Written evidence submitted by Welsh Women’s Aid (BSW0017)


About Welsh Women’s Aid

Welsh Women’s Aid is the umbrella organisation in Wales that supports and provides national representation for independent third sector violence against women, domestic abuse and sexual violence (VAWDASV) specialist services in Wales (comprising our membership of specialist services and members of the regional VAWDASV Specialist Services Providers Forums). These services deliver life-saving and life-changing support and preventative work in response to violence against women, including domestic abuse and sexual violence, as part of a network of UK provision.


As an umbrella organisation, our primary purpose is to prevent domestic abuse, sexual violence and all forms of violence against women and ensure high quality services for survivors that are needs-led, gender responsive and holistic. We collaborate nationally to integrate and improve community responses and practice in Wales; we provide advice, consultancy, support and training to deliver policy and service improvements across government, public, private and third sector services and in communities, for the benefit of survivors.


We also deliver the Wales National Quality Service Standards (NQSS), a national accreditation framework for domestic abuse specialist services in Wales (supported by the Welsh Government) as part of a UK suite of integrated accreditation systems and frameworks. (More information on the NQSS can be found here: http://www.welshwomensaid.org.uk/what-we-do/our-members/standards/)  




Welsh Women’s Aid welcomes the opportunity to respond to the committee’s call for evidence on the benefits system in Wales. As the umbrella body in Wales representing specialist violence against women and girls (VAWG) services, our response will focus primarily on how the benefits system in Wales impacts survivors of violence and abuse.


Economic abuse

Gender inequality leads to women’s poverty and gender-based violence, making them closely linked. Women are more likely to experience poverty and to have been adversely impacted by the austerity measures and cuts to welfare benefits, services and jobs.[1] The way in which survivors can access necessary benefits will have a direct impact on their ability to remove themselves from or minimise harm in violent or abusive situations.


When considering the suitability of the current welfare system in Wales it is vital to understand how systemic racism, homophobia and ableism, both perpetuates abuse and increases barriers to support and leaving abusive situations. VAWG is a cause and consequence of inequality between women and men, which intersects with factors such as ethnicity, age, class, sexuality and disability to impact on experiences of abuse and routes to recovery.[2] Our joint report with Disability Wales[3] highlights Disabled people in Wales are also more likely to be in poverty, less likely to be in work and have fewer qualifications than non-disabled people and these rates are the highest in the UK and that disabled people experience disproportionately higher rates of abuse than non-disabled people. A UK wide study found disabled women, disabled men and gay men disproportionately experience economic abuse.[4]


Two child tax credits

We have serious concerns surrounding the rape clause on two child limit on claiming tax credits. The Guardian reported[5] in July 2020 that 900 women had been forced to disclose rape and coercion in order to receive this benefit. This number has no doubt risen.


We (along with many other expert organisations) have objected to this clause and called for the removal of the two child limit on tax credits altogether.[6] It is inhumane that a requirement to receiving government aid be to disclose, and provide evidence for, abuse, rape and coercion. Choosing to disclose is a hugely personal decision for a survivor, and that person must feel ready and know that the right support networks are in place before re-living this trauma. Rape convictions in the UK are at an all time low[7] and survivors feel less confident than ever that that they will be believed. We must address this and create a new culture where abuse is actively challenged, perpetrators are held accountable, and survivors are believed. Verifying abuse to receive tax credits only serves to perpetuate myths and stereotypes and actively stalls progress. 


We also take issue with the caveat that the mother cannot be living with the biological parent of the child they are claiming support for. This will prevent women who currently cannot leave their perpetrator the financial means to do so, furthers child poverty and perpetuates a victim blaming narrative.


Universal credit

We remain opposed to the requirement for couples to make a joint claim in order to receive universal credit. We, and women’s organisations from across the UK, have repeatedly raised concerns about a single payment to joint claimants, as this is likely to increase opportunities for financial abuse and coercive and controlling behaviour for many who are living in abusive households, and an Alternative Payment Arrangement proposed.[8] In a 2016 briefing on benefit changes[9] we highlighted that an Alternative Payment Arrangement will allow a spilt payment between partners. However, Welsh Women’s Aid (and other organisations) do not consider this to be an adequate safeguard. For the arrangement to be considered, a Universal Credit Coach at the Job Centre would need to receive disclosure of the abuse. The potential for the perpetrator of abuse finding out that a disclosure has been made through this arrangement significantly increases risk of serious escalation of abuse.


No recourse to public funds

No recourse to public funds (NRPF) acts as a serious barrier for survivors experiencing violence and abuse with restricted or insecure immigration status in the UK and must be considered as part of any funding plan to completely end VAWDASV for women in Wales.


