Since 2009, the Scottish Government has published, in some form, an equality budget statement alongside the Budget. This year, the Government has overhauled its approach with the introduction of the Strategic Integrated Impact Assessment (SIIA, “the Assessment”). This new approach “combines multiple statutory duties into a single process and publication”. The Scottish Government explains that this approach has been informed by international best practice and engagement with key stakeholders, such as the Welsh Government, the Organisation for Economic Co-operation and Development (OECD), the National Advisory Council on Women and Girls (NACWG) and the Equality and Human Rights Budget Advisory Group (EHRBAG).
The SIIA was published on 19 January, six days after the Scottish Budget 2026-27, as opposed to alongside the Budget like its predecessors. This means that SPICe was unable to include consideration of equalities and human rights within its initial analysis of the Budget as we usually do. This blog replaces that analysis.
The journey of the Equality Budget Statement
Over time, the format of the Equality Budget Statement (“the Statement”) and its successor documents has evolved. Historically, though, it has always centred around the Scottish Government providing strategic and fiscal context, an equalities assessment of each portfolio, and a breakdown of the implications of the proposed budget for each protected characteristic (as defined by the Equality Act 2010). These have changed format and prominence and have been moved in and out of annexes over time, but have always been present in some form. In addition, the scope and content of the Statement have grown. The following bullet points illustrate changes over the years:
- The Fairer Scotland Duty was introduced in 2019. This placed a legal responsibility on the Scottish Government and a range of public bodies (including local authorities and NHS Boards) to consider actively how they can reduce inequalities of outcome caused by socio-economic disadvantage when making strategic decisions. This new duty was first reflected in the re-named Equality and Fairer Scotland Budget Statement (EFSBS) from 2019-20 onwards, along with a child poverty overview.
- In the 2020-21 Statement, following the introduction in 2019 of informal guidance for policy makers on equality and human rights budgeting, the Government began to include analysis against six questions for policymaking in the statement. It also began to include references to human rights and distributional analysis.
- In the 2021-22 document details of contributions to achieving National Outcomes and human rights were added to portfolio analysis, as well as analysis looking at risks against National Outcomes. This version of the Statement also included clear proposals for how policies would be evaluated, an Easy Read version, and the addition of socio-economic disadvantage, which had been referenced elsewhere since 2018, alongside protected characteristics.
- In the Statement for 2022-23, rather than going into detail on impacts and outcomes, the analysis by characteristic simply highlighted spend against each. There was, however, reference to intersectional disadvantage.
- For the 2023-24 Statement, our post-Budget analysis highlighted the addition of new columns to the portfolio analysis, but noted that “the data provided under this heading are rarely detailed and, in some cases, do not answer the question in the heading” and could be general or unrelated to spend.
- The 2024-25 Statement introduced a case study approach. The Government explained that the process for compiling the document had also been updated. Most notably, portfolios had been engaged earlier in their budget setting cycle to consider the equalities impact of their budget decisions. The Government also included analysis of its approach against the three principles of human rights budgeting and showcased cross-cutting spending decisions.
- Finally, in the 2025-26 Statement, the Government flagged further improvements to its internal process, “such as greater integration with the Programme for Government and budget processes to ensure that evidence actively shapes budget decisions when these are made, and the budget process itself to ensure that evidence actively shapes budget decisions when these are made”. It also introduced “analysis on key decisions”, though we noted at the time that this was effectively the case study approach with budget lines added. There was an expanded distributional analysis of the impacts of tax decisions on different groups, and a thematic analysis approach based on key indicators from the National Performance Framework, which set out a more meaningful narrative than past iterations.
Past concerns raised about the EFSBS
During past rounds of pre-budget scrutiny, the Equalities, Human Rights and Civil Justice Committee has both heard and set out concerns about the EFSBS. SPICe has also highlighted potential challenges in using the document in our annual Budget analysis.
