Pathways to Work: the government's response to the consultation

On 30^th October 2025, the Labour government released its response to the consultation on the Pathways to Work Green Paper 2025. The government received nearly 15,000 direct responses (i.e. responses that directly answered the questions posed by the government in the consultation) and over 33,000 indirect responses. The large majority of these indirect responses came from “a single campaigning platform, which put 2 surveys asking its own questions to its members.” Individual questions received between 5,600 and 12,500 responses each, with most receiving between 6,000 and 9,000 responses.

Responses to the consultation questions showed disagreement with the government’s key proposals. This is despite the fact that the government was deliberately not asking for comment on its key proposals. Nevertheless, disabled people and representative organisations took the opportunity to give answers to questions that the government should have asked, not just those which it did ask.

The limits of qualitative analysis

It is always difficult to analyse text-based responses. When I have done coding before, I would read through all the answers three times before even starting to think about common themes. On the fourth read through, I would highlight key phrases in each answer. Based off that, I would come up with major themes, and on the fifth read through, I would code the highlighted phrases by theme. On the sixth read through, I would break those themes down into sub-themes. In practice, steps 5 and 6 can be iterative, with sub-themes being refined, redefined, combined, or split; each of which requires going back over previously-coded text to fit a new system.

This is a hugely time-consuming process and takes a lot of brain power. In my experience, human text rarely has neat one-to-one maps with clear themes. There are fuzzy boundaries, overlaps, and ambiguities. The themes that one researcher identifies may not be how another researcher would group the same text. The more answers there are, the more information has to be held in one’s working memory. Each highlighted phrase has to be compared to all the other phrases to decide which theme it belongs to. It is not easy.

Having done all that effort, one still can’t say “X% of people think that Y is a concern”, based on X% of people mentioning Y as a concern. All the people who didn’t mention Y may also think that Y is a concern, but they didn’t think to mention it in a free-text response. This is particularly the case when Y isn’t even a direct answer to the question, but is a comment on the question itself or on wider issues.

Text-based answers may give an indication of the relative importance of different issues, but even then it is only indicative. There might be a highly important issue which the typical person wouldn’t come up with in an unprompted response, but if they were told about it they would immediately grasp its importance. Or there might be a minor issue which has received a lot of public attention and is therefore readily thought of in response to a question, but in practice it isn’t all that important. It’s just salient.

The value of qualitative responses is in the extra information given compared to quantitative responses, and in generating new lines of research. For the government, this should mean that where there were pushbacks to policy that the government was deliberately not consulting on, this should be taken seriously and explored in more depth.

Labour’s key proposals, and responses to them

Labour had proposed to introduce an additional criterion to PIP Daily Living, that at least one activity must score at least four points for a person to receive a PIP DL award. This proposal was not implemented in the summer 2025 legislation due to major opposition from MPs. In the consultation, the question (Q2) was not whether or not to implement this proposal (the consultation assumed it would go ahead), but what support to give people who score 8 or more points on PIP DL activities but who don’t score at least 4 in a single activity. Despite the government not asking about the change itself, respondents said that the PIP criteria should not be changed. Respondents were concerned about the impact on financial hardship, employment, independence, and mental health if such a change were introduced.

“It is misguided to assume those with lower scores have less need; scoring low points across multiple activities often reflects the complexity of someone’s condition.” Centre for Care

“The government should abandon its plans to introduce new eligibility criteria for the Personal Independence Payment (PIP). PIP is not an out of work benefit and the new additional requirement will not support disabled people into work, it will just push more people into poverty and destitution.” The Equality Trust

“UNISON is opposed to the proposal to raise the daily-living threshold (4-point rule) because it would strip necessary support from many disabled workers. The priority must be to abandon this change.” UNISON

It is perhaps disingenuous of the government to say that “many responses called for … reforming the Personal Independence Payment (PIP) assessment process.” It is important, when commenting on calls for change, to note in what direction people want the change to go. The government did not consult on the major change of making PIP DL harder to get, yet many people responded by saying that this change should not be made. Sick and disabled people want PIP to be reformed so that it adequately reflects the level of need of many people who are currently excluded, whereas the government wants to exacerbate the exclusion.

The government did not consult at all on cutting the UC Health Element from £97/week to £50/week. This change was implemented in summer 2025. There was no related question in the consultation that would have provided space for people to object to this cut.

The government wants to scrap the Work Capability Assessment, which assesses a person’s capability for work and determines how much Social Security they get and what, if any, requirements can be put on them as a condition of their benefit receipt. This measure was not consulted on. However, the government showed its awareness of the problems that this measure will cause by consulting on those problems in questions 7-10. These questions asked how the government should determine work-search and work-related activity requirements once the government has scrapped the process for determining those requirements.

Respondents said that there should be an individualised, person-centred assessment carried out by a medical expert. People who have Limited Capability for Work-Related Activity – a designation that is dependent upon the WCA, and which the government wants to scrap – should not be required to take part in government-mandated activity as a condition of their benefit receipt. In essence, respondents said that the principle of a person being treated as too sick or disabled to work should be retained, for people who can reasonably be said to have ‘limited capability for work-related activity’. Necessarily, this means retaining a system for assessing a person’s capacity for work and work-related activity.

Where ‘conversations’ do take place, they should be voluntary, supportive, and able to take into account wider issues such as caring responsibilities. There was concern about the stress caused by mandatory activity and the undermining of trust in staff who would deliver that activity. Again, this means that some form of assessment of capacity for work and capacity for benefit conditionality is an important part of a Social Security system.

“It should not be a backdoor method of enforcing conditionality.” Centre for Care

“We do not support making “support conversations” a condition of receiving benefits. People with disabilities, health conditions, and caring responsibilities should be exempt from any mandatory form of participation.” Equality Trust

“UNISON opposes making the support conversation a condition of benefit.” UNISON

Without carrying out an analysis of the government’s response to the consultation, let alone the responses themselves, it seems to me that common responses across the different questions include: increase the support available to sick and disabled people, including PIP, UC HE, and Access to Work; ensure that appropriate assessments for both extra-cost and work-incapacity benefits are in place; and do not apply conditions to benefit receipt for sick and disabled people. The likelihood of the government agreeing with any of these recommendations, however, seems low.