Transcript of Module 9 Second Preliminary Hearing, dated 10 September 2025

(10.30 am)

Lady Hallett: Good morning, Mr Wright.

Mr Wright: Good morning, my Lady. Can I confirm that you can see and hear us here in the hearing room?

Lady Hallett: I can indeed. Thank you.

Right, today is the second and last preliminary hearing for M9, economic response, before the hearings begin in November, and I’ll hand over to Mr Wright King’s Counsel to explain what we need to consider today.

Submissions by Lead Counsel to the Inquiry for Module 9

Mr Wright: Thank you very much.

Well, then this is a hybrid hearing, with some Core Participants and their representatives attending in person in the Inquiry hearing room and others appearing online before you. And I don’t mean any discourtesy by not introducing each of them this morning, given that your Ladyship is familiar with all of the Core Participants in Module 9.

The agenda for this preliminary hearing has been published on the Inquiry website, and in accordance with that agenda, and as the senior counsel with responsibility for the preparation and delivery of Module 9, I intend to provide this morning a brief further update on the following issues: one, Rule 9 requests; two, disclosure to Core Participants; three, expert witnesses; four, the provisional list of issues; five, Every Story Matters; and finally six, the public hearings.

In dealing with each of the agenda items, I will of course address, where convenient and appropriate, the written submissions that have been received from three Core Participants, namely the Disabled People’s Organisations, Long Covid SOS and Long Covid Support, and the Child Poverty Action Group, and in due course I will give way to counsel for two of those Core Participants, Ms Hannett King’s Counsel, on behalf of the Long Covid groups, and Mr Ahluwalia, on behalf of the Child Poverty Action Group, each of whom wish to make brief oral submissions your Ladyship.

Rule 9 requests.

As of this hearing, a total of 190 Rule 9 requests have been issued on behalf of Module 9, and that figure includes a request that has recently been issued to Will Quince, the former Parliamentary Under-Secretary of State for Welfare Delivery, and we thank both the Disabled People’s Organisations and the Child Poverty Action Group for helpfully inviting us in their written submissions to consider whether a request should be sent to Mr Quince. And we’ve reflected on those observations and other evidence received by the Inquiry, and have issued that request.

Although the Module 9 team reserves the right to issue further requests concerning issues which may arise consequent upon our review of statements yet to be received, I’m pleased to report that Module 9 has now issued all of the Rule 9 requests that it had originally planned, and the team has made good progress in providing feedback on the drafts it has received, and finalised statements will continue to be disclosed on a rolling basis.

We are grateful to all those corporate entities and individuals who have been issued with Rule 9 requests for their efforts to provide their evidence to the Inquiry in a timely manner. We appreciate that the deadlines we have set may at times have been challenging, and that in some instances, requests have been made for extensions of time.

The pressure of deadlines now being felt by some individual recipients of Rule 9 requests is the inevitable consequence of the ambitious timetable set for the module, and the delays, some significant, that the Inquiry experienced in receiving many of the key corporate statements.

In consequence of those delays, the timeline for the issuing of individual Rule 9 requests had to fall back, and that slippage gave rise to the further consequence of conflict between deadlines for individual statements and the summer vacation period.

Where we’ve been able to do so without jeopardising the overall progress of the module, we have accommodated all sensible requests for extensions of time, and we continue to liaise regularly with all the material providers and individual recipients of Rule 9 requests and will continue our constructive dialogue.

Our overriding objective in setting and urging compliance with deadlines has been to ensure that evidence is received by the Inquiry in good time so that it can be properly analysed by the Inquiry team and then disclosed in a timely fashion.

The receipt and disclosure of evidence as early as possible is to the benefit of all Core Participants, and of particular benefit to those individuals who will be required to give evidence during the public hearings.

The timeline of preparation leading to the public hearings will see the Inquiry legal team beginning to share proposals with Core Participants in the week of 20 October for week 1 witnesses.

It is plainly in the interests of those witnesses and the Inquiry that those evidence proposals are as well developed as possible, and engage with the evidence that the Inquiry has received. Further delays to the receipt of individual statements will impact our ability to assist the witnesses to give their best evidence on the key issues for investigation.

