Transparency data

Minutes of the meeting held on 8 October 2025

Updated 20 March 2026

Chair:

Dr Stephen Brien

Members:

Les Allamby
Tom Clark
Rachel Chiu
Carl Emmerson
Daphne Hall
Professor Stephen Hardy^{[footnote 1]}
Jacob Meagher
Dr Suzy Walton
Professor Sharon Wright

Apologies:

Bruce Calderwood
Joanne Cairns
Philip Jones

1. Private session

[Partially reserved item]

Consideration of postal regulations

1.3. The Committee endorsed the Postal Regulations sub-group’s recommendation that the following regulations were a suitable candidate for clearance by correspondence:

• The Social Security (Residence in an EEA State or Switzerland) (Amendment) Regulations 2025

1.4. The Chair asked the Committee Secretary to notify the Department that the Committee was content for the above regulations to proceed.

2. Private session

[Reserved item]

3. The Universal Credit (Transitional Provisions) (Amendment) Regulations 2026

3.1. The Chair welcomed the following officials to the meeting:

• Graeme Connor (Deputy Director, Health and Disability Reform)
• Amy Morgan (Deputy Director, Universal Credit Analyst Division)
• Nic Vaughan (Grade 6, Move to Universal Credit)
• Nic Lovesay (Grade 6, Working Age Services)
• Lesley McCarthy (Grade 7, Universal Credit Operations)
• Katherine Hicks (Universal Credit, Analyst)

3.2. These regulations cover two measures: One is to allow for Short Notice Migration Notices (SNMN) to be issued to those on legacy benefits, similar to those introduced for the closure of Tax Credits, through the Social Security (Miscellaneous Amendments) Regulations 2025. ^{[footnote 2]} Graeme Connor explained that currently a migration notice (MN), once issued, allows for a minimum of three months for someone to make a Universal Credit (UC) claim. Once a hard deadline for the closure of legacy benefits is set, MNs could no longer be issued if it is within three months of that deadline. These measures allow for a SNMN to be issued within those three months and would mainly be for those who have been successful with their respective Mandatory Reconsideration (MR) or appeal and have had their benefit reinstated. This would ensure they do not lose out on Transitional Protection (TP).

3.3. The second measure covers a cohort of customers whose legacy benefit award continued despite receiving a MN and failing to complete a UC claim they had commenced. For these 309 customers, they should have received a stop notice and their legacy award should have ended on the deadline date on their MN; however, due to an oversight that meant appropriate internal processes were not in place, and this did not occur. This measure will now provide for their legacy award to end retrospective to the date of their UC claim, allowing them the grace period they should have had, which entitles them to TP and the transfer to UC of any Work Capability Assessment decision. It was indicated that the Department know who all these customers are and will be in contact with them to ensure this happens because they are unable to cancel their original MN.

3.4. Amy Morgan provided the Committee with an update on the progress of Move to UC.^{[footnote 3]} As part of this update the Department highlighted a number of significant elements for these regulations:

• 132,000 Employment and Support Allowance cases remain that need to migrate to UC
• additional support is to be provided to the Enhanced Support Journey (ESJ) for those customers receiving Employment and Support Allowance
• for those of no fixed abode, work is being done with external organisations to provide communications to those who are homeless, which includes teams connected to rough sleepers, to ensure they are aware of pending deadlines to migrate and to help ensure they move to UC
• the continued use of Complex Case Coaches to assist those who cannot be paid their benefits into a bank account or where home visits may not be possible
• an awareness of cases where someone may need an appointee, which may require consent for someone to act on their behalf, which may also include a mental health capacity assessment, and can be a lengthy process
• an acknowledgment that there are cases where there has been no engagement and this ultimately leads to a termination of benefits, with a safeguarding referral to the local authority where progress cannot be made
• given the number of customers corporate appointees are dealing with, an extension has been granted up until the end of October to allow them more time to migrate over to UC
• current plan is to end ESA on the 31 March 2026

3.5. Committee members raised the following main questions in discussion:

On the timing, why do these regulations need to be brought in now? Would it have been better to know when legacy benefits will be ending?

