Today we submitted our response to the Department for Work and Pensions’ (DWP) “Pathways to Work” consultation. This is the process through which the Government is asking for people’s views on their proposed changes to welfare support for Disabled people.
About our submission
The DWP has released a questionnaire with an extremely limited scope, asking participants closed questions only about certain parts of the proposals. We do not agree that this is appropriate, so we decided to submit our response in writing instead.
In it, we focus on the impacts of proposals on those living with mental ill-health, distress and trauma. This includes the impact proposals are already having, how they intentionally harm those living with mental ill-health, and the knock-on effects this will have on our (already struggling) mental health system. We also outline in detail the failings of the consultation process as a whole.
Our submission is based on what our members’ have told us, and research about the impact these cuts will have. We have interwoven stories shared with us by members, which outline just how catastrophic the impacts have already been, and will continue to be.
Our full submission is linked above, but we are also providing a summary of the key points we made below.
Key points
Current context
- The UK welfare system is already causing harm. While we are supportive of reforms in theory, the specific reforms that are being proposed are cruel and ineffective.
- The proposals themselves have already caused harm, plunging many thousands into worry and despair. This is dangerous.
Impact of reforms
- The reforms intentionally target those living with mental ill-health, distress, and trauma, who will be severely impacted by changes to eligibility criteria for Personal Independence Payments; this will deepen poverty among those living with mental ill-health, create more despair, and prevent many people from working.
- Other reforms will also plunge hundreds of thousands into poverty, which in turn will deepen pre-existing despair and create new mental ill-health.
- Our mental health services are already failing – they cannot cope with this additional demand. This will then impact anybody who tries to interact with mental health services.
Reforms will fail on their own terms
- Far from increasing employment, many people (particularly those who are no longer eligible for PIP) will have to stop working.
- Reforms will exacerbate ill-health. They do not “save” money – instead, they simply shift expenditure from the DWP to the NHS.
Insufficient and potentially unlawful consultation
- The consultation excludes almost all reforms from its scope.
- There has been insufficient information for people to analyse the scale of the reforms, including a lack of proper impact assessments (particularly relating to mental ill-health), and a delay in the release of the full evidence pack.
- The consultation directly discriminates against Disabled people; the accessible versions were not published along with the consultation, consultation events are held in inaccessible locations, and venues are only announced with 24 hours notice meaning people cannot plan their journeys.
Key facts
Impact on those living with mental ill-health, distress, or trauma
- The Government has not (and does not intend to) conduct an impact assessment on how these reforms will affect those living with mental ill-health.
- 48% of people receiving PIP for anxiety and depression, and 26% for ‘other psychiatric disorders’ would not qualify for PIP under new rules..
- 1 in 3 mental health claimants would lose access to PIP. This includes: 81% of claimants on the standard rate, and 9% of people on the enhanced rate.
- Beyond the mental health context, 87% of all people currently receiving the daily living component of PIP at the standard rate would not qualify under the new rules proposed in the Green Paper.
Underlying logic
- The Government is putting too much faith in speculative claims that PIP assessments will become more thorough as a result of proposed changes. We know that people are routinely scored lower than they should be on PIP assessments.
- Despite Government ministers talking about “overdiagnosis”, research shows that there are 12 times as many people with undiagnosed distress as there are people who could be considered as ‘overdiagnosed‘. Disabled people are three times more likely to live with undiagnosed distress.
- The current fraud rate for PIP is 0% (Department for Work and Pensions, 2025).
- The reforms are supposedly designed to get people into work. But one sixth of those in receipt of PIP are already in work (Department for Work and Pensions, 2025).
- Research from Money and Mental Health (2025) showed that 63% of participants who were in work said they would have to significantly reduce or give up work if they lost their PIP entitlement.
Increasing poverty
- Reforms will plunge an estimated 700,000 people who are already in poverty into deeper destitution. This is on top of the 250,000 people who will be newly driven into poverty as a result. These are the Government’s own figures, which are notably lower than others predict; suggesting that the figure for those newly pushed into poverty will be closer to 340,000.
- The cascading impacts of these reforms mean that some households are set to lose as much as £10,000 a year (Citizens Advice, 2025).
The cost of “savings”
- Any potential savings outlined in the Pathways to Work Green Paper will be ‘offset by a range of unintended costs elsewhere across the system’ (including increased £1.2bn additional costs for the NHS); with this offset in mind, cuts are projected to ‘save’ a mere £100m by 2030, 2% of the £5bn claimed by the Government (The Disability Policy Centre, 2025).
- Poverty caused by the Government’s current welfare system is already costing public services £13.7 billion per year, including £6.3bn in healthcare expenditure (The Trussell Trust, 2025).
Our demands
Proposals should have been designed from the outset by those who interact with and rely on the welfare system.
In the absence of this, the Government must halt all advancements on implementing the reforms until a full and proper consultation has taken place.
A proper consultation must include:
- Full and proper impact assessments, equally available to all.
- Consultation which includes all reforms within its scope.
- Consultation events that are accessible, proportionate to demand, and co-designed with Disabled people.