Inclusion Scotland’s Perspective on Module 1 Implementation – July 2026
Module 1 of the UK Covid-19 Inquiry examined the UK’s resilience and preparedness for the pandemic, scrutinising the core structures, procedures, and decision-making for civil emergency planning and risk management. In its report, the Inquiry set out a series of findings and recommendations and an implementation timetable for reporting.
The Scottish Government has published its progress update on the implementation of the Module 1 recommendations of the UK Covid Inquiry (July 2024). As a Disabled People’s Organisation (DPO) representing disabled people and their organisations across Scotland, we have reviewed this update with cautious optimism and deep concern.
While we welcome the commitment to learning lessons from the pandemic, our detailed feedback reveals a troubling pattern: disabled people and our representative organisations are still being excluded from the very processes designed to protect us.
“Nothing about us without us” is central to pandemic resilience, yet coproduction on implementing the Inquiry’s recommendations has been inconsistent and risks being superficial.
Exclusion from Implementation
Throughout the progress update, we see repeated instances where DPOs have been excluded.
Risk Assessment (Recommendation Three): The Scottish Government has completed its review of the Scottish Risk Assessment without (to our knowledge) involving community groups or those who best understand the needs of their communities. The Scottish Risk Assessment Group includes organisations like the Met Office, SEPA, and Food Standards Scotland but not community or disabled people’s organisations. This recommendation should have been coproduced, but we have not been involved.
Programme Boards and Oversight Groups: The Future Pandemic Preparedness Cross-Government Delivery Group met in June 2026, and we are disappointed not to have been contacted about involvement. Similarly, the Crisis Preparation Oversight Programme has strengthened its role without our input. We would like to be involved in this work.
Written Updates: Cabinet received a written update on risk, resilience, and preparedness in March 2026, and the Ministerial Oversight Group received a written update on pandemic preparedness progress in early 2026. DPOs would like to see these documents to properly understand what is being proposed.
The Analytical Framework: DPOs would like to understand what is meant by this operational document. We see no tangible mechanisms for connecting with disabled people to collect our data or ensure our perspectives are included. The Memorandum of Understanding on data sharing across the four nations has been signed, but we cannot see if disabled people have been considered in this. The calendar does not appear to be public. Which presents a wider concern on the Scottish Government’s commitments to the Open Government agenda.
The Language Problem: “Vulnerable” vs. “Made Vulnerable”
A fundamental concern is the Scottish Government’s persistent use of the word “vulnerable” throughout its implementation update. Throughout the pandemic and since, DPOs have consistently recommended using “at risk”, not “vulnerable” to avoid stigmatising disabled people as inherently unable to cope. This is not merely semantic. Framing people as “vulnerable” locates problems with individuals rather than in systemic failures to provide accessible information, adequate support, and inclusive planning. This language directly contradicts the principle that people are made vulnerable by inadequate systems, not by their impairments. As DPO submissions to the Inquiry have argued, the discourse of vulnerability central to pandemic decision-making undermines the long-term aim of mainstreaming understanding that impairments are not inherent with weakness. We must shift to language that recognises that people are made vulnerable by lack of support, inaccessible information, and systemic barriers. When planning focuses on “vulnerable people” rather than “people made vulnerable by inadequate systems”, or “at risk” more than the general population, it excuses systemic failures and locates the problem within disabled people themselves. Similarly, we no longer describe communities as “hard to reach” because the onus is in the wrong place. They are not hard to reach; statutory bodies are simply poor at reaching them. The correct term is “seldom heard from.”
What Success Looks Like: The Disability Equality Plan Commitment
The Scottish Government’s 2025 Disability Equality Plan made a clear commitment: “We will strengthen our resilience and emergency planning to ensure appropriate, accessible, and timely responses for disabled people in times of crisis. Civil Contingencies Division and the Directorate for Equality, Inclusion and Human Rights will do so by working with DPOs to create a resourced plan setting out how we will enhance our disability competence and learn from the lived experience of disabled people.”