These regulations will come into force at the end of January 2026, so they need to be brought in now to make sure they are in place for the deadline to end remaining legacy benefits which is scheduled for 31 March 2026. SNMN will need to commence being sent at the end of January and despite a hard deadline yet to be set, the Department is confident, and measuring indicates suggest that March will be the end date for ESA. Any further delay would mean that could not be the case. If ESA did extend into another financial year, it will present problems with regards to uprating and budgets.

There is an expectation that numbers coming back into payment in the run up to March will be less than TC and will mostly relate to MRs and appeals, whereas TC also included those coming back into payment where they earned less than they possibly predicted at the start of the year.

Will these regulations therefore ensure that everyone who is entitled to TP will be given the adequate statutory period to receive it?

Even if the deadline was moved back, there would still be some people who potentially could come back into payment, so a deadline has to be set at some point.

Will the regulations regarding the abolition of legacy benefits come before the Committee?

This will be done through a Commencement Order so will not be subject to scrutiny by the Committee. SNMN will be introduced through these regulations; however, they will not be needed until that Commencement Order is brought forward.

These regulations are to be looked at in the context of when the Order is made and then they will be operated?

The Department is not yet committed to the date to bring the Order forward yet, but yes.

Does the Department have a view on numbers of claims that need to be remaining before considering the Order? The Department has indicated in the supporting paperwork that it is expecting less than 10 MRs and Appeals each month in the period of January 2026 to March 2026. With 132,000 ESA claims left what is the Department expecting to occur in the final few months; with Tax Credits there was an agreement with HM Revenue and Customs to get Appeals through the system, but what is the scale and task with these cases and how will they get through the system?

There will be far fewer cases coming back into payment than with Tax Credits, because there will be less changes of circumstances which can lead that to happen. On ESA mandatory reconsiderations and appeal numbers there is not as much notice as was had under TC because the numbers also include contribution-based benefits. In considering volume, it is estimated that around two per cent of the current MR’s and appeals would, if successful, require a MN, as most are either receiving some ESA (Income Related), or have already claimed UC.

Has consideration been given to those who are in receipt of legacy ESA contribution based who may get PIP and then may be eligible for ESA income based due to additional premiums? Appeals are taking a long time to be heard, so what if they become eligible after the closure date?

No, the Department agreed to look into this; however, there will be those that have appeals heard after whenever the closure date and they will miss out.

The plan is that the Department will migrate everyone to UC by 31 March 2026; however, is there a contingency plan?

The Department will consider the numbers and if there are a significant number to get over the line it will review and see if there is a systematic issue and whether it is too soon to say. There has been major progress over the summer, so it is looking confident for the 31 March, but the Department wants to be absolutely sure before introducing the Commencement Order.

At the end of this process, it is likely to involve the most vulnerable people, has this been considered?

With the ESJ customers, they get two reminders, one at week seven and one at week ten. If no UC claim is made, the ESJ will start, which includes three outbound phone call and home visits. If someone is issued a SNMN, a more flexible approach is adopted. It could involve moving straight to a phone call or home visit and will be decided on a case-by-case basis. There are around 13,000 that could be an entitled to ESJ from the current case load if they do not claim; however, the SNMN will involve small numbers so the journey can be tailored.

The Department may also receive contact by a partner organisation, social worker or family member which may indicate that the ESJ should be started sooner. The case can also be referred to a complex case coach, so steps may be put in place before week 11. Anyone issued a SNMN who would fall into this category would be appointed a complex case coach as soon as it is issued.

The Department indicates that four per cent of those on ESA have not gone on to claim UC and there could be a number of reasons for that, so how much money could someone lose if they do not get TP?

Most people on ESA without premiums will be better off on UC. Those in receipt of Severe Disability Premium (SDP) would be worse off; however, recent regulations mean that they can have a gap of up to a month before making a claim for UC and still get their SDP protection, which applies to both natural migration and move to UC. However, there are not that many left to migrate who are eligible. If someone was to lose their SDP and Limited Capability for Work and Work Related Activity, they would lose £663 a month.

They would also have a five week wait?

If a claim was made outside of the month, then yes. One of the reasons that the Department has not looked to introduce the Commencement Order is to make sure this is limited.

Has there been many terminations of entitlement on ESA?

