Consultation Response
WBG’s Response to the Pathways to Work Green Paper
We have responded to government's Pathways to Work: Reforming Benefits and Support to Get Britain Working Green Paper
The testimonies of Disabled women included throughout the response to this consultation have been drawn from WBG’s and Sisters of Frida’s June 2025 briefing: “Impact of Disability Benefit Changes on Disabled Women” 1 .
Women are the majority (56%) of Disabled people in the UK: 27% of women (9.3 million) are disabled, compared to 7.4 million or 22% of men 2 .
Disabled women face significant barriers in the job market, leading to lower earnings. While the rate of employment of Disabled women is similar to that of Disabled men (54%), it is significantly lower to that of non-Disabled women (71.8%) 3 . Disabled women are more likely to be in low pay than Disabled men (19% and 13%, respectively) 4 , compared to 9% of non-Disabled men, and they earn on average £7,300 per year less than non-disabled men 5 . The combined disability gender pay gap stands at 31%, compared to 17.2% for the disability pay gap 6 and 7% for the gender pay gap (for full-time employees) 7 .
Disabled women face dual discrimination and greater barriers to the labour market, meaning they rely more on benefits.
Disabled people face higher costs for a similar standard of living, an average of £1,010 extra per month 8 . This reflects the additional healthcare and medical costs, transport, mobility and adaptability costs, higher housing costs (such as more expensive water and energy bills), and the cost of care.
Around 70% of unpaid carers report having a long-term physical or mental health condition, disability or illness, and 59% of unpaid carers are women 9 . Disabled women often also have specific costs related to caring for others, as well as childcare costs.
The combination of higher day-to-day costs and labour market barriers means that Disabled people are more likely to live in poverty. Nearly half of everyone living in poverty is either a Disabled person or living with a Disabled person 10 . Around 23% of Disabled people are living in poverty after housing costs, compared to 20% of non-Disabled people 10 . Poverty outcomes are worse for women living in council housing, single mothers and Black, Bangladeshi or Pakistani women 11 .
In addition, WBG’s analysis of the cumulative impact of cuts to public services and social security and changes to taxation since 2010 has shown that the on-and-off freeze on working-age benefits was the primary driver of income loss for women since 2010. Disabled women have lost on average, around 11% of their living standards, equivalent to £4,000 per year, compared to 5% for non-Disabled men 12 .
In this context, and despite the challenges in access and current insufficient rates (see the 2023 APPG on Poverty and Inequality report on the inadequacy of disability benefits 13 ), social security provides crucial protection from poverty. Citizen’s Advice has found that the Disabled people they support are 12% more likely to be in a negative budget if they are not in receipt of PIP 14 . The Joseph Roundtree Foundation (JRF) similarly report that newly Disabled people who start to receive PIP have half the rate of entry into very deep poverty than those who do not 15 . As well as alleviating and preventing poverty, it is important to note that social security benefits also have a redistributive function, promoting equality and the anti-marginalisation of Disabled people.
Disabled women are at double the risk of VAWG as non-disabled women (12.7% compared to 5.1%) 16 . For Disabled women it can be harder to leave an abusive relationship: sometimes the abuser is also the caregiver. The type of violence suffered is often related to their condition, including the withholding of medicine and food, or non-provision of help for other personal needs 17 and it often involves financial coercion, including withholding and/or control of disability benefits.
Women from minority-ethnic groups, are at a higher risk of violence, while facing additional barriers in reporting to the police. This is particularly true for women from a mixed ethnic group (7.1%) and Black Caribbean women (7.7%), compared to White women (5%) 18 .
Availability of accessible accommodation is also crucial in Disabled women’s decision to leave an abusive relationship 19 .
Gendered impact of changes outlined in the Green Paper
In the Pathways to Work Green Paper and the March 2025 Spring Statement, the Government proposed major reforms to disability and sickness-related benefits. The main changes outlined, which are not up for consultation, include:
- restricting PIP eligibility to those who score a minimum of four points on at least one of the daily living activities,
- abolishing the Work Capability Assessment (WCA) for the UC ‘health’ element, instead using a single PIP assessment to determine access for financial support in PIP and any extra support through UC,
- freezing of Universal Credit ‘health’ element and halving it for new claimants,
- increasing the Standard Allowance of UC to raise it above inflation by 2029/30,
- switching back on WCA reassessments.
These changes will disproportionately impact women. The extent of the impact is unclear and has not been adequately assessed through a comprehensive Equality Impact Assessment. Additional figures sourced through the Freedom of Information (FOI) Act estimate that of the 1.32 million people estimated to lose their PIP due to these reforms, 62% are women 20 .
WBG and Sisters of Frida (2025) Impact of disability benefit changes on Disabled women
DWP (2025) Family Resources Survey: financial year 2023 to 2024
UK Parliament (2025) Women and the UK Economy. The Labour Force Survey on which headline labour market figures are based, is less reliable than usual and employment rates for Disabled people are particularly unreliable.
DWP (2024) The employment of disabled people 2024
TUC (2024) Disability Pay Gap
TUC (2024) Disability pay gap reaches staggering level of £4,300 a year
ONS (2024) Gender pay gap in the UK: 2024
Scope (2024) Disability Price Tag 2024
Carers UK (2025) Key Facts and Figures About Caring
DWP (2025) Households Below Average Income
WBG (2024) Where do we go from here? An intersectional analysis of women’s living standards since 2010
APPG Poverty and Inequality (2023) Inadequacy of Social Security
Citizen’s Advice (2025) Pathways to Poverty: How planned cuts to disability benefits will impact the people we support
JRF (2023) What protects people from very deep poverty, and what makes it more likely?
ONS (2024) Crime Survey England and Wales, Table 6: Prevalence of domestic abuse in the last year among people aged 16 years and over, by personal characteristics and sex
Women Enabled International and Sisters of Frida (op. cit.)
Crime Survey England and Wales (2024) Domestic abuse prevalence and victim characteristics, England and Wales: year ending March 2024, Table 6. Prevalence of domestic abuse in the last year among people aged 16 years and over, by personal characteristics and sex, England and Wales, year ending March 2024
EHRC (2018) Housing and disabled people: what should local authorities do?
DWP (2025) FOI request FOI2025/25982