Annual Report and Accounts for year ended 2024-25

2.1 Overview

The Performance Report describes the Scottish Commission on Social Security’s—

• Purpose: its main statutory roles and its membership
• Performance: how well it exercised its functions, performed its statutory roles and contributed towards improving the system for social security in Scotland
• Continuous improvement: the steps the SCoSS Board has taken to ensure its work can be as effective as possible
• Risks that could affect SCoSS’s performance and the action taken to mitigate them
• Strategies and governance: the strategies SCoSS has agreed to ensure strong governance
• The Chairs’ statement and overview of the performance report also form part of the Performance Report.

Purpose and Structure

The Scottish Commission on Social Security (SCoSS) is an independent public body established by the Social Security (Scotland) Act 2018 (‘the 2018 Act’). It provides expert advice to Scottish Ministers and the Scottish Parliament on devolved social security matters.

The 2018 Act sets out the functions of SCoSS which can be summarised as follows—

1. SCoSS must be consulted by the Scottish Government on most regulations about social security assistance made under the 2018 Act. SCoSS scrutinises and reports on draft regulations. The Scottish Government may change its regulations after considering SCoSS’s recommendations. When it lays the regulations in the Scottish Parliament, it must publish its response to SCoSS’s report at the same time. The Scottish Parliament’s Social Justice and Social Security Committee then scrutinises the regulations and may take evidence from SCoSS members when it does so.
2. SCoSS must report, from time to time, to Scottish Ministers and the Scottish Parliament on whether the expectations in the Scottish Social Security Charter (‘Our Charter’) are being met and make recommendations for improvement if they are not. It must consider reporting if it receives evidence that the Charter expectations are frequently not being fulfilled.
3. In addition, Scottish Ministers and the Scottish Parliament can ask SCoSS to report on any matter relevant to social security.

In undertaking its statutory duties, SCoSS takes full account of the social security principles contained within the 2018 Act and of relevant human rights obligations as defined by the 2018 Act.

SCoSS Board members are non-executive public appointments made by the Scottish Ministers in line with the Code of Practice for Ministerial Public Appointments in Scotland. The 2018 Act allows up to five Commissioners to be appointed. The Chair is responsible for providing leadership to ensure that the Board delivers its functions efficiently and effectively. The Chair is also accountable to the Scottish Ministers. The role of Board members is to provide direction, support and guidance to ensure that SCoSS delivers its functions effectively and efficiently, in accordance with the 2018 Act. SCoSS members were originally appointed for periods of three or four years. Members may devote up to 36 days a year to perform their functions, apart from the Chair, who may devote up to 60 days per annum. SCoSS is supported by a secretariat employed by the Scottish Government.

As noted in last year’s annual report, Judith Paterson and Dr Mark Simpson were appointed as Interim Co-Chairs in August 2023 until 31 July 2024. At the same time, a temporary Board Member, Dr Jackie Gulland, was appointed to the Board by the Cabinet Secretary for Social Justice with the term of appointment also ending on 31 July 2024. Following a successful recruitment exercise, the Cabinet Secretary appointed Ed Pybus as Chair and Adam Bennett as a Member of the Commission with both terms of appointment starting on 1 August 2024. On 1 August 2024, Judith Paterson and Dr Mark Simpson reverted to their original positions as Members of the Commission. Accordingly, since August 2024 the Board has consisted of a Chair and four permanent members. References to the Board in this report refer to the Board as from 1 August 2024.

During the course of the reporting year, SCoSS scrutinised and reported on nine draft regulations. The Commission established a Charter Sub-Committee, which met for the first time in April 2024, and supported the Commission’s scrutiny of the operation of the Social Security Charter in line with the Commission’s statutory function in this regard. The Commission produced its first report under this statutory function, considering the experience of people with communication needs who had engaged with the devolved social security system, in March 2025.

SCoSS has held eleven Board meetings during the reporting period as well as a number of ad-hoc meetings. Ad-hoc meetings tend to be held to consider draft scrutiny reports or to undertake line-by-line scrutiny of draft regulations in order to ensure that scrutiny deadlines are met.

