The Green Paper – what is changing and when

The UK government has announced changes to universal credit, personal independence payment and contributory benefits. Carri Swann examines the plans, set out in DWP’s March 2025 Pathways to Work Green Paper and amended in the later Spring Statement, and explains how soon they come into effect.

The benefit changes announced in the March 2025 Green Paper are explicitly designed to cut welfare spending. Mainly, these are cuts to disability and incapacity benefits, affecting disabled people and those with long-term health conditions. There are a couple of benefit increases for the wider population – small rises in the universal credit (UC) standard allowance and a boost for jobseekers getting contributory benefits – as well as a funding injection for employment support. However, for many, the changes will have a vast negative impact.1See, for example, Resolution Foundation, Chart: annual impact of changes to PIP and UC announced in the Green Paper by Family Characteristics: UK, 2029-30, 1 April 2025

The DWP says that the plans will be cemented in an upcoming White Paper. Some are subject to a consultation closing on 30 June and others might change as draft legislation goes through parliament. Advisers need to know what has already been proposed, though, because some of the changes are due as soon as April 2026.

According to the Green Paper,2DWP, Pathways to Work Green Paper, 18 March 2025 (‘Green Paper’)there will be two significant alterations to UC in April. First, the UC’s limited capability for work and work-related activity (LCWRA) element will be cut by nearly half for new claimants, to £216 a month. A new premium will be introduced to offset the cut for some people, but for only those with ‘the most severe, life-long conditions’ who fall under the work capability assessment severe conditions criteria.3House of Commons, Hansard, col 21, 12 May 2025; DWP, Work Capability Assessment Handbook: for healthcare professionals, 6 September 2024, Appendix 8

While the LCWRA element will not be cut for existing claimants, they will not see any inflation-linked rise in their LCWRA element in April 2026, even while the other elements of UC go up in value. LCWRA elements will then be frozen for all claimants until 2029/30.

Simultaneously, the UC standard allowance will increase above inflation for all claimants in April 2026 and subsequent years until at least 2029/30. The government has already abandoned its initial Green Paper promise of a £30 boost over two years and the planned rise is now much smaller, with the standard allowance to increase from £400.14 monthly in 2025/26 to around £460 by 2029/2030.4See HM Treasury, Spring Statement, 26 March 2025, Table 3.1 (item 15). The reference figure is the standard allowance for single people aged 25 and over.

The Green Paper announced that personal independence payment (PIP) eligibility rules will change in 2026/27 so that the daily living component is only awarded to claimants who score four or more points on at least one individual activity. This change is to be made through primary legislation. As well as affecting new PIP claimants, it will hit existing claimants on award review, except (it appears) those over state pension age.5Answer to House of Commons, Hansard, written question UIN 45439, 23 April 2025 In her Green Paper speech, the Secretary of State for Work and Pensions said that this change would come into force in November 2026.
Data released by the DWP shows that 46 per cent of PIP daily living awards are made to claimants who do not score four points on any single activity, and therefore stand to lose their awards when the rules are changed.6DWP, freedom of information response FOI2025/25575, 14 April 2025, available at whatdotheyknow.com An ‘evidence pack’ published in support of the Green Paper shows that the only activities on which claimants routinely score four points or more are activities 1 and 9.7DWP, Pathways to Work: evidence pack: Chapter 2 reforming the structure, 2 May 2025 The data has also been broken down by health condition, showing (for example) that 33 per cent of PIP claimants with cancer score fewer than four points for any single daily living activity, alongside 48 per cent with anxiety and depression and 77 per cent with arthritis.8Answer to House of Commons, Hansard, written question UIN 47466, 1 May 2025

For those affected, loss of PIP entitlement will have knock-on consequences for other benefits: loss of carer’s allowance, becoming benefit capped, and receiving less help with housing costs due to rules on non-dependents, extra bedrooms and the shared room rate, for example.
The government in the Green Paper sought to justify the change as ‘taking action now to control the rising increase in spend on PIP and to make it more sustainable’. The Office for Budget Responsibility has calculated that it will cut spending on PIP by £4.7 billion. This estimate is based on an assumption that PIP claimants and decision makers will behave differently after the rules change. But if these effects are not seen, the cuts could be closer to £9 billion.9B Baumberg Geiger, ‘The headline disability benefit cuts are £9bn, not £4.7bn’, 28 March 2025, inequalities.substack.com

Scottish adult disability payment (ADP) currently uses the same activities and scoring system as PIP. Westminster’s block grant to the Scottish government is forecast to reduce after the PIP changes take place. If corresponding changes are not made to ADP eligibility, it would seem that the Scottish government will need to fund the difference.

While it has not confirmed a deadline, the government has announced that it ‘will introduce legislation that guarantees that trying work will not be considered a relevant change of circumstance that will trigger a PIP award review or [work capability] reassessment. We will make these changes as soon as possible... By legislating, we aim to give people more confidence that they will not be reassessed because they have tried work.’10Green Paper, para 124 The significance of this announcement has been downplayed by welfare rights advisers, who note that scheduled assessments will still take work into account and that decision makers are liable to overemphasise work as evidence of a claimant’s abilities.11On this topic, see the recent decisions in AE v SSWP [2024] UKUT 381 (AAC) and KW v SSWP [2024] UKUT 410 (AAC).

One of the Green Paper proposals currently open to consultation concerns the future of the UC LCWRA element for young adults. It is planned that claimants under 22 will stop getting an LCWRA or ‘health’ element from 2027/28. Welfare rights advisers have voiced concerns about the repercussions of this change for all young people, but particularly for young parents and for those young people in education who would presently be unable to receive UC without LCWRA status.