The numbers are relatively small. If they make a claim before their deadline date, they will get their TP and there will be no gap in benefit. They will also get a two-week run on of their legacy benefit, which means they will not have a five week wait.

What are the small numbers? There is evidence that there is a negative emotional response to the MN or where people had hoped for a phone call but did not receive one. There are also many reasons as to why people are not claiming, such as balancing caring responsibilities. The Department indicates that elements such as the ESJ are in place and that they do not want to terminate claims; however, why is the Department not ensuring that it gets in contact before terminating claims?

The Department tries to make contact with each customer it holds contact numbers for as part of the ESJ. It attempts every number it has details of. If the calls are unsuccessful, it refers for a home visit and they would be called in advance to let them know when that is to take place and a letter is sent. This will be attempted twice. If they are not in, a note will be left to indicate that the Department has been to visit and then would do the second visit. However, if a report comes back to indicate that the property has been vacated or boarded up then the entitlement will be terminated.

Before entitlement is cancelled, during the transitional stage, the Department physically ensures that contact is made?

For most Income Support and all ESA customers, yes.

None of this good work has been included in the paperwork that the Department has presented to the Committee. The Committee would be in a better place for scrutiny if it had been presented with this because it can only go off the supporting paperwork.

Noted.

Given the percentages of those who go on to claim UC, around one in twenty are not claiming in the most vulnerable groups. That is way too high for this group. This feeds into the conversation around equality and diligence and ensuring people get over the line and claim what they are entitled to.

They are not slipping through the net, it could be that their circumstances are different, and they no longer wish to claim.

If that is the case, it needs to be written down and made clear in the supporting paperwork. The Department has stated its plan to end legacy benefits on 31 March. This presents a jeopardy for a certain group of people. These regulations are being put in place to avoid that jeopardy. The jeopardy being that they would lose out on entitlement that is better on legacy benefits and may not yet have migrated under the current system. The Department needs to make that clear and highlight the specifics, then the Committee can be tighter on the questions it needs to ask.

There would be jeopardy whatever date the Department sets. The cases that come back into payment will be mainly MR and Appeals and it wants to ensure that MNs are issued to these people. For those receiving standard ESA, going on to UC will mean that they are entitled to more. The concerns are with those who have SDP on ESA because they would lose out. However, for those with SDP who are appealing a LCWRA decision it is likely to be a straightforward outcome due to them having severe conditions.

This needs to be more tightly defined and made clear that these regulations are aimed at those with a superior legacy entitlement and need to migrate within three months of the end of legacy benefits. The supporting paperwork should also indicate that if someone claims UC after the termination date, they will have an additional month to claim if they have SDP and after that then they would receive no TP.

Noted.

There will also be appeals for those on ESA and Limited Capability for Work whose conditions have worsened, yet these reassessments have been kept on hold to prioritise new assessments. There are currently 110,000 in the backlog. Not all of these will be contributory ESA; however, it could be a substantial number that also have a PIP claim, who could then be entitled to ESA(IR) and subsequently entitled to TP. Would it not be better to wait until this backlog is cleared before considering this option?

If a customer has ESA and LCW they would be issued a MN anyway. It is difficult to know how many are contributory and how many would be looking to be considered for LCWRA from LCW. The Department is considering how many claims are coming back into payment. The Department agreed that it would take this away and come back to the Committee outside of the meeting.

There is a concern for very vulnerable people who may be unable to act for themselves and may be non-verbal autistic or have severe mental health problems. There is a risk that when they receive these MNs that they are in a bad place and there is a risk of death and/or suicide. There have been deaths in the past and there is a concern about the default position being to terminate a claim rather than keeping the payment live.

This was considered in detail under a former Secretary of State. It is exceedingly complicated, and the Department has always gone down the route of trying to communicate with anyone connected to that individual. This is why the termination date has not yet been set because the Department wants to make sure that none of these cases exist.

A group that will benefit from the SNMN are those who currently have an appointee that can no longer support or act for them, including corporate appointees that feel it is no longer appropriate that they do so. Once within the three-month time period a new MN could not be issued in these circumstances and would need to wait until a new appointee is put in place to send them a legal MN. This measure will ensure that they do not fall through the cracks of the system.

