Consultation Response to the Low Pay Commission – Low Pay Commission Consultation 2026

Consultation Response to the Low Pay Commission – Low Pay Commission Consultation 2026

June 2026

Young people

What is the outlook for the recruitment and employment of workers aged under 21? What is driving employers’ decisions on this?

Young people in Scotland, like those in the rest of the UK, are deeply concerned for their future career prospects.

In February 2024, Barnardo’s commissioned a YouGov poll of 1001 children aged 14-17 across Great Britain. They were asked to imagine themselves aged 30 and answer a set of questions about what their lives would be like at that age.[1]

The Poll results showed that 19% of young people don’t think they’ll have enough money to live comfortably when they’re 30. 61% don’t think they’ll own their own home, with children in the lowest socio-economic groups were less likely to believe that they will feel safe at age 30. One respondent said;

 “Everyone is struggling these days. Nobody has any money and bills are bad. My mum struggles to pay the bills and she’s a nurse with a master’s degree. I’m not that clever, so imagine my life will be harder than hers.”

The Scottish Government recently carried out a number of participation sessions with young people while preparing their most recent Child Poverty Delivery Plan.[2] During these sessions the topic of future prospects came up – ‘almost all discussions at events with children and young people addressed the importance of employers and organisations creating opportunities for young people leaving school.’ Highlighting, just how much of a concern this area is for our young people.

It has been headline news that there are a lack of jobs available for school leavers – the opportunities for this age group are shrinking and this issue only looks to get worse, there is a deepening youth job crisis. [3]  

The cost of employing new staff has risen. After years of austerity, followed by the pandemic and then the cost-of-living crisis which has yet to abate – the cost of hiring new staff is out of reach. However, this cannot be addressed through continued discrimination against young people. Where they are doing the same job as an adult, they should be paid the same wage.

A number of factors contribute to this;

  • When new staff are employed, there is a lot more competition from older, more experienced people, which makes it harder for young people.
  • Reduction in the availability of the types of jobs that young people take such as a decline in the hospitality sector and the uptake of AI outsourcing which is a threat to entry level positions.
  • Cost and availability of commuting. While Scotland has the free bus pass for under 22s, in rural areas routes may simply not exist, or they don’t run late enough. The services that do exist can be unreliable.
  • Increase in youth mental health issues and under funding of mental health services, especially after the impact of the pandemic, has resulted in a youth mental health crisis, impacting the ability of young people to work.
  • Disabled young people face specific barriers, with a lack of suitable job opportunities

Without a recognition of these impacts and taking significant steps to invest and support young people – these problems will not abate. There are specific issues around how 16- and 17-year-olds are treated by the devolved and reserved benefits systems and when addressing child poverty, that can leave them falling through a gap. For example, if a child leaves school for employment or an apprenticeship, their parents no longer qualify for child benefit, yet because the state assumes they still receive support from their parents, they are paid at a lower rate than 18-year-olds. In Scotland, 16- and 17-year-olds, whether in education, employment or training, as not included in the Scottish Child Payment. This can create unintended disincentives to training or employment.

How have recent changes in the minimum wages for young people affected their employment prospects? You may wish to consider both employers’ decisions about hiring and pay, and young people’s decisions about employment.

Arguably, there is age discrimination in setting the minimum wage for younger workers lower than the full national living wage. Those aged 16 and 17 who are working are the most impacted. Generally speaking, it is assumed that most in that age bracket will have some other support, such as living at home with parents.

However, many do not, or their parents’ ability to support them is limited.

Some will be studying and working part time, some will be working full time to support themselves, some may even have dependents of their own. They are reliant on the income from their employment to pay their daily living costs.

These young people have gas and electricity bills to pay, they have rent to pay and need money for their food, yet they must work longer to earn the same as someone who is older. They also only qualify for a reduced rate of Universal Credit – it is important to recognise the fact that not all school leavers going into the workplace have financial support from their families

For young people under 18 entering employment while still living at home, this can have an impact on wider family – if a young person leaves school for a job or apprenticeship, then this can disqualify the family from key benefits. This could disincentivise a young person from taking on employment or an apprenticeship.

It may be that that young person wants to move out and become independent, but it is also becoming increasingly unaffordable for young people to support themselves out with the family home.

While there is some incentive for businesses to hire more inexperienced workers by lowering the wage – a balance must be struck. As we have outlined above, there is great concern about the lack of suitable positions for young people entering the job market – whether this is part-time work to support their studies or as a full-time job.

When considering the rate of minimum wage, these realities need to be recognised. Interaction with benefits needs to be taken into account alongside looking at the various situations young people find themselves in.

What approach should we take to recommending 18-20 Year Old and 16-17 Year Old Rates for April 2027? For example, should we consider extending the NLW to 20 year olds?

A child’s rights-based approach must be taken when fixing the rate for 16-17 year olds, with a child’s rights impact assessment carried out to fully address the rights implications. This should include the views of children and young people.

Care should be taken to think about the implications for different groups of children, including those who are studying, those who are from poorer backgrounds, those who are disabled. We are particularly concerned for the situations of 16–17-year-olds who live independently and support themselves.

Interactions with both devolved and reserved benefits such as Universal Credit, Housing Benefits, Child Benefit and Scottish Child Payment should not be overlooked to have a meaningful picture. Child poverty remains at unacceptable levels in the UK, and this should be addressed through a child poverty prevention lens.

Apprentices

What are your views on the effectiveness and operation of the Apprentice Rate?

In addition to the concerns we have raised above, there are some specific issues with regard to the apprentice rate. There are a rising number of young people who the UK Government define as Not in Employment, Education or Training (NEETs), and the lack of apprenticeships is contributing to this. Wider work needs to be taken to increase the number of apprenticeships and support to employers to be able to provide them, without penalising young people with lower wages.

Some young people in apprenticeships will be supporting themselves, without any other family support. Low pay can impact on their ability to successfully complete the apprenticeship. It may be that it is just unaffordable.

For those under 18, who still live with their family, an apprenticeship reduces the family’s overall entitlement to benefits, which may lead to them turning down or delaying opportunities.[4] This particularly impacts on young people coming from poorer families and contributes to generational poverty.

Due to the lack of apprenticeships, and the pressures to remain in employment, some young people are accepting lower rates, as such they are being paid even less than the minimum rate.[5]

What is the outlook for the recruitment and employment of apprentices? What are the drivers of employers’ decisions on this?

There is a significant decrease in the availability of these positions. There is a need for additional incentives to employers to take on young people, support them and train them.

What do you expect the effects of the latest increase in the Apprentice Rate to be?

Without further support and investment, we are concerned that the trends we are currently seeing will continue, that the availability of such positions will continue to decline leaving more young people out of work or training.

However, these problems cannot only be addressed through rates of pay. There must be additional support and incentive to employers.

What approach should we take to recommending the Apprentice Rate for April 2027?

A child’s rights approach should be taken, and a child’s rights impact assessment should be prepared to look fully at the rights implications.

We believe that young people who are currently apprentices or are considering one should be directly consulted for their views and engaged in a meaningful way.

If you require any further information regarding this response then please contact Kit.Thompson@cypcs.org.uk


[1] Changing Childhoods Changing Lives report.pdf

[2] Tackling Child Poverty Delivery Plan 2026-2031

[3] Young people and work: interim report – GOV.UK

[4] ‘Apprenticeship penalty’ on benefits forces young people from poorer UK families to quit | Apprenticeships | The Guardian

[5] Low Pay Commission urges action on illegal underpayment of apprentices – GOV.UK

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