Vulnerable People Framework

The government agrees with the Inquiry that it is important to consider those most at risk in an emergency and to take specific steps to mitigate these risks as part of any future pandemic response.

The government has a number of guidance documents for identifying and supporting vulnerable people during a civil emergency. DHSC will undertake a review of the guidance to identify any gaps and establish a programme of work to better embed and consolidate the use of existing frameworks into decision-making.

Communicable disease outbreaks, including pandemics and emergencies, can amplify health, social, and economic inequities through disproportionate infection and illness rates and unequal impacts of response measures. This can result in income loss, job insecurity, education gaps and social isolation. Inequities can affect groups that have been identified as vulnerable or at risk before a pandemic, as well as groups that are more likely to be negatively impacted by decisions taken as part of a pandemic response (including health and care staff). This can also be particularly acute for children. It is also important to consider that different groups will be impacted variably in different emergencies, for example, Covid-19 and elderly people or HIV and gay, bisexual and other men who have sex with men (GBMSM) and people who inject drugs (PWID).

Since the Covid-19 pandemic, the government has significantly strengthened preparedness and planning for pandemic and emergency response and the protection of vulnerable groups. For example:

The Department of Health and Social Care has published a Pandemic Preparedness Strategy on 25 March 2026. It reflects on lessons from the Covid-19 pandemic and other past disease outbreaks, the UK Covid-19 Inquiry and early findings from the national pandemic exercise, Exercise Pegasus, to improve our ability to mitigate the impacts of a pandemic, protect the vulnerable and save lives.

Cabinet Office published updated guidance in April 2025, Identifying and supporting persons who are vulnerable in an emergency: Supporting guidance for Local Resilience Forums in England. It sets out the responsibilities of Category 1 and 2 responders to plan for and meet the needs of those who may be vulnerable in emergencies.

Cabinet Office and the GO Science circulated internal guidance to departments in November 2025, which sets out principles to help identify potentially vulnerable people during an emergency and how to assess disproportionate impacts on them for risk scenarios in the National Security Risk Assessment (NSRA).

Cabinet Office published the UK government Resilience Action Plan in July 2025. This sets out the actions that the government will put in place to improve our understanding of risk for vulnerable people.

NHS England has adopted Core20PLUS5 which seeks to reduce healthcare inequalities at both national and local system level. The UK Health Security Agency (UKHSA) uses an adapted version of Core20PLUS.

The National Situation Centre has created a Risk Vulnerability Tool (RVT) to estimate the number of people who are vulnerable to the negative impacts of NSRA risks.

The NSRA update in 2025 for R78 for a pandemic has a more extensive assumption than before to be used for vulnerable groups for pandemic planning.

DHSC’s review of the existing relevant guidance documents will identify any gaps and establish a programme of work to better embed and consolidate use of existing documents into decision-making, including the needs of vulnerable children. The review is set out at (Outcome 2) of the Pandemic Preparedness Strategy. This review will provide clarity on how central and local government will dynamically identify those most at risk during a pandemic response using surveillance, the latest clinical and scientific data and communications.

Outcome 5 of the Strategy commits to publishing health evidence reviews on the effectiveness of community protection measures including specific consideration of health inequalities. It also commits to developing understanding of the wider direct impacts (resulting from the pathogen) and indirect impacts (resulting from the response control measures and access to health services) on all sectors and communities, including healthcare staff, frontline workers, patients and population to build this into the development of a suite of policy options for community measures that could be used for future response, including mitigations for unequal impacts.

DHSC will also review how data, evidence, and analysis, including vulnerability assessments, inform decision-making and can evaluate the impacts of measures (Outcome 12). This will also include engagement with people with lived experience, as recommended by the CMO.

Health is a devolved matter in the UK and the government recognises that there are different approaches to identify and protect vulnerable groups across the four nations. However, the government is working with the devolved governments to ensure alignment of approaches and to identify gaps to ensure consistent and effective health outcomes across the UK.

Accepted

During development of the NI Civil Contingencies Risk Register, over 50 individual risks were mapped out in terms of how they would have a direct effect on Vulnerable People and how that effect could, or would, change depending on the nature of the particular emergency being responded to. This information has been made available to emergency planners both in hard copy and via the digital dashboard.

The digital interface will be further developed during 2026 with a search tool being added which will allow the user to interrogate consequence and identify the most significant risks and how those risks behave, i.e., are they ‘no-notice’ events for which prior planning will be key, or are they ‘rising tide’ issues where engagement with those who are most likely to be impacted develops over a longer period of time.