This element is absent from the supporting paperwork. If there are issues and problems the Department is trying to resolve, this needs to be made clear and to show what its intentions are and what it is doing to make sure these issues do not arise.

The Department will strengthen the explanatory memorandum and provide numbers to the Committee outside of the meeting.

What about those who are homeless, in hospital and in supported accommodation?

If a MN has been sent and someone has left the property, another MN can be sent. This would be the case if someone moved into temporary supported accommodation. However, the migration time would not be extended. More time would be given to them if needed. If there is a domestic violence situation, there are additional support measures.

If there was a domestic violence situation, that would be a new, individual claim because it would be a change of circumstances.

Noted.

What about situations where the Department is unaware of where a customer has moved to?

The MN would be sent to where the Department has details. Where contact cannot be made with the customer, it has often been found that they are in hospital or there are some customers who are quite transient due to their mental health. There have been cases that have been terminated, and the true circumstances have come to light, and a new MN has been issued.

What provision is in place for those where English is not their first language or where disabled people are unable to go into the Jobcentre? Is there an option for video calls?

If someone cannot verify their ID online, it can be done by telephone or face to face.

Where is the Equality Impact Assessment (EIA) for these regulations? Will they be included with the updated paperwork?

It was felt that the equality impact for the whole move to UC covered this element, so it was not included with these regulations.

There is a Public Sector Equality Duty and, in the paragraphs that have been provided on this, nothing mentioned has been relevant, which is concerning. Has the Department had regard to removing discrimination or victimisation?

There is a baseline situation; however, these regulations are changing elements and there are impacts that need to be evaluated. The measures seem positive but there are those facing jeopardy, such as those with ESA and SPD and those with appointees and they are likely to have protected characteristics. There is a need to highlight what has changed, how it will change and what the impacts will be. Therefore, the Committee is of the view that an EIA is required.

There is no jeopardy until the Commencement Order to terminate legacy benefits is brought in.

Noted.

For those who get the two-week run on in legacy benefits, how will they know if they have received it or how can they rectify this if they have not done so but would be eligible because they would not be aware with moving to UC, where their initial payment will not be paid for five weeks? It will be more important than for Tax Credits, as most of those claiming TCs will have had additional income and savings.

It is worth reiterating that only those with SDP would be worse off and they would also have an additional month to claim. The others will gain from going on to UC.

Under the new regulations on SDP, does the month start from when the legacy benefit ends or when the two-week run-on ends?

The Department agreed that it would confirm this to the Committee outside of the meeting.

What about those who have a disabled child and have a Child Disability Premium but may not have SDP themselves? Is there anyone with the lower rate child disabled element left in the case load because these regulations would not pick them up and could the Department check and confirm the numbers?

They would have been in receipt of Child Tax Credits and been migrated at that time; however, the Department agreed that it would check to see if there may be any cases and would inform the Committee outside of the meeting.

3.6. The Chair thanked officials for attending and for the constructive and candid discussion. He noted that the Committee would like to see updated papers reflecting some of the omissions highlighted in discussion before it can reach a view on whether or not to take the regulations on formal reference.

3.7. Subsequent to the meeting, and following consideration of revised papers provided by the Department, the Committee decided that it would not take the regulations on formal reference; however, they reiterated the following points that had been raised during scrutiny to ensure that implementation is managed in a way that minimises risk and protects the most vulnerable claimants.^{[footnote 4]} Most notably that:

• despite expected small numbers, those affected are likely to include claimants entitled to Severe Disability Premium or other additional elements. Missing the migration deadline could result in substantial and long-lasting financial loss and the cohorts affected merit careful handling given the potential impact.
• the tail-end cohort is likely to require intensive support, and that it considers it essential that adequate resources are available to manage SNMN cases effectively. This follows the Committees express concerns that the Commencement Order could be brought forward before the Department has migrated the majority of claimants already under Migration Notices.
• there is a risk that mandatory reconsiderations and appeals of ESA and those in receipt of contributory ESA awaiting a PIP appeal could conclude after the closure of ESA, leaving claimants unable to receive income-related ESA beyond abolition and unable to receive Transitional Protection or have their UC claim backdated beyond one month. This could disadvantage claimants through no fault of their own. Thereby. strongly encouraging the Department to consider whether delaying the closure date for ESA beyond April 2026 might provide a necessary safeguard.