Turning to disclosure to Core Participants. As our written note for the hearing set out, and bringing things completely up to date, the Inquiry legal team has made 31 tranches of disclosure, comprising 6,547 documents. This includes 46 witness statements and their exhibits, as well as material that had been provided to other modules.

Currently, there are eight draft statements that are being progressed for disclosure. Further tranches of disclosure will be made to Core Participants on a rolling basis, and we remain confident that the vast majority of relevant material will be disclosed in good time for the Module 9 hearings.

Expert witnesses. As Core Participants are aware, Module 9 has commissioned reports from five experts: Gemma Tetlow, whose report considers the principles of good policymaking in the design and delivery of economic interventions within the framework governing public expenditure; Rob Joyce, whose report considers the economic shock posed by Covid-19 and the policy responses available to the UK Government and devolved nations; James Smith, whose report examines the macroeconomic considerations underlying different categories of economic support packages and the value and risks inherent in such interventions; Mike Brewer, who considers the role of the benefits system and labour market interventions in an economic crisis, and examines the evidence on which individuals in the labour market were most vulnerable to the adverse economic effects of the pandemic, and David Phillips, whose report considers how local authorities and devolved administrations received funding and how this changed during the pandemic.

Those reports have been shared with Core Participants in draft, and all their comments on the drafts have been provided to the experts for their consideration. Rob Joyce’s report has since been disclosed to Core Participants, and the process of finalising the remaining reports is ongoing, and it’s intended that all reports will be disclosed before the end of September.

Given that process is ongoing, my Lady, I do not propose to say any more about the content of the reports at this hearing.

Moving, then, to the provisional list of issues. The provisional list of issues has been circulated in draft. The list is not intended to be exhaustive, prescriptive or final, nor does it set out all of the detailed elements packed within each issue. It is inevitable that as the module and its substantive hearing progresses, some issues may come into greater or lesser focus, or indeed new aspects may arise.

We have, of course, considered all the helpful observations made by Core Participants, and we’re grateful to them for their input. Many of the issues that they have raised will fall within the framework of the list of issues as presently drafted. For example, as a component part of our consideration of what measures the UK Government introduced to alleviate economic hardship, including uplifts to Universal Credit and Working Tax Credit, we will be examining the decision not to implement uplifts to legacy benefits but to apply an uplift only to Universal Credit.

Similarly, any consideration in the list of issues of whether communication with the public about those schemes was clear, accessible, and effective will, of course, require us to consider the digital divide, and whether schemes were accessible to all so as to meet their stated objectives.

The final list of issues must of course be consistent with the terms of reference, the temporal limitations of the Inquiry, and the scope of this module.

Consideration of why uplifts to benefits and other easements were not continued post-pandemic would immediately appear to fall outside the temporal scope of the Inquiry. Similarly, the suggestion that module nine should consider whether the levels of budget funding provided to local authorities were sufficient to meet the pressures placed on public services in a public health pandemic would appear to stretch the boundaries of Module 9 which, as we observed at the first preliminary hearing, is focused on the systems and structures for the delivery of funding to local government, rather than an examination of how local government administered that funding and to what effect.

We’re also grateful to the Child Poverty Action Group for raising the position of migrants and can confirm that Module 10 of the Inquiry will be considering the impact of the pandemic on migrants.

As we also made clear in our oral submissions during the first preliminary hearing in Module 9, and repeat here today, the Inquiry has well in mind the experience of those who have contracted Long Covid and those who may have consequently become economically vulnerable. Indeed, it is for that reason that the provisional list of issues raises questions such as whether economic schemes in support of jobs and the self-employed had an unequal impact or otherwise failed to protect economically vulnerable groups, and explore how, if at all, the potential risk of long term sequelae was taken into account.

We of course have an obligation to ensure, as we also observed at the first preliminary hearing, that the examination of those issues is proportionate and remains proportionate within the constraints of the wider module. And a final list of issues for Module 9 will be published on the Inquiry website following this hearing.

Every Story Matters.

The Every Story Matters record for Module 9 is now well progressed. We’ve heard from 54,809 people who have sharing their story through the Every Story Matters webform, and 273 interviews were held with people with experiences of particular interest, such as those who received financial support during the pandemic and those who were not eligible.

These experiences have been analysed and brought together with accounts from Every Story Matters events into one thematic record. The Inquiry is extremely grateful to everyone who took the time to share their experiences with the team and the insight provided is extremely valuable.

