, E., 2022. Social protection for people with disabilities in Europe an analysis of policies in 35 countries, Luxembourg: Publications Office of the European Union.	Comparative policy paper	35 European countries	2.8
Barr, B., McHale, P. & Bentley, L., 2022. The policy effects of disability benefit reforms: A comparative analysis of Denmark, the UK and Sweden, Liverpool: Department of Public Health and Policy.	Quantitative comparative policy paper using secondary longitudinal data	Denmark, Sweden and the UK	2.8
Blanck, J. M., Brzinsky-Fay, C. & Powell, J., 2025. Pathways to Inclusion? Labour Market Entry Trajectories of Persons with Disabilities in Europe. Social Inclusion, Volume 13, pp. 1-24.	Quantitative comparative analysis using longitudinal data	31 European Countries	2.4
Breznitz, D. & Zehavi, A., 2022. Promoting inclusive innovation for disabled people in four countries: who does what and why? Disability & Society, 29(4), pp. 827-849.	Comparative case studies	Sweden, Germany, USA Israel	2.8
Chhabra, G., 2021a. Turning a blind eye to employers’ discrimination? Attitudinal barrier perceptions of vision impaired youth from Oslo and Delhi. Disability & Society, 36(10), pp. 1688-1711.	Comparative study based on qualitative interviews	India Norway	3
Chhabra, G., 2021b. Social Resilience in the Labour Market: Learning from Young Adults with Visual Impairments in Oslo and Delhi. YOUNG, 29(5), pp. 508-528.	Comparative case studies	Norway and India	3
Eurofound, 2021. Disability and labour market integration: Policy trends and support in EU Member States, Luxembourg: Publications Office of the European Union.	Large scale comparative review	All EU member states	2.6
European Commission, 2021. Study supporting the evaluation of the European Disability Strategy (2010-2020), Brussels: s.n.	Implementation evaluation using public consultation stakeholder interviews	European wide.	3
Garcia-Mandico, S., Prinz, C. & Thewissen, S., 2022. Disability, Work and Inclusion Mainstreaming in all Policies and Practices, Paris: OECD Publishing.	Large scale comparative policy report	OECD countries.	2.8
Hall, C., Hardoy, I. & von Simson, K., 2024. Policies for young adults with reduced work capacity. Labour market impact in Sweden and Norway. Journal of population and Economics, 37(13), pp. 1-33.	Comparative impact analysis	Norway and Sweden	2.6
Heymann, J., Wong, E. & Waisath, W., 2022. A Comparative Overview of Disability Related Employment Laws and Policies in 193 Countries. Journal of Disability Policy Studies, 33(1), pp. 25-34.	Large scale comparative review	All 193 UN member states.	2.8
Hwang, G.-J., Jensen, N. K. & Wadiwel, D., 2024. Disability, employment and welfare reform: A comparative analysis of Australia and Denmark. Australian Journal of Social Issues, Volume 59, pp. 1013-1030.	Comparative policy paper	Denmark; Australia	2.8
Jensen, N. K., Gyu-Jin, H. & Wadiwel, D., 2024. Caught in the middle? Comparing disability payment restructuring and workfare in Denmark and Australia. Disability & Society, 40(9), pp. 2494-2516.	Comparative policy paper	Denmark; Australia	2.8
Litsardopoulos, N. et al., 2025. Work and Health: international Comparisons with the UK, Brighton: Institute for Employment Studies.	Comparative policy paper	Denmark, Germany, Sweden, the Netherlands, Austria, Belgium, France, Greece, Ireland, Italy, Luxembourg, Portugal, Spain, and the United Kingdom.	2.8
MacDonald, D., Prinz, C. & Immervoll, H., 2020. Can disability benefits promote (re)employment? Considerations for effective disability benefit design, S.l.: OECD Publishing.	Comparative policy paper	OECD countries.	2.2
Miguel, M. & Rodriguez, V., 2022. Sheltered employment for people with disabilities: An international appraisal with illustrations from the Spanish case, Munich: Munich Personal RePEc Archive.	Literature review	EU countries with a case study of Spain	1.8
Osterud, K. L. & Vedeler, J. S., 2024. Disability and Regulatory Approaches to Employer Engagement: Cross-National Challenges in Bridging the Gap between Motivation and Hiring Practice. Social Policy and Society, 23(1), pp. 124-140.	Qualitative interviews	Norway; USA	2.8
Rydland, H. T. et al., 2023. Promoting labour market inclusion of the chronically ill: a scoping review of Scandinavian countries’ efforts. Scandinavian Journal of Public Health, Volume 51, pp. 1097-1107.	Scoping review	Denmark, Sweden and Norway.	2.8
van der Zwan, R. & de Beer, P., 2021. The disability employment gap in European countries: What is the role of labour market policy? Journal of European Social Policy, 31(4), pp. 473-486.	Qualitative comparative Analysis	European wide.	2.2

1. Gough, D. (2007). Weight of Evidence: a framework for the appraisal of the quality and relevance of evidence. Research Papers in Education, 22(2), 213–228. ↩

2. PRISMA 2020 flow diagram – PRISMA statement ↩