4. Private Session

[Reserved item]

5. Next Meeting

5.1. The next meeting is scheduled to take place on 5 November.

6. Annex A

6.1 Attendees

Guests and officials

Item 3:

• Graeme Connor (Deputy Director, Health and Disability Reform)
• Amy Morgan (Deputy Director, Universal Credit Analyst Division)
• Nic Vaughan (Grade 6, Move to Universal Credit)
• Nic Lovesay (Grade 6, Working Age Services)
• Lesley McCarthy (Grade 7, Universal Credit Operations)
• Katherine Hicks (Universal Credit, analyst).

Secretariat:  

• Denise Whitehead (Committee Secretary) 

• Kenneth Ashworth (Assistant Secretary)

• Robert Cooper (Assistant Secretary)

• Edward Munn (Assistant Secretary)

• Lauren Shields (Analyst)

7. Annex B

7.1 Correspondence A

Graeme Connor
Deputy Director, Health and Disability Reform
Department for Work and Pensions
King’s Court
Sheffield

20 October 2025

Dear Graeme,

The Universal Credit (Transitional Provisions) (Amendment) Regulations 2026

Thank you for attending the Social Security Advisory Committee’s meeting on 8 October to present the above-named regulations for our statutory scrutiny. I am grateful for the time you invested in considering and responding to our many and detailed questions. I will be writing in due course to formally communicate the findings of our scrutiny.

In the meantime, I am writing separately to raise a related concern identified by the Committee relating to the changes to Regulation 44. The context for this is that the Department currently plans to have completed the move of all remaining legacy benefit claimants to Universal Credit by 31 March 2026. The abolition of legacy benefits will be achieved through a Commencement Order, and will therefore not be subject to the further scrutiny of this Committee. Nonetheless, the Committee wanted to ensure that the question of the timing of this closure was given due consideration in light of the issues identified in the scrutiny of the Short Notice Migration Notice regulations.

The Committee acknowledges that there are significant ongoing costs associated with continuing to run separate IT systems to deliver both legacy benefits and Universal Credit; and also that the numbers of claimants likely to be affected by this are small in the context of the overall caseload. However, as we are now at the end of the migration process, that small cohort is likely to include some of the most vulnerable claimants. This requires a high degree of diligence on the part of the Department to support the move onto Universal Credit where an entitlement exists, and to ensure that no vulnerable people slip through the net.

During our scrutiny, it was evident that the Department has given consideration to putting in place processes by way of mitigation of a number of potential risks and negative impacts, with enhanced support that introduces a number of interventions through reminder letters, telephone calls and visits. However, during our discussion, a number of scenarios were identified by Committee members where that support might be insufficient. Hence, we are seeking reassurance that appropriate precautions will be taken to support vulnerable claimants through this process, and that the Department will allow adequate time and staff resources for the most vulnerable claimants to be transitioned with care.

In light of our concerns set out above,^{[footnote 5]} the Committee would welcome greater clarity about the Department’s own criteria for determining whether or not it will assess whether or not it would be acceptable for legacy benefits to be closed down and the Commencement Order to be brought forward. We would also suggest that the Department considers how the Commencement Order could be amended to push back the date to provide a safety valve to protect these vulnerable claimants. This would enable the Department to review its plans in the event that the level of risk remained at an unacceptable level, perhaps in terms of the residual numbers of complex claims or vulnerable claimants, or the capacity of the Department to respond to that risk (e.g. visiting officers etc).

I would be happy to further discuss any aspect of this letter with you if that would be helpful.

A copy of this letter goes to the Minister for Social Security and Disability.

Yours sincerely,

Dr Stephen Brien
SSAC Chair

7.2 Correspondence B

Graeme Connor
Deputy Director, Health and Disability Reform
Department for Work and Pensions
King’s Court
Sheffield

24 October 2025

Dear Graeme,

The Universal Credit (Transitional Provisions) (Amendment) Regulations 2026: Regulation 44

Thank you for attending the Social Security Advisory Committee’s meeting on 8 October to present the above-named regulations for our statutory scrutiny. The Committee greatly appreciates the support you have provided throughout the scrutiny process, including subsequent meetings with you and your colleagues on 15 and 22 October, and for the constructive engagement you and your team have shown throughout.

