The Social Security (Up-rating) (Miscellaneous Amendments) (Scotland) Regulations 2025: scrutiny report

Currently, some devolved assistance (such as disability and carer benefits) is being delivered under an agency agreement with the Department for Work and Pensions (DWP) until all clients in Scotland are transferred across to Social Security Scotland. During the period of the agency agreement, Scottish Ministers uprate these benefits in line with the DWP benefits (i.e. for April 2025, increases based on the September 2024 Consumer Prices Index (CPI) of 1.7%).

The Commission has commented, in previous years, on the use of the September CPI rate to determine the level of up-rating that the Scottish Government chooses to adopt.

In January 2024 the Scottish Government published a Multi-Criteria Decision Analysis (MCDA) to assess different measures of inflation. As we noted in last year’s uprating scrutiny report, SCoSS understands that this analysis was prompted by the high and volatile inflation of recent years in order to consider whether the best measure was being used.¹https://socialsecuritycommission.scot/wp-content/uploads/2024/01/Up-rating-2024-scrutiny-report.pdf We commended the MCDA process taken last year and recommended²Recommendation 3. The Scottish Government should conduct a further Multi Criteria Decision Analysis to inform its approach to the up-rating of social security payments following the completion of case transfer. that another analysis should be carried out to inform policy development on what the uprating policy should be after case transfer. The Scottish Government accepted this recommendation, which we welcome.

SCoSS further considers that this process should also include wider aspects of uprating policy as well as the measures adopted. As previously recommended³Recommendation 4. The Scottish Government should engage stakeholders with a range of expertise (including, but not necessarily limited to, the economy, social security, equality and poverty) to inform decisions on aspects of the next uprating Multi Criteria Decision Analysis such as criteria, weighting and options to be considered, and accepted by the Scottish Government⁴https://socialsecuritycommission.scot/wp-content/uploads/2024/01/Letter-from-Shirley-Anne-Somerville.pdf, it can be beneficial to involve a wide range of stakeholders in such a process to ensure that multiple perspectives are involved from the outset. This would also be consistent with social security principles (f) (designed with the people of Scotland on the basis of evidence) and (g) (to continuously improve the system in ways which (i) put the needs of those who require assistance first and (ii) advance equality and non-discrimination).

A future MCDA should also consider developments in alternative measurements of inflation.⁵See eg Joint paper from Royal Statistical Society, Citizens Advice and Financial Fairness Trust https://rss.org.uk/RSS/media/File-library/Policy/2024/CA-RSS-aFFT-paper-Measuring-household-inflation-FINAL.pdf

Recommendation Two: To inform policy decisions about uprating Scottish benefits once agency agreements with the Department for Work and Pensions  have ended, the Scottish Government should undertake a policy review, and a further multi-criteria decision analysis of options. This should consider whether there are any measures of inflation which more accurately reflect the effects of inflation on households in Scotland.