Letter from IHREC to the Department of Social Protection regarding the ‘cost of disability’ consultation
Department of Social Protection,
Áras Mhic Dhiarmada,
Store Street,
Dublin 1, D01 WY03.
5 May 2026
A chara,
I write to you regarding the recent public consultation on the Cost of Disability led by the Department of Social Protection and the summit scheduled to take place on 13 May. This matter is of particular interest to us as the ‘A’ status National Human Rights Institution (‘NHRI’) and the National Equality Body (‘NEB’) for Ireland with the statutory mandate as the Independent Monitoring Mechanism for the UN Convention on the Rights of Persons with Disabilities (‘UNCRPD’).
Context While the rights enshrined in the UNCRPD are interdependent, you will be aware that Article 28 of the UNCRPD in particular addresses the costs of disability. It enshrines the right of disabled people to an adequate standard of living for themselves and their families and obliges the State to take appropriate steps to safeguard and promote the realisation of this right, including though the provision of appropriate and affordable services; devices and other assistance for disability-related needs; social protection programmes and poverty reduction programmes; assistance from the State with disability-related expenses for disabled people in situations of poverty; public housing programmes; and retirement benefits and programmes.
IHREC has raised concerns relating to the cost of disability and more broadly the right to an adequate standard of living through several recent publications, most recently in our 2025 submission to the CRPD Committee. Households with a disabled member are at a significantly higher risk of poverty and lower standards of living than those without. We draw your attention to the 2025 report published by IHREC and the ESRI that found that the cost of disability is calculated to be over half a disabled families’ disposable income, strongly related to the severity of disability, and that the income provided by disability payments falls well short of meeting the needs of disabled people. The research found that individuals and households affected by disability suffer a
double penalty to their living standards as their labour income is lower and consumption needs are higher than non-disabled individuals and households, noting in particular the increased costs associated with disability including healthcare-related, housing accommodations and transport costs. The report recommended significant investment in response in services such as adult care, childcare, education and training, along with changes in employer policies, such as flexible work arrangements and formalised recruitment practices, alongside a ‘cost of disability’ payment.
We have called on the Government to take a number of actions to implement article 28 of the Convention, including measures to: ensure that income provided by disability payments is sufficient to provide an adequate standard of living; to ensure that disabled people are not incentivised against accessing and/or progressing in employment by cliff-edges and income thresholds in the social welfare system; and to address deficiencies in the accessibility of and administration of the social protection system. Echoing these recommendations, the UNCRPD has recently, in its List of Issues pursuant to Ireland’s review in 2027, asked the State to provide information regarding measures to ensure the Disability Allowance provides an adequate standard of living and to introduce a permanent Annual Cost of Disability Support Payment, and about measures to remove disincentives in the social protection system that prevent or limit access to employment for persons with disabilities.
To achieve these aims, we recommend that policy decisions are informed by use of human rights and equality impact assessments and by adequately resourced consultation with disabled people, in line with our recommendations for implementation of the statutory obligations under Section 42 of the IHREC Act 2014, the Public Sector Human Rights and Equality Duty (the Duty).
The Duty is a statutory obligation which complements existing public policy, strategies and procedures, as they relate to progressing equality and human rights. The Duty provides an effective medium to ensure effective delivery of any commitments agreed to address the cost of disability. Implementing the Duty also provides a coherent framework for a consultative approach to assessing and understanding the intersectionality of issues faced by people living with disability.
Discussion regarding addressing the cost of disability must be considered in tandem with measures to enable disabled people to live independent lives and be included in their communities on an equal basis with others, including by providing community based supports and services, personal assistance, financial supports and by embedding the principle of universal design, community living and participation across functions of all public bodies with due regard to obligations under the Duty.
Disability Advisory Committee input on Cost of Disability consultation
In this context, we welcome the commitment of the Government to “develop and implement whole-of-government solutions that will address the cost of disability experienced by disabled people” in its National Human Rights Strategy for Disabled People and the recent consultation process. IHREC’s Disability Advisory Committee (‘DAC’) is a statutory advisory Committee comprising disability experts with extensive lived experience whose role is to advise the Commission on matters of law and policy. In advance of the planned Summit on May 13, the DAC recently considered the consultation led by the Department of Social Protection and planned Summit. The DAC provided a number of observations regarding the consultation process and the substantive questions therein, including:
- The DAC welcomed the accessibility measures provided throughout the consultation process, including the provision of material in multiple formats, and multiple options available to input. Concerns were raised regarding the short timeframe for submission which was considered not to provide sufficient time for organisations to meaningfully engage with their stakeholders including preparing their own accessible material to engage with and involve relevant groups. Specific concerns were raised regarding avenues available for disabled people who do not communicate linguistically to engage with the process and the DAC recommends that consideration be given to facilitating these individuals.
- The DAC noted that a one-day summit is insufficient to enable the depth and scope of reflective discussions required and observed that a series of national conversations would be more appropriate, given the complexity of the subject matter and the critical importance of supporting and enabling accessible participation.
- The DAC noted that substantial feedback from the Government should follow the consultation and that meaningful engagement should continue, including after policy proposals are developed and implemented.
- Noting the interdependency of UNCRPD rights, the DAC recommended consideration and dialogue regarding poverty, low pay and disability services. Particular reference was made to the increased energy costs and the impact of these on disabled people.
- The DAC cautioned against household assessments which do not measure the distribution of the funds within the household and recommended applying individual assessment for disabled people.
- The DAC noted concerns regarding inaccessible systems and processes for applying for social welfare payments such as Disability Allowance, including inadequate provisions of reasonable accommodations to applicants and recipients. The DAC referenced income thresholds that disincentivise disabled people from taking up work due to fear of losing supports, noting that this coincides with inadequate provision of housing and a wider housing crisis, as well as barriers to accessing employment, which collectively render disabled people financially dependent on others, increasing their risk of financial abuse.
- With respect to the risks of financial abuse, the DAC recommended consideration of measures to prevent and respond to all forms of financial abuse and exploitation.
- In order for any future measures to be positively impactful, the DAC strongly recommended flexible payment structures, noting that multiple models may be required to address thediversity of contexts and the diversity of disabled people. The DAC recommended careful consideration of people who are at high economic risk including refugees and members of the LGBTQ+ community, and that measures proposed would reflect and respond to the changing need of disabled people over their life course.
Finally we draw your attention to Article 4.3 of the UNCRPD and General Comment no. 7 on the participation of disabled people through their representative organisations in the implementation and monitoring of their rights, within transparent, participatory mechanisms that are enabled by the provision of appropriate and accessible information and resources. We welcome the commitments in the National Human Rights Strategy for Disabled People to enable and support meaningful and participatory stakeholder engagement with disabled people and note that this is not confined to this initial consultation phase but rather is ongoing process requiring close consultation and active involvement of disabled people representing the wide diversity in impairments.
We look forward to engaging further on this issue and are available to discuss the matters raised above.
Yours sincerely,
Rebecca Keatinge
Head of Monitoring and Compliance
Letter