The migration of claimants to Universal Credit and the closure of legacy benefits is scheduled to be completed by the end of March 2026. The above regulations provide a safe, albeit broad-brush, vehicle to achieve that migration for those who would otherwise not have received the more standard three-month notice period, for example as a result of coming into payment for a qualifying benefit within three months of the scheduled closure.

The Department’s stated approach to migrating existing customers to Universal Credit has been that the most vulnerable claimants would be moved across towards the end of the process, ensuring that it could benefit from the lessons learned from the more straightforward cases and review learning from the migration of more complex cases. This approach was designed to ensure a greater degree of consistency and more support, in particular those with disabilities and health conditions.

In order to ensure continuity of payment and entitlement to transitional protection, this final group needs to be adequately notified and supported in their journey. Not only are they likely to be vulnerable, but their timetable is also foreshortened.

As we have discussed, the Committee would benefit from a fuller exploration of the impact and specific effects of the proposals for claimants in different circumstances. For example, while the supporting material addressed protected groups that might be impacted, it does not articulate clearly the specific claimant circumstances and journeys of those affected, or what that impact would be. Although the Committee was satisfied that the regulations provide the enabling powers, it found that the specific circumstances triggering their use would benefit from fuller articulation to support our statutory review.

For example, this lack of specificity has made it challenging for the Committee to fully assess how these necessary regulations would be implemented and to scrutinise the Equality Impact Assessment (EIA). In particular, the information presented to the Committee lacked documentation on the core claimant journeys and circumstances that would trigger the need for Short Notice Migration Notices.

Additionally, the EIA was not clear that the reference baseline was one where the commencement order had been assumed to be made. Consequently, it was not stated whether the proposals would benefit or be to the detriment of each cohort, merely outlining some of those who would be affected. We would value a greater understanding of the likely circumstances in which these regulations are likely to be needed, and how the Department envisages operationalising these provisions.

Why is this important? During our discussions, Committee members identified a number of scenarios where the proposed support being put in place by the Department may prove to be inadequate. For example: claimants who are homeless, in hospital or supported accommodation; and individuals who are unable to act for themselves and may be non-verbal and/or have severe mental health problems. The examples identified by the Committee members were not necessarily exhaustive, but demonstrate some of the vulnerabilities involved and how the proposed arrangements being put in place might fall short for them. We would welcome the Department’s own assessment of the specific vulnerabilities within the claimant cohort that these regulations are likely to impact.

It is the Committee’s view that there needs to be a presumption of vulnerability among the group impacted by these proposals and it is therefore essential that DWP sets out its understanding of the circumstances in which these regulations would need to be triggered, what consideration it has given to risks identified and what, if any, mitigation is being put in place to address those risks.

My earlier letter to you (20 October) suggests that the Department considers how the Commencement Order could be amended (if needed) to push back the date to provide a safety valve to protect these vulnerable claimants, thereby enabling the Department to review its plans in the event that the level of risk remained at an unacceptable level.^{[footnote 6]} However, given the current stated timeframe for the closure of legacy benefits, we need to have greater understanding of how the journey is going to be managed for such groups before the Committee can complete its scrutiny of these regulations. For example, to what degree will the Department have a more proactive and comprehensive response where a particular vulnerability is identified or presumed?

For the Committee to able to complete its statutory review, it requires the Department to provide greater specificity of who is likely to be impacted by these regulations, and what consideration has been given to the consequences and mitigation of those impacts.^{[footnote 7]}

We also request that the Department (a) documents with clarity the primary circumstances under which a Short Notice Migration Notice would be issued, (b) demonstrate that the plans for supporting such claimants accounts for an appropriate presumption of vulnerability and the likely shortened timeframe for them to complete a UC application, and (c) undertakes a review of its current EIA to ensure it reflects more accurately and comprehensively the Department’s consideration of potential impacts and consequences, along with estimates (even approximate) of those likely to be affected.