These stories will help us learn lessons for the future, and the Inquiry plans to disclose the Module 9 record to Core Participants in early October of this year.

Turning, then, to the public hearings.

The public hearings in Module 9 will commence on Monday, 24 November 2025, and conclude on Thursday, 18 December 2025. As with the Inquiry’s other modules, the public hearings will commence with an impact film which will feature members of the public from across the four nations talking about their experiences of the economic impact of the pandemic and the support offered to mitigate that impact.

In preparation for the public hearings, the Inquiry intends to circulate a provisional list of witnesses and will invite Core Participants’ submissions on this list.

The hearing schedule allows for 16 sitting days. Allowing for the first and last days of the hearings to be occupied by opening and closing statements, there are no more than 14 days available for witness evidence. The Inquiry legal team is developing the provisional witness list with those parameters firmly in mind, and with a correspondingly hard focus on the central issues and the need to call only those witnesses who are best placed to speak to those issues.

We invite all Core Participants to apply a similar level of focus to any requests that additional witnesses should be called.

In a moment, then, my Lady, I’ll give way to Ms Hannett King’s Counsel, but not before I take the opportunity to thank all Core Participants for their continued constructive engagement with the Inquiry legal team, and express the confident hope that they will bring the same approach to the public hearings when we reach them in November.

Thank you.

Lady Hallett: Thank you very much indeed, Mr Wright.

Ms Hannett [King’s] Counsel.

Submissions on Behalf of Long Covid Support and Long Covid SOS by Ms Hannett KC

Ms Hannett: May I start by thanking Mr Wright and his team for their preparation today. It’s been of considerable assistance both to my team and to my clients.

My Lady, I appear on behalf of the Long Covid groups. In this module, that’s Long Covid SOS and Long Covid Support. I’m assisted by Ms Sivakumaran and I’m instructed by Jane Ryan of Bhatt Murphy Solicitors.

Long Covid SOS was established in June 2020 as a volunteer-run patient advocacy and campaign group. They advocate for the recognition, research, and rehabilitation for people impacted by Long Covid.

Long Covid Support began as a peer support face (sic) group in May 2020, registering as a charitable company in May 2021. They provide support and information to sufferers of Long Covid and campaign for equitable access to high-quality healthcare, employment and welfare rights, and research into treatment into Long Covid. Together in this module, they represent the cohort of the population whose lives have been devastated by Long Covid.

My Lady, you have our written submissions, where we address first the provisional list of issues and second the draft expert reports. I propose to make very brief submissions on each of those points now.

Turning first to the list of issues, the matters to be addressed by Module 9 are of the most profound concern to my clients. They say that the economic impact of Long Covid ought to have been of the most profound concern to the government. To date, that has not been the case.

There are three reasons why the economic impacts of Long Covid are of such importance. First, the number of persons affected by Long Covid are significant. The most recent study, the NHS England’s GP Patient Survey in 2025, found that, in England, an estimated 2 million people aged over 16 years suffered from Long Covid. Second, that may well be an underestimate. The GP survey also found that 4.5 million people were unsure if they had Long Covid. The history of minimisation and disbelief, my Lady, which you’ve heard about in previous modules, coupled with a lack of access to testing in recent years, means that it’s likely that the rate of Long Covid is higher than presently understood.

Indeed, the Inquiry has heard from me more than once in previous modules that there has been inadequate and incomplete data collection on the prevalence of Long Covid.

Third, many of those affected by Long Covid are affected sufficiently seriously that they have reduced the hours that they work or have given up work entirely and become economically inactive. Others have become carers for family members with Long Covid.

The individual economic impact is profound but so too is the macroeconomic impact. The LOCOMOTION study found that the 381,000 people impacted a lot by Long Covid lost income of 5.7 billion from infection to February 2023, with a further 4.8 billion cost of informal caregiving over the same period.

The Long Covid groups, therefore, look forward to the Inquiry asking why the economic impacts on those with Long Covid and their families has to date been ignored by the government and why no economic policies have been developed to address the financial impact on them. This carries immediate relevance what only for people with Long Covid now, but also for a future as-yet-unknown pandemic.

