Fourth Special Report
The Defence Committee published its Fourth Report of Session 2024–25, The Armed Forces Covenant (HC 572), on 1 April 2025. The Government Response was received on 3 June 2025 and is appended below.
Appendix: Government Response
1. The timetable presented to us by the Secretary of State for producing a report meant there were fewer opportunities to take oral evidence on this subject than we would have preferred (Conclusion, Paragraph 5)
2. Assuming precedent is followed, a Select Committee will be appointed to consider the Armed Forces Bill, with the opportunity to hear oral evidence before considering the Bill line by line. We recommend that the Government allow time for that Committee to hear from a broad range of organisations with an interest in the Armed Forces Covenant, as well as on other issues that may be within the scope of the Bill (Recommendation, Paragraph 6)
The Ministry of Defence (MOD) agrees with the conclusion at Paragraph 5, acknowledging that the timeframe for producing the report was limited. The MOD greatly values the Committee’s efforts in gathering and analysing both oral and written evidence in the short timescale provided. We appreciate the Committee’s thorough and timely recommendations and welcome further collaboration with the Committee on this subject.
The Minister for Veterans and People has committed to engaging with the Committee on an annual basis. We believe that ongoing Committee scrutiny will be particularly valuable once the Armed Forces Covenant is fully embedded into law. This will help ensure that discussions are guided by the practical application of the new framework. The MOD’s expectation is that, as for previous Armed Forces Bills, a Committee will be appointed to consider the matters in the Armed Forces Bill 2026 and to take evidence from interested/invited stakeholders.
The Covenant today
3. The evidence we received shows that where the Covenant is working well it is improving outcomes for service personnel, their families and veterans and is removing some of the disadvantages people face as a result of military service. However, this was not the experience of everyone who responded to our inquiry. We heard many examples where the Covenant was not working as designed, resulting in people who have served being financially disadvantaged, unable to access medical care, or unable to find an appropriate school for their children as a result of their service. In cases like these, the Government and society are falling short of their commitment to the Armed Forces community (Conclusion, Paragraph 13)
4. Implementation of the Covenant Legal Duty varies considerably across the UK. In some places the Legal Duty has resulted in the creation of new policies and initiatives that have tangibly improved the lives of the forces community; in others the Duty appears to have changed very little. As a result, people’s experiences of the Covenant are very different depending on where they live, which services or organisations they interact with and which individual member of staff in an organisation they speak to. This is frustrating for people in the forces community, and gives them the impression that the Covenant is a hollow commitment. The Government wants to expand the scope of the Covenant, and we understand the reasons for this. However, equal attention must be given to ensuring that the Legal Duty is consistently and appropriately applied and translates into better outcomes for people in the forces community. (Conclusion, Paragraph 20)
5. Alongside its plans to legislate for an expanded Covenant Legal Duty, the Government should develop a strategy for making sure the Covenant is fully and consistently applied and recognised by signatories and by those subject to the Legal Duty across the UK, including in the Devolved Administrations. Actions as part of this strategy could include establishing clear and demanding standards and mechanisms for accountability, improving guidance to those delivering services, and facilitating knowledge-sharing so that best practice can spread. (Recommendation, Paragraph 21)
The MOD agrees with the conclusions at Paragraphs 13 and 20. The MOD welcomes the Committee’s assessment of the Armed Forces Covenant. We remain committed to identifying opportunities to strengthen the Covenant and we recognise that the application of the Covenant principles varies across the UK. We are also aware that these inconsistencies may result with some members of the Armed Forces community experiencing challenges. The MOD thanks the Committee for its recommendation at Paragraph 21. We acknowledge the crucial role consistent implementation has in delivering the Armed Forces Covenant and maintaining consistent application of its principles UK wide.
We recognise that a significant factor contributing to the inconsistency of the application of the Covenant principles is the misunderstanding of what the Covenant Legal Duty is and what it does. The extension of the Legal Duty across a broad range of policy areas and wider government will increase education and awareness of the unique nature of service. It should, however, be noted that the Legal Duty is deliberately flexible and does not mandate outcomes. This ensures service providers retain their ability to honour the Covenant in the way most suited to local needs. Imposing UK-wide minimum standards for service delivery to the Armed Forces community would not be appropriate as they could potentially disadvantage members of the local general population with more need.