In 2024-25, all Board meetings were conducted virtually with the exception of the November Board meeting which was held at the Scottish Government building at Atlantic Quay in Glasgow. To ensure that all Commission decision-making and proceedings are transparent, the minutes of all formal SCoSS Board and Sub-Committee meetings are published on the SCoSS website. All SCoSS scrutiny reports and corporate documents are also available on the SCoSS website.

SCoSS’s vision and strategic objectives

The SCoSS Business Plan 2024-25 set out the vision, strategic objectives and key priorities for the reporting period. The SCoSS Board reviews progress, on a quarterly basis, against the objectives and priorities set out in the Business Plan and this is considered later in this report. The vision set out in the 2024-25 Business Plan was—

“We want a robust, effective, efficient Scottish social security system that meets its full potential to improve outcomes for the people of Scotland. We want to help achieve this by providing independent expert advice”.¹SCoSS Business Plan 2024-25, p.4.

Governance

The 2018 Act provides the legislative basis for SCoSS.  As an advisory Non-Departmental Public Body (NDPB), the SCoSS Framework Document sets out the broad framework within which SCoSS operates and defines key roles and responsibilities which underpin the relationship between SCoSS and the Scottish Government. SCoSS Standing Orders govern the operation of the Board and the Audit and Charter Sub-Committees. SCoSS adheres to best practice principles and relevant guidance regarding corporate governance, primarily as set out in ‘On Board: a guide for members of statutory boards’. The Audit Sub-Committee provided oversight of SCoSS finances and governance. The Board also considered the Commission’s budgetary position and risk register on a quarterly basis.

The Commission’s ‘Framework Document’ sets out the broad framework which the Commission operates within specifically with regard to the Scottish Government. The framework document was updated and, following approval from the Cabinet Secretary for Social Justice, published in June 2024.

The Social Security (Amendment) (Scotland) Act received royal assent on 23 January 2025.  The 2025 Act provides for the extension of the scrutiny remit of the Commission as well as removal of the body corporate status of the Commission and the requirement to produce externally audited annual reports and accounts. The 2025 Act replaces this latter requirement with a duty to publish an annual report.  Regulations giving effect to the provisions of the 2025 Act came into force on 10 May 2025²The Social Security (Amendment) (Scotland) Act 2025 (Commencement No. 1 and Saving and Transitional Provisions) Regulations 2025.

In terms of the Secretariat staffing complement, the 2023-24 annual report noted the decision not to fill a vacant post. Accordingly, in 2024-25 the Secretariat consisted of five members of staff. In December 2024, the Analysis and Participation Officer post within the Secretariat became vacant. As a result, the Secretariat consisted of four members of staff from December 2024 to the end of the reporting period.

Overall Performance

During the reporting period, SCoSS reported on all draft regulations that were referred by Scottish Ministers. Therefore, SCoSS performance met expectations over the reporting year. Further information on our performance is detailed below.

Within the reporting period of these accounts, SCoSS produced nine substantive reports on draft regulations.

During 2024-25, SCoSS made 53 recommendations to the Scottish Government. Four reports were submitted to the Scottish Government in the last quarter of 2024-25 and responses to three of these reports are expected later in 2025. Due to changing circumstances no response was required from the Scottish Government to our letter in respect of the Winter Heating Assistance (Pension Age) (Scotland) Regulations 2024 which did not include any recommendations.

In the remaining five reports which the Scottish Government has responded to in 2024-25, SCoSS made 34 recommendations of which 22 (65%) were accepted, five (15%) partially accepted and five (15%) rejected. A further two recommendations (5%) were considered not applicable because of changes in Scottish Government policy in the intervening period. SCoSS made a further six observations. SCoSS appeared before the Social Justice and Social Security Committee once in May 2024 to discuss the Pension Age Disability Payment regulations.

Best Value

The principles of best value are firmly embedded across all of SCoSS’s operations. Instead of reporting best value against specific projects and initiatives, we look at best value holistically.