Two major changes announced in the Green Paper are due to take effect in 2028/29. First, the work capability assessment (WCA) is to be scrapped. In UC, a ‘health element’ will instead be paid only to claimants also getting a qualifying disability benefit. In England and Wales, this will be the daily living component of PIP, eligibility for which is already being squeezed from 2026. What will count as a qualifying disability benefit in Scotland, where PIP is being replaced by ADP, is not yet confirmed.

While the WCA is largely unpopular with claimants and advisers, the proposal to limit a UC health element to PIP claimants would be immediately detrimental to the 600,000 or more claimants who currently get an LCWRA element but not PIP.

With no concept of work capability in UC, there will be more work-related requirements – and, therefore, sanctions or the threat of sanctions – for ill and disabled claimants. The Green Paper actually suggests that a new ‘baseline expectation of engagement’ will be introduced by 2027/28, before the work capability assessment is scrapped, though it is unclear how this would sit with legal protections for claimants with LCWRA status.
In a second major proposal for 2028/29, the Green Paper opened a consultation on overhauling contributory benefits. It proposed that contributory employment and support allowance (ESA) and jobseeker’s allowance (JSA) be replaced with a single contributory benefit called unemployment insurance (UI).

The Green Paper describes UI as having no concept of work capability, with all claimants treated as jobseekers and ‘easements’ acting as the only protection for ill and disabled claimants. Unlike contributory ESA, which is paid indefinitely to claimants in the support group, the proposal is to make UI time-limited for everyone. It is also to be paid at a single rate regardless of the claimant’s circumstances. The proposals have prompted criticism for undermining the contributory principle and ending long-term provision for ill and disabled people’s core needs other than via means testing.

Beyond the 2026 PIP changes, the government used the Green Paper to announce a wider review. The official justification for this plan is that ‘[PIP] needs modernising. It is over a decade since PIP was introduced, during which time there have been significant shifts in the nature of long-term conditions and disability, as well as changes in wider society and the workplace.’ Given this and other public statements, it seems that the review is likely to lead to changes to the PIP descriptors, activities or qualifying rules.

The exercise is to be led by Sir Stephen Timms, Minister for Social Security and Disability, and began on 12 May. The Green Paper says that it ‘will take time and require extensive engagement, so any changes to the PIP assessment would only be introduced following the reforms set out in this Green Paper’ (emphasis added).

The review could revisit some of the suggestions floated in the Conservative government’s 2024 PIP Green Paper, such as using diagnosis to decide PIP eligibility; adding, removing or merging PIP activities; a review of the ‘prompting’ descriptors; or changing the 12-month PIP required period.12DWP, Evidence Pack: modernising support for independent living: the health and disability Green Paper, 13 June 2024 The Secretary of State stated in her March 2025 Green Paper speech that means testing PIP or paying it in vouchers have both been ruled out.

The Green Paper includes some other proposals without definite timescales. One of the most significant is the proposal to raise the age for claiming PIP from 16 to 18, which is currently open to consultation. While welcomed by some welfare rights advisers, this change is assessed by the DWP as a cut, which means that some young people are likely to lose out – eg, as a result of the more restrictive rules for the disability living allowance (DLA) higher rate mobility component compared with the PIP enhanced rate mobility component.
There are also undated plans to make practical changes to PIP and WCAs, which seem likely to take place in the next 12–24 months. The Green Paper promises that work capability reassessments will be resumed, and that for both PIP and WCAs, there will be a move towards a higher proportion of face-to-face assessments, compared with the current 10 per cent. The Green Paper claims that this will be implemented ‘while ensuring we continue to meet the needs of our people who are claiming, who may require a different method of assessment – eg, due to the need for a reasonable adjustment’.

The Green Paper also suggests that audio-recording of assessments may be introduced as standard, replacing the current opt-in system, after years of recommendations from external bodies.13See CPAG, Health Assessments for Benefits: an analysis of the government’s response, 27 June 2023 In her speech to announce the Green Paper, Secretary of State Liz Kendall went further, saying that ‘we will ensure they are recorded as standard – to give confidence to claimants and taxpayers that they’re being done properly’ (emphasis added).

The Green Paper promised a new approach to safeguarding at the DWP, from 2025/26. There is likely to be more detail in the DWP’s response to the Work and Pensions Committee’s May 2025 safeguarding report.

Other Green Paper proposals include that the DWP reduces the initial PIP assessment requirement for, and improves communication with, claimants with the most severe and unchanging conditions – and that the DWP introduces new ways of accessing and collating medical evidence.
There were also some announcements that went beyond benefit policy: for example, the Green Paper promised extra spending on ‘employment, health and skills support’ and opened a consultation on the future of Access to Work.

The Green Paper proposals have provoked widespread concern for seeking to cut financial support from those who need it most, largely without consultation. Official claims that the overall package of changes will increase disabled people’s access to paid work, and so mitigate the cuts, have been criticised for a lack of evidence.14And undermined by some of the DWP’s own research – see, for example, DWP, The Experience of Additional Work Coach Support: findings from qualitative interviews with customers, 2 May 2025. See also Resolution Foundation, Report: No work-around, 20 May 2025. Advisers bracing for the changes may wish to have their say – through the consultation closing on 30 June, through their MP, or by joining efforts coordinated by Disability Rights UK, the Disability Benefits Consortium and others.