The MOD is committed and will continue to commit to working with Other Government Departments (OGDs), the Devolved Governments, Local Authorities and the Third Sector to help raise awareness of the issues faced by the Armed Forces community. Between May and August 2024, the MOD conducted a Covenant Legal Duty Impact Survey, which was published in the Armed Forces Covenant Annual Report 2024.1 Organisations targeted included Local Authorities, NHS bodies, and state funded schools and colleges across the UK. 210 responses were received and over two-thirds of the Local Authorities and NHS bodies which responded said their understanding of both the Covenant and the impacts of service life had increased because of the introduction of the Legal Duty.
Existing policies, such as the Service Pupil Premium administered by the Department for Education (DfE) and the recent decision by the Home Office to waive visa fees for non-UK veterans with over four years of service, demonstrate positive steps in supporting Service families and veterans. However, we acknowledge that further efforts are needed to enhance support for the Armed Forces community. We will continue to engage with OGDs to ensure our Armed Forces community do not face disadvantage and to reinforce the government’s dedication to reaffirming its commitment to those who have served.
As part of embedding the Covenant fully into law, and the MOD’s approach to tackling inconsistencies of outcomes, the MOD will be providing training materials, webinar training sessions, downloadable resources and updated statutory guidance. These will help organisations comply with their legal obligations, by providing uniformed templates to record decisions taken. Additionally, the MOD host an annual conference which invites Armed Forces Champions from across the nation to share best practice in delivering the Covenant. The MOD regularly engages with Local Authority Champions in a range of forums to share their work and knowledge with others.
To ensure private sector organisations are upholding the values of the Covenant pledge, the Defence Relationship Management conduct initial due diligence checks on all organisations who register as either covenant signatories, or through the Defence Employer Recognition Scheme (DERS). If an organisation is alleged to have failed to uphold the values, they have agreed to, the MOD has policy in place to assess their continued suitability, known as the ‘Covenant Test’.
The future of the Covenant
6. We welcome the proposal to extend the Covenant Legal Duty to areas of central government. If this duty is properly implemented, we would expect to see Whitehall departments taking the needs of the forces community into account during policy development, so that the forces community are not unintentionally disadvantaged by new policies (Conclusion, Paragraph 28)
7. The Government should extend the application of the Armed Forces Covenant so that all Government departments and the devolved administrations are required to give due regard to the principles of the Armed Forces Covenant. As the current duty of ‘due regard’ is inconsistently interpreted, the extended duty must be accompanied by clear guidance so that the duty is clearly understood and is not treated as a tick-box exercise (Recommendation, Paragraph 29)
The MOD agrees with the conclusion at Paragraph 28 and accepts the recommendation at Paragraph 29. It has been government policy since 2011 for HMG to implement the Covenant principles when making relevant policies and decisions. However, in practice, this policy has sometimes been inconsistently applied as evidenced by discussions at local and national engagement forums, as well as through correspondence via the Covenant mailbox. Putting the Covenant fully into law is essential to further remove disadvantage for the Armed Forces community and will see their needs taken into account during policy development and decision making.
Officials are currently developing plans to extend the Covenant Duty to all UK Government Departments, Devolved Governments and to a wider range of policy areas. This will reinforce this Government’s manifesto commitment of resetting the nation’s commitment to the Armed Forces community. It will also seek to fully embed the Armed Forces community in policy development and decision making. The approach taken when applying the Covenant Legal Duty mirrors the Public Sector Equality Duty, which is an embedded part of policy development. The Covenant Legal Duty ensures, like the Public Sector Equality Duty, that consideration of the Armed Forces community is not a one-off action but becomes a continuous process.
The MOD continues to work with organisations to ensure the duty is understood. As noted previously, the MOD is also developing training materials, webinar training sessions and downloadable resources which will be available following the passage through Parliament. These will be publicly available through the Covenant website and will be shared across all stakeholders to enable understanding. This will also increase the awareness of the Covenant as the accessible online format will provide materials for training and support to a broad audience. This will also work to embed understanding of what is required by stakeholders to comply with the extended Legal Duty.
