The COVID-19 pandemic exposed deep flaws in how Wales plans for and responds to emergencies. The UK COVID-19 Inquiry's Module 1 report, published in July 2024, concluded that Wales's resilience systems were inefficient and needlessly complex, and set out ten recommendations for reform.
Since then, the Senedd has been examining how far the Module 1 recommendations have been acted on. In March 2025, the Wales COVID-19 Inquiry Special Purpose Committee published a report highlighting areas where the UK Inquiry did not fully address Wales’s specific circumstances. Following its dissolution in October 2025, the Public Accounts and Public Administration Committee (PAPAC) took on this work, scrutinising the Welsh Government’s response to the Module 1 report and its preparedness for future emergencies. Its report will be debated in Plenary on 18 March.
This article explores some of the key issues that have emerged.
A ‘labyrinthine’ system
The UK Inquiry’s central criticism of Wales’s civil contingency arrangements was their complexity. Too many entities, overlapping responsibilities and unclear lines of accountability left the system struggling to function effectively. Similar observations were made by Audit Wales as far back as 2012, yet little was done before the pandemic to simplify these arrangements.
Emergency responders who gave evidence to PAPAC acknowledged that some degree of complexity is unavoidable given the range of government bodies, agencies and partner organisations involved in responding to major incidents. What matters most, they argued, is having clear lines of accountability within that system.
The Welsh Government has made efforts to simplify these structures since the pandemic. The Wales Resilience Framework 2025 sets out revised governance arrangements, including the reconstitution of the Wales Resilience Forum, a body chaired by the First Minister that brings together senior leaders to coordinate Wales's approach to emergency preparedness.
These revised structures were tested in response to 31 real-world incidents in 2025. The First Minister has pointed to the relative absence of public disruption during those incidents as evidence that they are working.
Measuring what works
A recurring theme in PAPAC’s evidence was the difficulty of knowing whether Wales’s revised arrangements are actually delivering better outcomes. Current assessment appears largely qualitative, relying on lessons-learned reporting and subjective feedback from the responder community.
Elsewhere, other governments have developed more objective approaches to measuring and evaluating preparedness. For example, Canada’s Emergency Preparedness and Response Programme tracks quantitative indicators—such as the percentage of exercise objectives met and recommendations implemented following incidents—while in the United States, annual National Preparedness Reports assess performance against core capability targets. In the Australian State of Victoria, the Inspector-General for Emergency Management conducts system-wide evaluations of the state’s emergency management arrangements.
PAPAC’s report recommends that the Welsh Government adopt a similar approach, publishing measurable performance indicators with annual reporting and an independent review mechanism.
Exercise Pegasus
The UK Inquiry criticised pre-pandemic exercises as “bureaucratic and ineffective,” focused more on process than on learning. Exercise Pegasus, a UK-wide pandemic preparedness exercise carried out in autumn 2025, was intended to mark a departure from that pattern.
However, witnesses offered mixed views on whether it has achieved that aim. Public Health Wales described the exercise as a “game changer,” but others raised concerns about gaps in its scope, including the absence of compound risk scenarios (such as a pandemic coinciding with severe flooding or prolonged utility failure) along with limited involvement from social care and the voluntary sector.
A phase focused on pandemic recovery is scheduled for the spring, with the findings to be published shortly after. When published, these findings will reveal whether Exercise Pegasus represents a genuine shift, or a repeat of past patterns.
The voluntary sector: an under-used resource
PAPAC heard that voluntary organisations play a vital role in connecting statutory services with communities, delivering practical support and accessing networks that government agencies struggle to reach. During emergencies, they can also act as trusted messengers, reaching groups who are less likely to engage with formal communications in language and formats that reflect those communities’ experiences.
Yet while the UK Inquiry noted that Wales’s voluntary sector was more embedded in emergency planning than in other UK nations, it seems this capacity is not being fully utilised. The British Red Cross told PAPAC it was unable to help people affected by the recent floods in Monmouthshire because statutory agencies would not share relevant data. Similarly, the Wales Council for Voluntary Action explained that there is no standing mechanism to distribute funds quickly through trusted voluntary partners during emergencies. Race Council Cymru also reported not being contacted about resilience planning since the pandemic, despite the disproportionate impact of COVID-19 on ethnic minority communities.
These concerns are not new. Similar issues were raised by the Equality, Local Government and Communities Committee during the Fifth Senedd and remain unresolved. At the same time, the sector is under significant financial pressure, with several organisations telling PAPAC they would be less able to respond to a major emergency today than in 2020.
Unequal impacts
The pandemic’s impact was profoundly unequal. Age, sex, ethnicity, disability and socioeconomic status all shaped a person’s likelihood of serious illness or death, and the public health measures introduced in response disproportionately affected certain groups and deepened existing inequalities.
Official guidance often overlooked the practical realities and diverse experiences of people’s lives. Wales also lacked any independent risk assessment framework before the pandemic, relying entirely on UK-level analysis that did not consider the specific circumstances of the Welsh population—something the UK Inquiry identified as a fundamental flaw. Persistent gaps in equality data, particularly around ethnicity, compounded these problems.
Building Communities Trust saw these failures as symptomatic of a deeper flaw in how health policy is designed and applied:
Health policy is largely socially blind. It doesn't take into account, to a large degree, the different socioeconomic characteristics of different people. Therefore, you have a one-size-fits-all policy, which means that, actually, people who have got more challenging socioeconomic conditions are implicitly disadvantaged.
Since PAPAC began its work, the Equality and Human Rights Commission has taken formal enforcement action against the Welsh Government in the form of a Section 23 legal agreement, after finding consistent failures to comply with the Public Sector Equality Duty.
PAPAC’s report responds to these systemic failures by calling for vulnerability assessments to be embedded in civil contingencies planning, and for organisations representing protected characteristic groups to be formally integrated into emergency communications from the outset.
What comes next?
The UK Inquiry published its Module 2 report in November 2025, focusing on core decision-making and political governance, with Module 2B examining Wales specifically. It found weaknesses in the Welsh Government's early pandemic response and made 19 recommendations which apply across all four nations. These include:
- reforming emergency decision-making structures;
- improving intergovernmental coordination;
- widening participation in the Scientific Advisory Group for Emergencies (SAGE); and
- strengthening parliamentary scrutiny of emergency powers.
Five further reports are planned for 2026, with three more expected in the first half of 2027. PAPAC’s report recommends that the next Senedd prioritises scrutiny of each remaining module, ensuring that as the UK Inquiry's work continues, its findings are examined properly and translated into action in Wales.
Article by John Hitchcock, Senedd Research, Welsh Parliament