This is the standard we are holding them to. By that measure, the current implementation falls short. Where were communities involved in the risk assessment review? Where are the mechanisms for connecting with disabled people? Where is the coproduction that the Disability Equality Plan promised?
Where We See Progress
We acknowledge some positive developments.
The National Centre for Resilience has now finalised its reports following round-table workshops on emergency planning policy. Critically, these workshops were attended by people with lived experience, and the findings reflect our priorities. Trust must be built on sustained relationships with local communities and underrepresented groups. Inclusion improves outcomes and leads to more practical, credible, and usable resilience systems. Resilience is a system requiring continuous investment in skills, infrastructure, partnerships, and learning.
DPOs have been invited to the National Centre for Resilience event “Strengthening the Emergency Planning System with Disabled People” on 25 November 2026, which is a welcome step forward.
The Scottish Training and Exercising Calendar went live on 10 February 2026, though we note it was published on Resilience Direct and work is ongoing to ensure responders are aware of it. We are glad to have been invited to the NCR event, but this must become the norm rather than the exception.
What we need to see
Based on our analysis of the Module 1 implementation progress, we call on the Scottish Government to:
Include DPOs as core partners in all pandemic preparedness and resilience programmes. This means not consultation after decisions are made, but genuine coproduction from the earliest stages. We should be at every table where decisions about our lives are being made.
Shift the language from “vulnerable people” to “people made vulnerable by inadequate systems.” Recognise that disabled people are experts on what needs to change, not passive recipients of services.
Make all documents publicly available so we can properly analyse and contribute to the processes that affect our lives. Documents like the Analytical Framework and the Memorandum of Understanding should not be hidden from the people they affect.
Establish clear mechanisms for connecting with disabled people to collect our data and ensure our perspectives are included in emergency planning at every level.
Build the capacity of both disabled people and emergency services through resourcing DPOs, and training delivered by disabled people. This is essential for breaking down the barriers that currently exist.
The Stakes
Our recent report, Lessons Learned: Inclusion Scotland’s Review of Disability-Inclusive Emergency Planning, provides clear evidence of where progress has stalled and what urgently needs to change. The report makes it plain that without genuine partnership with Disabled People’s Organisations, resilience systems will continue to fall short for the very people they are designed to protect.
Almost 60% of people who died from COVID were disabled people and people with learning disabilities were 30 times more likely to die of Covid- This was not inevitable.
We cannot afford to repeat these failures.
The research on disability-inclusive climate emergency planning found that Scotland is currently “failing” on developing inclusive governance, building awareness and capacity of disabled people, and training emergency services, three of the six critical steps for effective disability-inclusive planning. The same gaps appear in pandemic preparedness.
Conclusion
The Scottish Government has made some progress on implementation, and we welcome the commitment to a Scottish Resilience Strategy. The strengthened Crisis Preparation Oversight Programme and the work of the National Centre for Resilience are also positive steps. Inclusion Scotland and other equality stakeholder organisations have been included in the membership of the COVID-19 Inquiries Response and Engagement Group (CIREG).
But the persistent exclusion of DPOs from operation PEGASUS, core decision-making structures suggests the fundamental lesson of the pandemic has not yet been learned: disabled people must be involved in the decisions that affect us.
We were promised coproduction. We were promised that our voices would be heard. We were promised that lessons would be learned. The progress update shows that while some structures are being developed, the people most affected by emergency planning decisions are still being left out.
The Scottish Government must urgently rectify these gaps. The Scottish Resilience Strategy must have disability inclusion at its heart, not as an afterthought. DPOs must be involved in its development from the beginning. And the language must shift to recognise that people are made vulnerable by systems, not by their impairments.
Only then can we truly say that the lessons of the pandemic are being learned and that disabled people will not be left behind in any future crisis.
Written by Inclusion Scotland’s Policy and Research Officer Maia Pace