Perhaps unsurprising when considering the additions and expansions over the years, the length and accessibility of the Statement became a concern, as highlighted in our analysis of the 2023-24 document and the 2022-23 Statement. The Government addressed this by annexing much of the detail in the 2024-25 Statement, but, as we noted at the time, this did not reduce the bulk of material. Last year’s Statement was a significant redesign, with the size of the main document plus its annexes halved.
Witnesses to the EHRCJ Committee’s pre-budget scrutiny over time have highlighted concerns that the Equality Impact Assessments upon which the Statement is based are often “done as add-on exercises”, and that there is a lack of detail to demonstrate whether, or how, equalities data has informed decision-making. In 2024-25 we noted that there was no analysis of how spending had changed in the EFSBS despite budget lines changing, and that there was a lack of detail on the impact of any changes.
Emma Congreve, Interim Chair of the Equalities and Human Rights Budget Advisory Group, in September 2025 evidence to the EHRCJ Committee, explained the importance of understanding trade-offs. She said that EHRBAG had worked with Scottish Government officials on how to illustrate the decision-making process, but it had not been feasible to produce such an analysis for inclusion in the 2025-26 EFSBS.
Concerns around timing of the Statement link into using the detail it contains as a tool. Dr Alison Hosie (SHRC) said during pre-Budget scrutiny for 2025-26:
The biggest issue that still remains is that the EFSBS comes out when the budget decisions are already made; we do not get the information on impact assessment in advance. It does not inform public discussion about what budgetary decisions need to be made or have any impact on the budgetary decisions, which are in effect pretty much made by that point. We do not really get a sense of what information has fed into those decisions.
Another long-standing concern has been the lack of connection between the Statement, the Budget and National Performance Framework. Progress against this has been slowed by the Scottish Government’s decision to fully review and overhaul the National Performance Framework after the Statutory Process on reviewing the National Outcomes highlighted that more fundamental changes may be needed. The anticipated Human Rights legislation planned by the Scottish Government was seen, earlier in this session, as an opportunity, but that legislation has been delayed until the next parliamentary session.
Vagueness has been another issue raised previously, with Dr Hosie saying, about the 2023-24 Statement:
There are a number of vague statements connecting budgets to positive impacts on people’s rights, but there is no substance to explain how that is to be achieved. A little bit more detail is needed—lines about the illustrative examples of the type of spending and the analysis that has gone into formulating those policy actions. At the moment, when you read through the examples you are left wondering why the examples were chosen. Have they been cherry picked? What was the reasoning behind their inclusion?
Although the addition of case studies to the EFSBS in 2024-25 provided useful detail, in the EHRCJ Committee’s collaborative work during the most-recent round of pre-budget scrutiny, citizen participants noted that the focus was on positive examples and that there may be benefit from understanding where the Government had reflected on less successful approaches.
Finally, the Scottish Women’s Budget Group highlighted, in a submission to the EHRCJ Committee in February 2025, that the Statement still failed to take an effective intersectional approach and built in “a siloed approach to both portfolio areas and protected characteristics”.
What is different about the SIIA
So, how does the SIIA differ from the EFSBS?
For a start, it marks several strategic shifts in approach. Most notably, it combines five different assessments into a single process. As well as the Public Sector Equality Duty (PSED) and Fairer Scotland Duty reflected in the EFSB, it also incorporates the:
- Child Rights and Wellbeing Impact Assessment (CRWIA)
- Consumer Duty
- Island Communities Impact Assessment (ICIA)
The document also covers the Scottish Spending Review, Infrastructure Delivery Pipeline, and the Budget. Despite this, it is more concise than previous iterations, even when including the accompanying Detailed Impact Table.
The Assessment makes heavy use of what the Scottish Government describes as its “enhanced” distributional analysis. There is also detail of pilot study activity on budget tagging, and a pilot approach to intersectional analysis based on minority ethnic women.