By way of providing support to the team undertaking this review, and at your invitation, I was very pleased to have an opportunity to expand on the Committee’s feedback, and to explain in more detail the nature of the evidence that the Committee was seeking, with Hannah Birtwistle-Gordon and her team on October 22. During that meeting, I was assured that the information required by the Committee does exist but has yet to be written down. We appreciate the team’s efforts to document this thinking and look forward to receiving it in the coming days in order that we can complete the statutory scrutiny process as soon as possible.

I will revert with the outcome of the Committee’s scrutiny of these regulations as soon as we have received, and had an opportunity to consider, the Department’s revised documentation including the EIA. In the meantime, I would be very happy to discuss further.

A copy of this letter goes to the Minister for Social Security and Disability, Bill Thorpe, Jenan Hasan and Hannah Birtwistle-Gordon.

Yours sincerely,

Stephen Brien
SSAC Chair

7.3 Correspondence C

5th November 2025

Dr Stephen Brien
SSAC Chair

Dear Stephen,

Thank you for your letter of 20 October regarding the approach DWP are taking to completing Move to UC and ensuring all individuals are safely moved to Universal Credit. I would also like to thank you and the committee for your support around the associated regulation changes.

At our meeting on 8 October, colleagues provided a wealth of information regarding the Enhanced Support Journey. This additional activity has been the cornerstone to protecting those customers who are potentially vulnerable travelling through the net and successfully making the transition to Universal Credit. When we started to invite those on Employment and Support Allowance (without tax credits) in September 2024, there were around 800,000 households to move to UC. As we shared at the meeting, the majority of households have now had their Migration Notice. Our last published MI showed nearly nine out of ten are successfully made the transition. Our next MI, due to be published next week, will show further significant progress.

Throughout Move to UC, as with the rollout of Universal Credit, we have had checks and balances in place to constantly monitor progress and accuracy of delivery to ensure all customers are treated consistently and are provided with the best service. These have been developed further with checks focused on the groups of claimants who are likely to be more vulnerable.

As we approach the final months of our Move to UC timeline, we are constantly monitoring our readiness to complete the Move to UC and close the remaining legacy benefits. These include criteria focussed specifically on customers including:

• Outstanding caseloads on a trajectory to zero – such that towards the end of the period we can monitor each outstanding case individually
• Resources are in place to provide the Enhanced Support Journey for everyone, including sufficient capacity in services such as Visiting Officers.
• Systems, processes and resources in place to understand remaining cases yet to claim, and support them appropriately
• Approach for handling successful appeals and MRs is agreed / in place and working effectively
• Customer and Staff information and guidance (e.g. Gov.UK, Intranet pages etc) are kept up to date reflecting progress and the forecast completion of Move to UC / closure of Legacy benefit entitlements

Due to the governance, data and systems put in place to monitor and assess cases in the Move to UC journey, we are currently confident that: the caseload is reducing as anticipated; we have sufficient time to undertake all possible actions including issuing safeguarding referrals for vulnerable cases; volumes requiring a shorter journey will be small enough that they can be supported on a case-by-case basis. Where a claim is not made, we feel assured that all actions within our abilities will have been undertaken and we have no alternative other than closing a customer’s legacy benefit.

However, we are far from complacent and recognise the impact that our decisions will have on customers, so across the policy and delivery teams we are constantly monitoring progress and reviewing individual cases to ensure we are doing the right thing.

Since we met, we have published the Commencement Order to effect closure of Income Support and Jobseeker’s Allowance (Income-Based), as well as further small changes to reduce the inflows to Income-Related ESA and working-age Housing Benefit, another step towards completing the Move to UC. We will bring forward a similar Commencement Order for the remaining legacy benefits shortly, to take effect at the end of March 2026 as planned. However, the decision will not be made until we understand the customer impact of doing so. This includes assurances that every eligible customer has been issued with a Migration Notice, or is on track to do so, and resources are in place to support them to move ahead of the abolition date. Once a decision is made to start the process, we will retain the ability to review the closure date should any unforeseen circumstances arise.