The Long Covid groups have pointed to evidence in previous modules that the long-term sequelae of a virus are a well known phenomenon and yet the government made no preparation for them. In a future, as-yet-unknown pandemic, it’s more likely than not that a novel virus will similarly lead to a significant proportion of individuals suffering from the long-term sequelae of those virus, and if lessons aren’t learned from the Long Covid experience the mistakes of today will be repeated in the future.

The Long Covid groups welcome the chair’s determination of 31 October 2024 for Module 9 that the position of those with Long Covid will of course play an important part in her consideration of the key economic interventions, as well as the confirmation given by Mr Wright this morning. They also welcome the inclusion in the provisional list of issues questions asking whether matters related to Long Covid were considered in the economic response to the pandemic.

The Inquiry must, however, ask whether economic policies should have been developed specifically to address the risk of long-term sequelae, and to that end, Long Covid groups have suggested in their written submissions a small number of amendments to the provisional list of issues and ask that you and your team consider those with care.

Finally, on this issue, the Long Covid groups endorse the submissions of the Disabled People’s Organisations and ask the Chair to amend the list of issues as they request, noting the observations of Mr Wright this morning, but, in particular, to ensure that Module 9 considers all welfare benefits so that consideration is not limited to uplifts to Universal Credit, Working Tax Credit and Statutory Sick Pay, and further, second, that proper consideration is given to the value of unpaid carers to the economy.

People with Long Covid sadly have firsthand experience of both the limitations of welfare benefits in alleviating economic hardship as well as the demands placed on unpaid carers for support. The investigations into Module 9 will fall short if they fail to take into account these key issues.

Turning, second, then, to expert reports.

My Lady, the Long Covid groups were disappointed to find that not one of the experts instructed in Module 9 factored in the financial and economic impacts of Long Covid into their draft reports. We say that this omission is at odds with the commitment that Long Covid would play an important part in the investigations in Module 9 and, we say, have not rectified, will hamper the Inquiry in its work insofar as it relates to Long Covid.

Long Covid groups were pleased to see that Robert Joyce addressed this omission to some extent in his recently disclosed final report with a brief reference to Long Covid, but as we’ve explained in our written observations on the draft expert reports, it’s important that the impact of Long Covid on the financial health of individuals, the labour market and the wider economic impact is properly recognised, considered, and the subject of appropriate recommendations in the remaining final expert reports.

In conclusion, my Lady, the Long Covid groups very much look forward to assisting the Inquiry further in its important work on Module 9. Unless I can be of any further assistance.

Lady Hallett: Thank you very much indeed, Ms Hannett. Extremely helpful.

Mr Ahluwalia.

Submissions on Behalf of Child Poverty Action Group by Mr Ahluwalia

Mr Ahluwalia: Thank you, my Lady.

Child Poverty Action Group, or CPAG, if I may, is grateful for the opportunity to participate in the Module 9 of the Inquiry as a Core Participant and very much welcomes the opportunity to make comments today on the provisional list of issues for Module 9, and I will do my best to expand on the key points in our written submissions, rather than repeating them. CPAG is pleased that the Inquiry has previously confirmed that Module 9 will include consideration of the support provided to the group referred to as economically vulnerable families, and further, we agree with the Inquiry’s indication that this group must include families claiming benefits. CPAG is grateful for the confirmation this morning that a Rule 9 request has been sent to Mr Quince, and CPAG is also grateful for the previous confirmation that this module will consider the impact of the government’s economic response, including the impact on families and children in poverty, as an essential part of evaluating that response.

This is particularly important in CPAG’s view because for families in poverty, the government’s economic response was inevitably their main lifeline for coping with the economic shocks they faced.

This is because, first, existing systems did not protect them. The pre-existing social security system was an inaccurate safety net to mitigate losses of income and insufficient to prevent families being pushed into deeper poverty or destitution.

Second, going into the pandemic, a large number of families had little or no personal savings available for them to draw on when incomes were hit. 3.5 million children lived in households with less than £1,500 in savings.

And third, during the pandemic, costs for low-income families went up, and essential costs already formed a much bigger proportion of spending for families in poverty compared to higher income households even prior to those increases.

And so, for low-income families during the pandemic, their experience of the social security system and other government economic interventions cannot be separated from their broader experiences.