8. The Government is right to recognise that the existing Covenant Duty does not reach into many areas of life in which the service community faces disadvantage, and to consider expanding the scope of the Covenant Legal Duty. As noted in the previous chapter, extending the Legal Duty will only achieve meaningful results if it is also deliverable. The extension of the Duty must therefore be co-designed with those who will be bound by it and expected to deliver it, and they must be appropriately resourced to enable them to do so. Otherwise, there is a risk that existing commitments will be diluted and that those who deliver the Covenant will only be able to provide the bare minimum of support. Such an outcome would let down the forces community (Conclusion, Paragraph 30)
9. The Covenant Legal Duty should be expanded to cover the breadth of areas in which members of the Armed Forces community regularly experience disadvantage. The Government should work closely with local authorities and other bodies who might be required to deliver an expanded Covenant Duty to co-design a Duty that meets the needs of the forces community and that can be delivered in the context of severe constraints on their resources (Recommendation, Paragraph 31)
The MOD acknowledges the conclusion at Paragraph 30 and the recommendation at Paragraph 31. We are actively seeking opportunities to enhance support for Armed Forces communities in alignment with HMGs manifesto commitment. We value the participation of Local Authorities and other signatories who are tasked with implementing the Covenant principles.
Officials were directed to take a “maximalist” approach to policy areas in scope for the Covenant Duty extension. MOD officials undertook an extensive research and engagement programme exercise to identify areas where the Armed Forces community may experience disadvantage. This included hosting roundtable discussions and other workshops with more than 150 organisations. Following extensive consultation and from anecdotal evidence provided through a dedicated Covenant mailbox (where people can raise any concerns and questions), it is likely that there are several areas where disadvantages arising from Service, could be improved through the inclusion in the Duty extension. We anticipate that plans for the duty extension will raise awareness of the Covenant and drive further, positive outcomes for the Armed Forces community.
We acknowledge that the expansion of the Covenant Legal Duty will place an additional strain on Government Departments and Local Authorities. We will continue to conduct extensive engagement to ensure resourcing constraints are considered. To mitigate any additional burden on Local Authorities, the MOD is co-developing a new burdens assessment, alongside Ministry of Housing, Communities and Local Government (MHCLG) and the Local Government Associations. Again, the MOD will be providing training materials, webinar sessions and downloadable resources to support organisations in their delivery of the Covenant Duty. These will help these bodies comply with their legal obligations.
10. The evidence available to help us understand how well the Covenant is working is currently very fragmented. This makes recognising success, learning lessons and holding organisations to account difficult. The Minister told us there were ‘plans afoot’ to create structures that can improve Government’s understanding of how well the Covenant is working. (Conclusion, Paragraph 36)
11. The Government should provide the Committee with an update, in its response to this Report and when it gives evidence to the Committee on the Covenant Annual Report in the future, on the work it is doing to improve data collection and sharing of how the Covenant is being delivered. (Recommendation, Paragraph 37)
MOD acknowledges with the Committee’s conclusion at Paragraph 36 and accepts the recommendation at Paragraph 37. The MOD currently utilises the Covenant Annual Report to assess the success of the Covenant through monitoring progress, stakeholder engagement, governance, and lessons learned. Furthermore, the MOD gathers direct feedback from cohorts covered by the Covenant via the Covenant website and a dedicated online mailbox, receiving over 5,000 unique hits per month, this is used to identify and where possible, resolve service-related disadvantages. The MOD is aware that the evidence currently available to measure the success of the application of the Covenant Duty is limited and we recognise the importance of improving data collection and governance to target better and more consistent outcomes for our people.
Engagement with OGDs, Devolved Governments and the Third Sector continues. The MOD hold regular round tables which provide opportunity for raising awareness of the planned policy and Duty Extension developments, and collaborative discussions including policy development and best practice with stakeholders across Government, the Devolved Governments, Local Authorities and the Third Sector. As previously noted in this response, the Covenant team hosts an annual conference with the Devolved Governments and Local Authorities which are forums to share best practices. The next Covenant conference is to be held in July 2025, which we plan to encourage organisations to share their experiences in delivering the Covenant duty and raise awareness about the unique needs of the Armed Forces community and recognise success.