2.2 Analysis of SCoSS’s performance

The objectives and priorities for the year were set out in the SCoSS Business Plan 2024-25. Performance against the strategic objectives and priorities in the Business Plan is considered below.

Strategic Objectives

Strategic Objective One – We will provide expert, independent and evidence-based scrutiny of draft social security regulations that is driven by the social security principles and human rights.

This approach has been taken to scrutiny of all nine sets of draft regulations in 2024-25 ensuring that the social security principles and equalities and human rights are central to scrutiny. These issues have, subsequently, been central to each scrutiny report.

In the course of producing scrutiny reports, the Commission has provided detailed insight as a result of the expertise provided by Commissioners and frequently drawn on feedback from stakeholder evidence in interpreting the technicalities of social security legislation at a practical level. Where appropriate, reports have detailed the relationship between the regulations and existing human rights laws. In addition, during 2024-25, the Commission would explicitly scrutinise a draft set of regulations via the use of a scrutiny template which provided for scrutiny of the draft regulations through the lens of the social security principles.

For example, our response to the draft Disability Assistance (Scottish Adult Disability Living Allowance) Regulations 2024 recommended that the Scottish Government monitor and consult with stakeholders on the potential impact on people in situations where they cannot reinstate entitlement to Scottish Adult DLA, in order to help meet the social security principle of continuous improvement. In response, the Scottish Government accepted the requirement to continue to monitor these provisions.

Meanwhile, our report on the draft Winter Heating Assistance (Pension Age) (Scotland) Regulations 2024 recommended that the Scottish Government should give consideration to the aims of the Public Sector Equality Duty and collect further relevant data to inform longer-term development of Pension Age Winter Heating Payment, as part of ongoing revisions of its equality impact assessment. The Scottish Government accepted this recommendation, highlighting that the three aims of the Public Sector Equality Duty would continue to inform its ongoing evaluation of the impact of the benefit.

Strategic Objective Two – We will provide independent challenge and advice on whether people are getting the service from the social security system that the Social Security Charter says they should expect.

Scrutinising whether the expectations set out in the Social Security Charter are being met informs all SCoSS scrutiny. Accordingly, assessing progress in ensuring people are obtaining the service the Charter says they should expect is a regular feature of our scrutiny reports.

The Commission established a Charter Sub-Committee which met for the first time in April 2024 and on a total of ten occasions in 2024-25. In March 2025, the Commission published a report on ‘people with communication needs and the Scottish social security system: fulfilling the expectations of ‘Our Charter’. This represents the Commissions’ first report, since the establishment of SCoSS, meeting the statutory requirement to report from time to time on whether the expectations in the Charter are being met. The report represented the culmination of a substantial scrutiny process undertaken by the Charter Sub-Committee in 2024-25. It is anticipated that the work of the Charter Sub-Committee will be an expanding area of the Commissions’ scrutiny in 2025-26 and subsequent years.

Strategic Objective Three – We will work alongside Scottish Ministers, the Scottish Government and the Scottish Parliament as well as other key stakeholders, such as people with lived experience, to ensure our work constructively supports the development of a Scottish social security system based on dignity, fairness and respect.

In May 2025, we published our first ‘Stakeholder Engagement Strategy’. The strategy outlines objectives and priorities to ensure the involvement of a variety of stakeholders in the work of SCoSS with the aim of effective, appropriate and consistent engagement.

SCoSS has continued to develop external engagement with stakeholders, including people with lived experience, in undertaking scrutiny of draft regulations in 2024-25. For example, ten organisations attended a roundtable discussion in January 2025 offering views that supported our response to the draft Carer’s Assistance (Young Carer Grant and Carer Support Payment) (Miscellaneous Amendment and Saving Provision) (Scotland) Regulations 2025. It is anticipated that our approach to stakeholder engagement will be further adapted based on such events.