This is because, for people experiencing poverty, it is pervasive through all aspects of their lives. During the pandemic, poverty played a role in home lives during lockdowns, in physical and mental health, and in children’s education when parents were unable to afford learning resources that would normally be provided by schools. Many of the long-term economic consequences of those impacts are yet to play out.

And so with that context, CPAG have three headline points on the provisional list of issues.

First is that an effective evaluation of the government’s economic interventions requires consideration of the overarching social security system, both prior to and during the pandemic.

Second headline point is that examining the objectives and reasoning behind the government’s economic interventions will be essential.

And the third headline point is that the Inquiry’s assessment of the government’s economic interventions must be informed by an understanding of the intended beneficiaries of the interventions and must include an assessment of their differential impact, in particular on adults and children who are already socioeconomically disadvantaged prior to the pandemic.

At the core of CPAG’s submissions is the point that economic interventions do not and did not happen in a vacuum, and it is only through understanding the underlying assumptions which underpin the design of the implementations and how they relate to the wider social security system that we can assess their effectiveness.

At this point, I will also note that the Disabled People’s Organisations, in their written submissions, do concur with CPAG’s views about the importance of looking at the overarching social security system as a necessary context for considering the government’s decision making when it came to economic interventions.

My Lady, in the time that I have left and to give context to our headline points, I will make brief submissions about probably the most familiar of the government’s economic interventions in relation to social security, which was the implementation of a £20 weekly uplift to Universal Credit and Working Tax Credit.

CPAG is grateful to Mr Wright for his comments earlier this morning on this in relation to the decision not to implement a similar uplift for legacy benefits, although we would note that the removal of the uplift in October 2021 is within the timeframe of the Inquiry’s investigations.

CPAG submits that there were significant and avoidable impacts on low-income families due to the design and implementation of the £20 uplift which CPAG sought continuously to highlight in its work engaging government at the time. The uplift was an important economic intervention, the absence of which would have undoubtedly meant that more families with children were plunged deeper into poverty. We know this from the fact that child poverty went down during the pandemic when the £20 uplift, furlough and the Self-Employment Income Support Scheme were in place, and following the removal of those measures, child poverty increased.

However, in CPAG’s view, the design of the £20 uplift was fundamentally flawed, and the nature of its flaws illustrate the need for the Inquiry to carefully scrutinise the underlying assumptions and objectives of the government’s economic interventions.

This is bearing in mind that levels of social security support received by families on the eave of the pandemic were severely inadequate as a result of austerity measures introduced in the preceding decade. The system was already penalising families with children through policies such as the two-child limit and the freezing on child benefit rates.

In terms of objectives, CPAG’s submission is that the government’s primary intention appears to have been to support high-income households who had a sudden loss of income and that low-income families with children, as well as disabled people, who form the majority of legacy benefit claimants were, at most, an afterthought.

And finally, in terms of interactions with other measures, the government at best failed to provide adequate support to low-income families, and at worse, caused families to even lose social security income, exacerbating the hardship they were experiencing.

For example, some working families who were already in receipt of benefits prior to the pandemic and whose earnings dropped below the level needed to qualify for an exemption from the overall benefit cap were newly benefit capped for the first time and saw their benefit income decrease, despite the £20 uplift. Thousands of others did not see the full benefit of the £20 increase because the increase took them over the amount the benefits are restricted to as a result of that overall benefit cap.

And as the Disabled People’s Organisations have highlighted, the absence of the uplift in legacy benefits is another stark limitation of the intervention, and CPAG saw examples of people who were left with impossible choices on whether to give up their legacy benefit and claim Universal Credit.

Unless I can assist further, my Lady, those are CPAG’s submissions for today.

Lady Hallett: I’m very grateful indeed, Mr Ahluwalia. Thank you very much.

Mr Wright, do you have anything further you wish to add?

Mr Wright: No, thank you very much, my Lady.

Lady Hallett: Very well. Thank you very much indeed, everybody, and for people being extremely focused and constructive, if I may say so. I will consider the submissions that have been made by Ms Hannett and Mr Ahluwalia and with the Inquiry team, and if any determinations are necessary, I shall make them and let people know in due course.

Thank you all very much indeed, and I look forward to such a constructive approach at the hearings in November.

Thank you. Bye bye.

(11.00 am)

(The hearing concluded)