Many migrant women fleeing abuse have increased barriers to doing so due to a lack of eligibility to claiming any kind of housing benefit. In Wales there is a duty on social services[10] to meet the care and support needs of adults as well as children where it is necessary to protect them from (a risk of) abuse or neglect regardless of their immigration status (with the exception of those excluded from social services support under Schedule 3 of the Immigration and Asylum Act 2002). However, this duty is little known about or understood, and acted upon even less.


The intersection of immigration law and welfare access leads to discrimination against survivors and their access to benefits (i.e. support and safety) based on their nationality/residence status and/or that of their perpetrator. The UK Government must uphold its commitments to the Istanbul Convention by abolishing no recourse to public funds for survivors of abuse to ensure that migrant women fleeing abuse have equal access to safety and support.


Economic abuse

We have heard survivors’ direct experiences of experiencing financial/ economic abuse whilst also attempting to access welfare support through Welsh Women’s Aid’s survivor network. One response highlighted that whilst trying to leave an abusive relationship including ongoing financial abuse, they have found it difficult to access any kind of benefits due to being in employment. As a result they have ended up in debt in order to support themselves and their children in accessing safety. They shared how the current benefit system, is not currently set up to support them in their situation.


Other survivors identified barriers in accessing benefits due to welfare benefit sanctions, being in work and therefore unable to afford refuge, or having trapped capital and being unable to afford legal advice and advocacy to access appropriate state support. The barriers to accessing refuge-based support for working women and for women wrongly accused of owning / having access to assets which are under the perpetrators control, exclude them from entitlement to benefits. This is a concern that is being raised repeatedly among Welsh Women’s Aid’s membership.



Pre COVID-19, 1 in 3 women were experiencing some form of VAWG across their lifetime, this is not a ‘normal’ we wish to return to. The pandemic created new challenges for the specialist sector and new dangers for survivors. Restrictions provided perpetrators with greater means of control, including financial control. Research by the Women’s Budget Group shows the uneven impact of school closures, shutdown industries, furlough, and flexible working arrangements are marked between mothers and fathers, those on lower incomes and higher incomes, white and Black, Asian, and ethnic minority groups and those who are not disabled compared to those who are disabled.[11]


Currently welfare support and access to benefits does not facilitate survivors’ pathways to freedom from abuse. It puts a burden of evidence, proof and disclosure on to the survivor with little recognition of the impact of coercion, trauma and financial abuse. Further to this, the exclusion of access to benefits and welfare support for some women, namely migrant women, means the benefit system actively discriminates against specific cohorts of women accessing support and safety. Universal credit was promoted as a mechanism to offer simplification and flexibility however for women experiencing violence and abuse it has often done the opposite. Leaving them trapped in controlling and abusive relationships or struggling financially once they are able to leave. Significant support is required from specialist services to enable women to access they welfare support they are entitled to. This requires the investment of resource and expertise within specialist services to provide advice and advocacy.


Welsh Women’s Aid supported proposals that there should be assessment of all welfare reforms for their impact on women’s ability to escape abuse. We would welcome the committee’s commitment to include this within its assessment of the benefit system in Wales. We offer our expertise and engagement with survivors lived experience and specialist services grassroots knowledge to support this assessment.


August 2021





[1] https://www.welshwomensaid.org.uk/wp-content/uploads/2019/12/WWA-Cheques-and-Balances-Economics-of-Abuse-Report.pdf

[2] https://www.welshwomensaid.org.uk/wp-content/uploads/2019/11/Annual-Membership-Report-2018-19-FINAL.pdf

[3] https://www.welshwomensaid.org.uk/wp-content/uploads/2019/04/WWA-and-Disability-Wales-2019-report-Final-ENG.pdf

[4] https://www.refuge.org.uk/files/Money-Matters.pdf

[5] https://www.theguardian.com/society/2020/jul/17/data-shows-900-women-in-uk-affected-by-tax-credit-clause

[6] https://www.rcm.org.uk/media/2290/child-tax-credit-and-the-rape-clause.pdf

[7] https://www.welshwomensaid.org.uk/2020/10/survey-finds-rape-victims-have-lost-faith-in-justice-system/

[8] http://holyrood.engender.org.uk/content/resources/Gender-Matters-in-Social-Security---Individual-Payments-of-Universal-Credit.pdf

[9] https://www.welshwomensaid.org.uk/what-we-do/briefings-consultation-responses-and-publications/

[10] Sections 35(3)(b) and 37(3)(b) of the Social Services and Wellbeing (Wales) Act 2014

[11] https://wbg.org.uk/analysis/reports/building-back-better-for-women-girls/