As noted above, external engagement was also central to the work of the Charter Sub-Committee in the development of a report on people with communication needs. In the course of this work, we gathered first-hand views from over 70 people and direct quotes were used throughout our report highlighting key areas of interest raised in focus groups with people with communication needs themselves and structured interviews held with representatives of organisations with a specific interest in the experiences of people with communication needs. Stakeholder engagement is expected to continue to be an on-going feature of the Sub-Committees’ scrutiny work in 2025-26.

SCoSS has sought to develop constructive relationships with Scottish Government officials and sought feedback from officials on the impact of all our scrutiny work.  Commissioners provided oral evidence once on our scrutiny reports to the Social Justice and Social Security Committee in 2024-25.

Strategic Objective Four – We will make engagement with people with lived experience of the Scottish social security system and engagement with other stakeholders central to our scrutiny.

SCoSS has continued to develop engagement with relevant external stakeholders and with people with lived experience of the devolved social security system across a range of scrutiny of draft regulations in 2024-25, for example engaging ten organisations in a roundtable discussion in January 2025 on the draft Carer’s Assistance (Young Carer Grant and Carer Support Payment) (Miscellaneous Amendment and Saving Provision) (Scotland) Regulations 2025, as well as taking written evidence from other organisations.

Engagement with people with lived experience has also been central to the work of the Charter Sub-Committee. For example, in 2024-25, the Sub-Committee worked closely with ENABLE, the Health and Social Care Alliance Scotland and Young Scot to host a series of focus groups with people with communication needs to consider their experiences of the social security system. In total, we met around 70 people and their views and experiences were built directly into the report published in March 2025.

In order to promote its charter research report among stakeholders, SCoSS hosted a webinar on 12 May 2025. This was addressed by the Chair and SCoSS members who shared the research background and how it was undertaken, as well as findings and recommendations. Fifty-six stakeholders joined the event, with attendees from across the Scottish Government, Social Security Scotland, other Commissions and third sector organisations. The webinar has also been made available through SCoSS’s YouTube channel to allow for further engagement from stakeholders.

Strategic Objective Five – We will be transparent about how we make our decisions and make our information accessible and inclusive.

The Minutes of all SCoSS Board and Sub-Committee meetings are published on the SCoSS website and promoted via Twitter / X. All SCoSS scrutiny reports and corporate documents are available online. We have sought to promote the work of SCoSS via a quarterly newsletter to external stakeholders who have expressed an interest in receiving information about the work of SCoSS. Currently, we have 49 external stakeholders signed up to receive the newsletter and 4,718 followers on Twitter / X.

Strategic Objective Six – We will make the improvements to how we work that were recommended by the independent review of SCoSS, making sure we can deliver statutory functions within our budget.

The Improvement Plan, agreed following the independent review of SCoSS, has continued to be implemented during 2024-25. A revised Framework document setting out the relationship between SCoSS and the Scottish Government was published in June 2024. A review of all corporate documentation was concluded in April 2025. Recruitment to the SCoSS Board was completed in August 2024 including the appointment of a new Chair.

The Social Security (Amendment) (Scotland) Act 2025 received royal assent in January 2025. Secondary legislation giving effect to the provisions relating to the Commission came into effect on 10 May 2025. As a consequence, we will review the Framework Document in 2025-26 to take account of the new governance structure of the Commission and review and simplify our governance structures more generally.

The SCoSS budget allocation for 2024-25 was £450K. However, the budget allocation letter included provision for a mid-year finance review to review the in-year finance position and year-end projections. This review was completed in October 2024 and highlighted forecast budget pressures in 2024-25. Accordingly, the Accountable Officer proposed that the SCoSS budget allocation be revised to £480K. The SCoSS Board agreed a revised budget allocation letter in October 2024. The Commission delivered its statutory functions within the allocated budget in 2024-25.

Priorities

Scrutiny of draft social security regulations

We will undertake expert, independent, evidence-based scrutiny of draft regulations referred to us by the Scottish Government, including—

• Draft Scottish Adult Disability Living Allowance Regulations
• Draft Funeral Expense Assistance Regulations
• Draft Pension Age Winter Heating Payment Regulations
• Draft Up-rating Regulations
• Draft regulations following from the parliamentary passage of the Social Security (Amendment) (Scotland) Bill.