There is a detailed strategic overview of top-level fiscal plans, which, rather than simply setting out a list of priorities and aspirations, takes steps to illustrate the data underlying decisions, what steps have been taken, and the impact expected based on the distributional analysis. It also highlights intersectional impacts and demonstrates how decisions relate to the Scottish Government’s obligations, such as the UN Convention on the Rights of the Child (as incorporated into Scots Law). The latter may give an indication as to the opportunities which may arise should the Government achieve its intention to further embed human and social rights in Scottish law. It also provides a useful lens through which to understand cross-portfolio impacts.
There is a detailed assessment of impact of decisions against the Scottish Government’s four priority areas, along with an acknowledgement that there have been trade-offs and as a result, some portfolios have not kept pace with inflation. A recognition of the impacts of these decisions, and mitigating factors, is a welcome addition. Islands and intersectional impacts are woven throughout the analysis, as is a narrative which recognises both spend and disadvantage from a cross-cutting perspective.
Echoing the main Budget document this year, there is reference to preventative spend and public service reform, with the Scottish Government explaining:
Re-prioritisation is inevitable in order to direct spend where it is most impactful. Any reductions should therefore be seen in the wider context of a Budget that continues to fund the social contract that is at the heart of this Government’s approach, with an overall positive, or neutral, impact across disadvantaged groups.
Finally, the SIIA sets out its methodology and timeline in detail, including giving more clarity on the role of the cross-ministerial workshop process than has been set out in the past.
Does the SIIA address past concerns?
The overall approach shows the clear link between strategic aims and spending that stakeholders have been asking for, and crucially, there is recognition of where targets have not been met. It might, however, be more powerful if the evidence used was more linked to past interventions to illustrate the outcomes-based approach to budgeting that many stakeholders have called for over the years.
The pilot approaches on budget tagging and intersectional analysis are both useful and promising. The detail and narrative sets out the reality of exploring and assessing budget decisions, and used well, the approaches could prove to be practical tools for both budget-setting, and for scrutiny. The challenge for the Government will be scaling this up to give a holistic picture of the budget without it becoming unmanageable or losing meaning.
There are some disconnects between committee evidence and scoring in the SIIA. As the EHRCJ Committee found out in its scrutiny, there was a limited evidence base to understand the effectiveness of employability policy. Despite this, the SIIA analysis marks this area of spend as making an “exceptional contribution” against the five statutory duties.
There remain some bold but broad statements of anticipated impact, for example phrases like “transformational investment in sport and physical activity”– committees will be watching to see if these impacts come to pass, and whether levels of investment are maintained.
There will always be a degree of assumption in statements around, for instance, how many people would be worse off had it not been for past decisions, because these will focus on the intervention alone rather than the balanced impact of the budget. Evidence of a holistic picture of how Scotland is changing would carry more weight. However, tracking impacts and understanding the broad range of data available will remain challenging until there is more certainty over the future of the National Performance Framework and how various data improvement strategies will feed into this.
In the meantime, stakeholders may look to test some of the statements made, and look for evidence of the Scottish Government’s assertion that it has “embedded an integrated assessment approach at the core of a fiscal programme” when reading across fiscal documents. For instance, the SIIA highlights the “exceptional” impact of its £70 million investment in colleges, but we have already highlighted transparency issues around this figure in our post-budget analysis. As we have noted, there are issues around the choice of baseline used in the Budget which may create concerns around other such statements.
Neutral, positive, or exceptional?
Overall, concerns around length, level of detail, use of data and demonstrating decision-making have been met with significant improvements. The one concern raised by stakeholders that the new approach does not address at all is timing – the SIIA may well demonstrate more use of impact assessments in decision-making, but it’s still the case that Committees and stakeholders only get to see this detail once decisions have been made.
The Scottish Government has indicated that the SIIA is a pilot approach, and that it will evaluate and publish results by the end of 2026. Therefore, it is unclear how this will feed into the next round of budget scrutiny.
For the time being, the progression within what has always been described as an iterative approach is clear, and the SIIA goes further in addressing past concerns raised than any of its ancestors.
Ailsa Burn-Murdoch, Senior Researcher, SPICe