As part of risk mapping, a series of thematic templates have already been developed which provide a best practise guidance to those preparing for vulnerable people impacts. The Northern Ireland Civil Contingencies (Building Resilience Together) Framework remains the overarching guidance document for emergency response. A comprehensive review will commence shortly, incorporating lessons from Exercise Pegasus to ensure plans and procedures are clear, practical, and fit for purpose. These templates will be included as annexes in the 2026 revision to the NI Civil Contingencies Framework and will be subject to EQIA screening along with the wider document.

In preparing the templates, engagement took place with the community level of the NI Civil Contingencies network. The Community and Voluntary Sector have been involved with the development of risk mapping and have added rigour and challenge to our current thinking. Our commitment is to continue engaging with those who have direct knowledge of our communities.

The 2026 update to the Civil Contingencies Framework will see a complete revision of the Vulnerable People Chapter to include the recently revised UK Government protocols. This will not only ensure cohesion across the jurisdictions but also afford the opportunity to include our legal remits under s75 of the NI Act.

The Scottish Government accepts this recommendation in principle. The Scottish Government recognises, as highlighted by CIREG, individuals and groups may be disproportionately impacted by an emergency, and the ways in which they are affected may change based on the nature and timescale of the crisis.

Vulnerability in this context refers to individuals who are more likely to be harmed or less able to independently help themselves during an emergency (e.g. those who rely on the state and cannot live independently). Vulnerability can arise from factors such as age, disability, poverty, pregnancy, mental health, ethnicity, gender, and neurodivergence, although this not an exhaustive list. Emergencies impact many people, including individuals and groups who would not generally be considered ‘vulnerable’ outside the context of an emergency. Vulnerability is shaped by many complex factors, which can be temporary or long-lasting, and their significance may differ based on the specific context of the emergency.

We continue to recognise legal duties, including the legal requirements under the Public Sector Equality Duty, do not stop due to a pandemic or other public health emergencies. This includes the requirement in the Equality Act 2010 (Specific Duties) (Scotland) Regulations 2012 to assess and review policies and practices.

In recognition that some individuals and groups may be disproportionately impacted by an emergency, we will explore how we can utilise and enhance existing stakeholder relationships and networks in order to ensure equality expertise and lived experience can be drawn upon readily during any emergency response. This is in addition to work to ensure these groups directly inform our planning for future events.

Recognising CIREG feedback that multi-agency partners have a significant role in supporting the safety of vulnerable people, the Scottish Government actively supports partners in the maintenance of tools to support the swift identification of, and support to, those most at risk during an incident.

The Scottish Government has established a programme of Future Pandemic Preparedness to ensure all areas of Government take action to effectively manage future pandemic risks. As part of the Future Pandemic Preparedness programme, key enhancements to existing practice relevant to this recommendation will include coordinating a PANEL (Participation, Accountability, Non-discrimination, Empowerment and Legality) - based human rights assessment of both Pandemic ScotOps (the decision-making structures activated during a pandemic crisis) and known, evidence-based Public Health & Social Measures (PHSMs).

The PANEL approach provides a human rights-based lens to embed equity and inclusion into emergency decision-making and pandemic response. Our aim is to ensure those groups at greater risk are systematically considered in advance of, and during, a pandemic crisis.

The Scottish Government will consider whether and how these actions to identify those most vulnerable during pandemics could be used during other whole-system civil emergencies.

In addition, as set out in the Scottish Government’s response to the Module 1 Report, the Scottish Government recognises the vital role of multi-agency partnerships in supporting vulnerable people and is committed to putting measures in place to enable support to reach vulnerable people during civil emergencies.

The Cabinet Office recently circulated internal guidance on Identifying and assessing the disproportionate impacts of emergencies to Vulnerable People in the National Security Risk Assessment (NSRA): Guidance for Lead Government Departments. This guidance sets out principles to identify potentially vulnerable people during an emergency, assisting responders to develop a better understanding of who may be vulnerable in different civil emergencies.

The Scottish Government will integrate this guidance into our updated approach to Civil Contingencies Risk Assessment, as part of our response to recommendation 3, ‘Risk Assessment’ of the Covid Inquiry Module 1 report. This will provide a tool for responders and policy makers to systematically consider vulnerability when planning for, responding to, and recovering from civil emergencies.

2.1. As noted above, the Welsh Government’s primary responsibility is to keep the people of Wales safe. To do so, it is critically important that we are able identify as far as is practical those at risk during an emergency, and we therefore accept recommendation 8. We have already made substantial progress, as set out below.

No statement on delivery from Cabinet Office has been found in the sources searched. This is separate from the response above.