We will review our scrutiny processes to improve efficiency and make sure that reports and recommendations are clearly founded on human rights and the Scottish social security principles.

SCoSS has scrutinised and reported on all draft regulations referred to SCoSS within agreed timescales. The draft regulations scrutinised in 2024-25 were—

• Funeral Expense Assistance (Scotland) Amendment Regulations 2024;
• Disability Assistance (Scottish Adult Disability Living Allowance) Regulations 2024;
• Winter Heating Assistance (Pension Age) (Scotland) Regulations 2024 and a further response we produced to a second set of draft Winter Heating Assistance (Pension Age) (Scotland) Regulations 2024 (which were subsequently not enacted);
• Social Security (Up-rating) (Miscellaneous Amendments) (Scotland) Regulations 2025;
• Social Security (Best Start Grants, Best Start Foods, Funeral Support Payment, Scottish Child Payment and Winter Heating Payment) (Miscellaneous Amendment) (Scotland) Regulations 2025;
• Carer’s Assistance (Young Carer Grant and Carer Support Payment) (Miscellaneous Amendment and Saving Provision) (Scotland) Regulations 2025 and a further response on an additional provision subsequently included in the Carer’s Assistance (Young Carer Grant and Carer Support Payment) (Miscellaneous Amendment and Saving Provision) (Scotland) Regulations 2025; and
• Social Security (Cross-border Provision, Case Transfer and Miscellaneous Amendment) (Scotland) Regulations 2025.

Accordingly, we have formally reported on nine sets of draft regulations in 2024-25.  We anticipate that scrutiny will be required, in 2025-26, for draft regulations arising from the parliamentary passage of the Social Security (Amendment) (Scotland) Act 2025.

In 2024-25, the Scottish Government accepted 22 out of 34 of SCoSS recommendations in 2024-25 to which it has responded to date. The Scottish Government also partially accepted 5 out of 34 recommendations made by the Commission.

We also provided informal commentary on proposed regulations to support the delivery of free school meals to Primary Six and Seven pupils in receipt of Scottish Child Payment.

The SCoSS Board regularly reviews its approach on conclusion of any scrutiny process, with time taken at Board meetings to consider improvements. Commissioners successfully trialled, in 2024-25, a more structured approach to consideration of the social security principles in relation to draft regulations as part of consideration of the original Draft Pension Age Winter Heating Payment Regulations and this has been adapted for other scrutiny processes.

Social Security Charter

• We will expand the ways we learn directly from stakeholders and people with lived experience on whether people are getting the service that the Social Security Charter says they should expect.
• We will report on improvements that the Scottish Government could make to better deliver commitments in the Charter.

In 2024-25, SCoSS undertook research with people with communications needs on their experiences of the social security system in Scotland in the context of commitments made in the social security charter. This provided an opportunity to expand our approach to learning directly from stakeholders and people with lived experience. In particular, with support from third sector organisations, SCoSS has hosted focus groups and undertaken direct interviews which have sought to gather their views and reflect on their experiences. Feedback from events is considered on an ongoing basis to consider where improvements can be made.

The Commission published a report on the experience of people with communication needs during 2024-25. This report represents the Commission’s first report, since our establishment in 2019, on whether the expectations contained in the Social Security Charter are being delivered and improvements that could be made.

Work alongside Scottish Ministers, the Scottish Government, Scottish Parliament and key stakeholders.

• We will develop a longer-term work programme, which we will share with Scottish Ministers and the Scottish Parliament, with a framework for dealing with requests for reports on social security that may be requested from us.
• We will engage proactively with, and when requested provide evidence to, the Scottish Parliament’s Social Justice and Social Security Committee.
• We will hold workshops with Scottish Government and Social Security Scotland staff to improve the shared understanding of the role of SCoSS as our remit expands under proposals in the Social Security (Amendment) (Scotland) Bill.