Yours sincerely

Graeme Connor
Deputy Director
Health and Disability Reform Policy Division
Department for Work and Pensions

7.4 Correspondence D

Graeme Connor
Deputy Director, Health and Disability Reform
Department for Work and Pensions
King’s Court
Sheffield

19 November 2025

Dear Graeme,

The Universal Credit (Transitional Provisions) (Amendment) Regulations 2026

Thank you for presenting the above regulations to the Social Security Advisory Committee at its meeting on 8 October 2025, and also for your helpful subsequent briefings and written material on these proposals.

This letter confirms that the Committee has decided that, under the powers conferred by Section 173(1)(b) of the Social Security Administration Act 1992, it does not wish to take these regulations on formal reference and that they may proceed accordingly.

The Committee appreciated the Department’s efforts to explain the rationale for introducing Short Notice Migration Notices (SNMNs) and the benefits these measures will bring in safeguarding Transitional Protection for claimants affected by late Mandatory Reconsiderations or appeals. It has, however, asked me to reiterate the following points that arose during the scrutiny process, and which they hope may assist the Department as it finalises its plans for implementation and the closure of legacy benefits. The Committee recognises the benefits these regulations will deliver and supports their intent. The feedback provided is designed to ensure that implementation is managed in a way that minimises risk and protects the most vulnerable claimants.

Assumptions in Supporting Paperwork

The Committee noted that some statements in the explanatory memorandum may not fully reflect the realities for affected claimants. For example:

• An assumption that claimants impacted by SNMNs will have alternative income sources (para 2.1.15) is not necessarily accurate. Some may be on contributory Employment and Support Allowance (ESA) awaiting a Limited Capability for Work-Related Activity assessment or the outcome of a Personal Independence Payment (PIP) appeal, and may face significant hardship if migration is delayed.
• The assertion that no concerns were raised by stakeholders following the introduction of SNMNs for tax credit households (para 2.2.9) does not align with members’ insight from their roles outside of the Committee.

Numbers Affected and Risk to Vulnerable Claimants

While the Department expects numbers to be small, those affected are likely to include claimants entitled to Severe Disability Premium or other additional elements. Missing the migration deadline could result in substantial and long-lasting financial loss. Although the numbers are small, those cohorts affected merit careful handling given the potential impact.

Timing of Commencement Order and Resource Allocation

SSAC’s Chair, Dr Stephen Brien, has previously written to you expressing the Committee’s concern that the Commencement Order could be brought forward before the Department has migrated the majority of claimants already under Migration Notices. The Committee has asked me to re-emphasise that tail-end cohort is likely to require intensive support, and that it considers it essential that adequate resources are available to manage SNMN cases effectively.

Appeals Settled Too Late for SNMN Issue

There is a risk that mandatory reconsiderations and appeals of ESA and those in receipt of contributory ESA awaiting a PIP appeal could conclude after the closure of ESA, leaving claimants unable to receive income-related ESA beyond abolition and unable to receive Transitional Protection or have their UC claim backdated under the new provisions. This could disadvantage claimants through no fault of their own. The Committee strongly encourages the Department to consider whether delaying the closure date for ESA beyond April 2026 might provide a necessary safeguard.

I trust that this feedback is helpful, but do please let me know if you require any further information and/or clarification.

A copy of this letter goes to Hannah Birtwistle-Gordon.

Denise Whitehead
Committee Secretary

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1. Present for agenda items 2 and 3. ↩

2. The Social Security (Miscellaneous Amendments) Regulations 2025 ↩

3. Latest release on departmental statistics on Move to UC ↩

4. See Annex B for correspondence between the Committee and the Department. ↩

5. These will be outlined with greater specificity in a subsequent letter confirming the outcome of the Committee’s statutory scrutiny. ↩

6. For example, in terms of the residual numbers of complex claims or vulnerable claimants, or the capacity of the Department to respond to that risk (e.g. visiting officers etc). ↩

7. The proposals set out in the EIA add significantly to the regulatory development and timeframes. The inclusion of an enabling provision is useful, but clearly does not get at pace towards setting out the specific claimant journeys and circumstances that necessitate their use. The consideration of these, and the impacts of being foreshortened, from three months to a shorter period. There is no doubt that, done well, the process leads to better outcomes. ↩