12. To enable proper scrutiny of cross-government efforts to implement the Covenant, Whitehall departments should provide an annual update on actions they have taken to uphold the Covenant as part of the Covenant Annual Report, along with outcomes. Departments should–when requested to do so by the Committee–make themselves available to give evidence as supporting witnesses alongside MOD as part of the Committee’s scrutiny of the Covenant Annual Report (Recommendation, Paragraph 38)
We thank the Committee for its recommendation at Paragraph 38. The delivery of the Covenant is regularly subject to parliamentary scrutiny through the annual legal obligation on the Secretary of State for Defence to report progress on delivering the Covenant across the UK to Parliament. The Covenant also remains subject to regular Parliamentary scrutiny through Parliamentary Questions and reviews by the House of Commons Defence Select Committee.
The MOD has already committed and will continue to commit to work with officials in OGDs to highlight areas of success and areas for improvement. The Covenant Annual Report already features some of the work carried out to support the Armed Forces community by wider Government departments, Devolved Governments and Third Sector organisations and the MOD will continue to seek their input. In light of the expanding scope of the Covenant, the MOD will engage with OGDs to consider how best they can report against their obligations.
The MOD acknowledges that there are still some areas that require improvement and development to reinforce and strengthen the Covenant. The MOD recognises the importance of proper scrutiny and will commit to providing evidence as part of the Committee’s scrutiny of the Covenant Annual Report. The Minister for Veterans and People has and will continue to encourage OGDs to do the same.
Conclusion
13. The Armed Forces Covenant is a solemn commitment by our whole society to recognise the courage and dedication of our Armed Forces. While progress has been made since the Covenant was introduced, it is still not consistently implemented and as a result our society is falling short of that commitment far too often. The upcoming Armed Forces Bill is an opportunity to renew and reinforce the nation’s promise to those who serve, but this is only part of the change that needs to occur. Understanding of the Covenant needs to be deeply embedded in our institutions and in wider society so that those who have served can be in no doubt that the Covenant is there to support them. The Covenant gives us all a duty to our service men and women; we must take it as seriously as they have taken their duty to us (Conclusion, Paragraph 39)
We agree with the Committee’s conclusion at Paragraph 39. The Government values the contribution the Armed Forces community has made in support of the UK’s security and defence. We recognise the sacrifices made by service personnel and their families sacrifices that are often not shared by wider society. The MOD remains wholly committed to honouring these sacrifices and to supporting the Armed Forces community.
It is important to recognise the Covenant continues to have a significant, positive impact on the Armed Forces community. Some examples of positive changes include the following:
- To support Armed Forces children with Special Educational Needs and Disabilities (SEND) facing service-related disadvantages from frequent moves, the DfE recently published non-statutory guidance for Local Authorities on handling Education Health and Care Plans (EHCP) for children with SEND moving in or out of their area. Crucially, it clarified that Local Authorities have the legal flexibility to maintain these plans even when a child temporarily leaves England – a key outcome of close work between the MOD and the DfE, and an important step for Armed Forces families.
- The MHCLG legislated in November 2024 to honour the commitment to support Armed Forces communities, to exempt all former members of the regular Armed Forces from any local connection tests for social housing applied by local councils in England. This ensured that regardless of when they last served, no veteran of the regular Armed Forces would need to meet a local connection test for social housing, ensuring that veterans across the UK have access to the housing support they need.
- The National Health Service (NHS) has developed dedicated pathways to ensure veterans can access support tailored to the unique needs of the Armed Forces community. This marks an important step in recognising and addressing those specific needs. We are committed to continuing to strengthen the valuable work already conducted by those governed by the Covenant Duty and those that have signed the pledge.
The MOD believes that enshrining the Armed Forces Covenant fully into law will help ensure the needs of the Armed Forces community are placed at the forefront of policy and decision makers’ minds. We will continue to explore ways to enhance our support and ensure the Covenant remains a meaningful commitment. The MOD remains dedicated to recognising the unique commitment that members of the Armed Forces and their families make for Defence and hope that embedding the Covenant fully into law will reinforce this Government’s manifesto commitment and renew the contract with those who serve and have served.