The Commission considered, in 2024-25, developing a longer-term work programme. However, we recognised that given we have a very limited awareness of forthcoming draft regulations in the medium term that developing such a programme is problematic. Accordingly, we do not consider that it is feasible to develop a longer-term work programme at present.

Commissioners have provided evidence to the Scottish Parliament’s Social Justice and Social Security Committee when requested. In 2024-25, the Committee took oral evidence from us on The Disability Assistance for Older People (Scotland) Regulations 2024.

All scrutiny reports are proactively shared with the Committee including our charter research reports.

An extension to the SCoSS remit, as proposed in the Glen Shuraig review recommendations, is contained within the provisions of the Social Security (Amendment) (Scotland) Act 2025. The Chair has held, and will have further, discussions with Scottish Government and Social Security Scotland staff to improve the shared understanding as to the role and remit of SCoSS, following the commencement regulations giving effect to the relevant provisions of the 2025 Act having come into force.

Stakeholder engagement

• We will implement our updated stakeholder engagement strategy which includes embedding lived experience within our scrutiny work.
• We will gather feedback from Scottish Government, Scottish Parliament and all stakeholders who contribute to SCoSS scrutiny.
• We will engage with the wider policy community to gather feedback on the impact of SCoSS scrutiny work.

The Commission agreed a Stakeholder Engagement Strategy early in 2024-25 which is being implemented and includes ensuring that lived experience is at the heart of our independent advice. To date, implementation of the strategy has largely been embodied by charter research work which, as detailed above, has enabled us to directly engage with a range of people with experience of the social security system.

Feedback is proactively sought from officials following each scrutiny process through a survey of officials and this information is used to consider our approach to future scrutiny of draft regulations. Improvements to date have included the introduction of regular meetings between the Secretariat and officials during the scrutiny period and changes to our ‘Engaging with SCoSS’ document, further explaining the role officials play in supporting effective scrutiny.

The SCoSS Secretariat attended the Child Poverty Action Group Scotland conference in June 2024 and received positive feedback from Scottish Fiscal Commission and Scottish Parliament officials on the impact of SCoSS reports and our approach to communication.

Since August 2024, the Chair has initiated a process of engagement with the wider policy community, including the Scottish Human Rights Commission, the Poverty and Inequality Commission and the Social Security Advisory Committee to consider our respective roles and ongoing working relationships. The Chair also met with organisations providing direct advice and support to clients of Social Security Scotland to strengthen our relationships with these groups and learn more directly from individuals’ experiences.

SCoSS sought to engage with stakeholders in the promotion of its charter research report on the experiences of people with communication needs of the Scottish social security system, including hosting a webinar on 12 May 2025. The event, which placed priority on ensuring accessibility among stakeholders (including through the provision of a sign language interpreter and an option to watch later) was attended by 56 people from across the Scottish Government, Social Security Scotland, various Commissions and third sector organisations.

Transparency and accessibility

• We will publish all Minutes of SCoSS Board meetings, Sub-Committee meetings and scrutiny reports on the SCoSS website.
• We will improve the accessibility of the SCoSS website.
• We will make sure that we engage with stakeholders in an inclusive way.

The minutes of all Board, Audit and Charter Sub-Committee meetings and all scrutiny reports were published on the SCoSS website in 2024-25. The Secretariat continues to monitor if there are ways to improve the accessibility of the website. Measures have previously been taken to improve the accessibility of the website and documents are provided in HTML and PDF formats and in alternative formats if requested.

SCoSS utilises ‘X’ (formerly Twitter) to promote all minutes of meetings and scrutiny reports. The SCoSS account has 4,718 followers on that social media platform. We also provide a quarterly newsletter to 49 individuals and stakeholder organisation that have signed up to receive the newsletter.

A key tenet of the aforementioned Stakeholder Engagement Strategy is ensuring that we engage with stakeholders in an inclusive way. As part of our recent charter research work we engaged closely with third sector partners, including RNIB Scotland, the Health and Social Care Alliance Scotland (and its members) and Young Scot, to design focus groups with inclusive research methods. For example, we held three separate focus groups with people with hearing loss in order to support different types of communication support needed by these groups. During this process we have shared initial findings with people who have engaged with us and we produced British Sign Language versions of the final report.

Governance

• We will deliver on our corporate responsibilities, ensure that we create a sound governance framework and demonstrate value for money through our audited accounts.
• We will review governance, finance, performance and assurance framework and risk register on a quarterly basis at meetings of the Audit Sub-Committee.
• We will provide induction to new Board members and identify training opportunities for Members to support their role as a Board Member of an advisory NDPB.
• We will streamline our governance procedures as legal requirements on SCoSS for external audit are removed under proposals in the Social Security (Amendment) (Scotland) Bill.

SCoSS has completed the external audit process which provides evidence that a sound governance framework is in place and operational as well as demonstrating value for money via the externally audited accounts. The 2023-24 annual report and accounts was laid in the Scottish Parliament on 13 September. Audit Scotland’s 2023-24 Annual Audit report made one recommendation which has been implemented. A new framework document has been agreed in 2024-25. A review of all corporate documentation was completed in April 2025, including updating the Commission’s Code of Conduct and Standing Orders.

Governance, finance, performance and assurance framework and risk register have been reviewed at all Audit Sub-Committee meetings. The Board also considers finance updates and the risk register on a quarterly basis.

An induction programme was put in place for a new Chair and Board Member who joined SCoSS on 1 August which was completed at the end of 2024. This included undertaking training provided by the Scottish Government Public Bodies Unit for new Board members.

Lastly, we intend to streamline our governance procedures once commencement regulations to give effect to the provisions in the 2025 Act have come into force and the 2024-25 external audit process has concluded. There will be a substantial reduction in governance following the removal of ‘body corporate’ status and the requirement to undergo external audit. This process will require the agreement of a new Framework Document, in 2025-26, to reflect the new governance status of the Commission.

Finance

Our current budget provides funding to cover all expenditure associated with operating SCoSS within the guidance of an advisory Non-Departmental Public Body. The SCoSS Board is supported by a secretariat of Scottish Government civil servants. The secretariat, along with our operational costs and members’ fees, is funded from a Commission budget which is provided by the Scottish Government.

In 2024-25, the SCoSS Budget is £450,000. SCoSS will undertake a full mid-year review of its budgetary position in 2024-25, in what is anticipated to be a challenging financial environment.

SCoSS will fully comply with the requirements of external audit, undertaken by Audit Scotland, and will publish an Annual Report and Accounts which will also be laid in the Scottish Parliament.

SCoSS received, in April 2024, a budget allocation of £450K in 2024-25. The 2024-25 budget allocation letter was agreed by the Board in April 2024. The budget allocation letter included provision “to hold a mid-year finance review in October, with full support from the Sponsor Unit, to review the in-year finance position and year-end projections”³Scottish Commission on Social Security Budget Allocation letter 2024-25, p.2..

A mid-year review was undertaken jointly by the SCoSS Secretariat, Finance and Sponsor Unit and completed in October 2024. As a consequence the SCoSS Board and Accountable Officer agreed that the SCoSS budget allocation be revised to £480K in 2024-25.

SCoSS has fully complied with the requirements of the external audit process during the 2024-25 external audit process.

SCoSS scrutiny of draft regulations

In 2024-25, SCoSS produced nine substantive reports on draft regulations. Of the 34 recommendations made in these reports to which the Scottish Government has responded, 80% of SCoSS’s recommendations were accepted, at least in part, by the Scottish Government (65% of recommendations were agreed to and 15% were partially agreed to). This high rate of acceptance, by the Scottish Government of our recommendations, combined with the provision of oral evidence to the Social Justice and Social Security Committee, we consider to be indicative of a high level of impact resulting from our scrutiny work.

In undertaking scrutiny, SCoSS has not just made recommendations on the wording of draft regulations or on direct policy considerations, but has also considered the bigger picture. This reflects the fact that we are obliged to scrutinise draft regulations against the principles in the 2018 Act and these span the whole policy cycle from policy design through to continuous improvement.

This year, this has included the introduction of a new scrutiny template, explicitly highlighting the interaction between draft regulations, the social security principles⁴Social Security (Scotland) Act 2018, Section 1. and charter expectations.⁵Social Security Scotland, ‘Our Charter’. This has enabled SCoSS members to consider the broader impact of draft regulations and the consideration that has been given to them in the drafting of regulations when undertaking scrutiny. Each scrutiny report details these considerations.

Risks facing SCoSS

The SCoSS risk register is considered by the SCoSS Board on a quarterly basis following advice from the Audit Sub-Committee. The Audit Sub-Committee review the risk register at each meeting. Following the Audit Sub-Committee, the risk register is considered, including any changes proposed by the Sub-Committee, at the next meeting of the SCoSS Board.

Following the February 2025 meeting of the Audit Sub-Committee and subsequently the SCoSS Board, eight risks were identified and are reported upon in the risk register. These remained the risks contained in the risk register at the end of the reporting period and are detailed in the table below.

Finance report

In 2024-25, SCoSS was delegated a budget of £0.48m by Ian Davidson as the Accountable Officer. Last year’s annual report and accounts stated that—

“SCoSS has been delegated a budget of £450K in 2024-25. Given the pay awards made in 2023-24 and 2024-25, staffing costs will increase in 2024-25.  As of June 2024, forecast expenditure in 2024-25 is forecast to be £470K. The Audit Sub-Committee and Board are actively monitoring this position. As noted above, the Secretariat and Sponsor Unit will undertake a mid-year review of the financial position whilst the Secretariat and Scottish Government finance officials meet on a bi-monthly to monitor the budgetary position”.¹¹SCoSS, Annual Report and Accounts 2023-24, p.17.

As noted earlier in this report, the mid-term review resulted in the Accountable Officer and SCoSS Board agreeing a revised budget allocation of £0.48m.

At year end, SCoSS had spent £0.43m, a £0.05m underspend against the budget. This underspend was “re-absorbed” into the overall Scottish Government spend at year end.  It is worth noting that staffing costs have, in previous years, tended to account for the vast majority of SCoSS expenditure. This remained the case in 2024-25 when staffing costs accounted for 92% of SCoSS expenditure. For a full breakdown of SCoSS expenditure in 2024-25, please refer to Section 5 – Financial Accounts.

Forecast underspends presented to the Board during the reporting period tended to be higher than the end-year position. For example, the SCoSS Board was advised in February 2025 that expenditure in 2024-25 was forecast to be £444,796 as opposed to the end year position of £428,648. The level of underspend, against the allocated budget of £480K, reflected the impact of a staff vacancy in the Secretariat from December 2024 to the end of the reporting period. In addition, costs relating to the migration of the SCoSS website to Oracle Cloud in March 2025 were substantially lower than forecast.

In terms of the variation in the pattern of spend, the Secretariat staff costs were broadly similar to the previous year albeit lower than forecast due to a vacancy within the Secretariat from December 2024 to the end of the reporting period. Board member fees increased as a consequence of an increase in the size of the Board in August 2024 from four to five members. Overall, this resulted in staff costs, including Board member fees, that were slightly higher than the previous year.

Non-staff cost expenditure increased by just under £9,000 as compared to expenditure in 2023-24. This increase was primarily due to costs associated with Charter scrutiny work and the costs associated with the publication and promotion of the report. There was also an increase in website costs related to the migration of the website to Oracle Cloud. Due to the challenging overall financial position, the Scottish Government sought collective action to reduce expenditure throughout 2024-25. This resulted in a substantial reduction in ‘other expenditure’ during the reporting period.

Projects

No projects were undertaken in 2024-25.

Ian Davidson
Accountable Officer (Deputy Director, Social Security Policy)