UK Covid-19 Inquiry Module 2 Update

Posted onNovember 21, 2025
Isabel Gregory

“Too little, too late” UK Covid-19 Inquiry publishes its conclusions and recommendations on government decision-making during the pandemic.

Yesterday, Baroness Heather Hallet, Chair of the UK Covid-19 Inquiry, published her highly anticipated report examining government decision-making during the pandemic, delivering a series of damning indictments on the governance of the UK's pandemic response.

Directly from the report:

“The earliest indications in April 2020 that people from ethnic minority groups were at a heightened risk of becoming infected by Covid-19 ought to have been translated into swift action by each of the four governments. They should have had access to data demonstrating the extent to which specific groups were being exposed to greater risk and - crucially – why. There ought to have been clearer sponsorship at the most senior levels of government, of a strategy targeted at reducing the risks to each of those ethnic groups shown to be particularly vulnerable. This required proper and sufficient expertise at the heart of the policy on, and operational response to, the pandemic.

[…]

In future national emergencies, it is imperative that the response assumes that those who are already disadvantaged will be exposed to greater risk of infection and dying; that, in part, this may be linked to their occupations; and that these factors make it more likely that people from ethnic minority groups will be exposed to greater risk. There must then be a clear strategy from the outset to reduce the risks to which they are exposed.”

About the UK Covid-19 Inquiry

The UK Covid-19 Public Inquiry was established to examine the preparedness, response and handling of the pandemic. The Inquiry has taken a modular approach with ten focused areas of examination. Module 2, focusing on government decision-making, heard evidence in Autumn-Winter 2023.

About FEMHO
The Federation of Ethnic Minority Healthcare Organisations represents the interests of Black, Asian and Minority Ethnic healthcare workers and communities in the UK Covid-19 Inquiry.

Legal Representation
Saunders Law's team is led by Cyrilia Davies Knight and Isabel Gregory, working alongside a counsel team comprising:

Leslie Thomas KC and Una Morris (Garden Court Chambers)
Philip Dayle (39 Essex Chambers)
Elaine Banton (7BR Chambers)
Ifeanyi Odogwu (Matrix Chambers)

Saunders Law also represents the Covid Airborne Transmission Alliance in Module 3 of the Inquiry.

Disproportionate Impact on Minority Ethnic Healthcare Workers

FEMHO's participation in the Inquiry has focused on the devastating and disproportionate impact of the pandemic on Black, Asian and Minority Ethnic healthcare workers and communities. The statistics are stark:

The first 10 doctors to die from coronavirus in the UK were all from minority ethnic groups
By April 2020, 95% of doctors and 64% of nurses who had died were from these communities, despite representing only 44% and 20% of those staff groups respectively
A 2021 UK-REACH study found ethnic minority healthcare workers accounted for 65-76% of deaths during the first year, despite comprising less than 20% of the NHS workforce
These communities also faced compounded socioeconomic disparities

Key Conclusions

The Inquiry's full report can be found online here: Report

The report delivers a damning assessment of the government's pandemic response, with key findings including:

Systemic Failures in Decision-Making

All core decisions came too little, too late
Harsh measures, including lockdowns, could have been avoided through earlier decisive action
Lessons from the first wave were not learned or applied in subsequent waves
Central government decision-making was undermined by a toxic culture that prioritised volume and visibility of advice over quality

Foreseeable and Preventable Disparities:

Those who suffered most were already socially and economically disadvantaged, with ethnic minorities experiencing the highest mortality rates
The disparate impact was foreseeable but not adequately addressed
Occupational exposure emerged as a critical risk factor affecting not only infection rates but also hospitalisation and mortality
No UK government systematically considered how their decisions would affect vulnerable groups

Structural Deficiencies:

Decision-making groups lacked diversity and failed to recognise the reality of home life for much of the population they served
No centralised oversight existed to monitor or address differential impacts across society
Efforts to address disparities were underestimated and fragmented

Data and Communication Failures:

Disaggregated ethnicity data was insufficiently collated and analysed, preventing proper understanding of who was most vulnerable and how interventions should be calibrated
Despite the absence of formal data, emerging evidence left little doubt about the disproportionate impact on ethnic minority communities
Inadequate financial support undermined infection control measures, as many lacked the economic means to self-isolate
Public messaging often failed to reach vulnerable groups, lacking accessibility and clarity

Key Recommendations

Baroness Hallet has put forward 19 recommendations aimed at preventing a repeat of these failures. Critical recommendations include:

Legislative Action:

Recommendation 6: Implement a socio-economic duty by bringing Section 1 of the Equality Act 2010 into force across the UK. Currently, only Scotland and Wales have taken this essential step, leaving England and Northern Ireland without this protection.

Systematic Protection for Vulnerable Groups:

Recommendation 8: Create a comprehensive framework for identifying and protecting those at risk during emergencies, addressing both direct disease impact and the consequences of response measures. The framework must include:
Specific, actionable steps to mitigate risks
Equality impact assessments as standard practice (with provisions to reinstate them promptly if crisis conditions initially prevent their completion)

Fundamental Principles for Future Emergencies:

The report establishes critical principles that must guide future pandemic responses:

Assume disproportionate impact: Emergency responses must operate on the presumption that disadvantaged groups will face greater infection and mortality risks, with ethnic minority communities particularly affected due to factors including occupational exposure
Proactive strategy from day one: Clear strategies to reduce risks for vulnerable groups must be implemented at the outset, not as an afterthought
Targeted interventions: Planning must inform the design of interventions specifically calibrated to protect those most at risk
Ministerial oversight of indirect harms: Proper governance structures with ministerial accountability must be established early to identify and mitigate the unintended consequences of emergency measures

FEMHO's Response to the Report

“The report acknowledges that black and brown people were disproportionately affected by Covid. Indeed, the first 10 doctors who died were of Black and Asian Ethnic Minority.

Our central complaint for advocacy at the inquiry was that there was no consideration of health inequality due to race and ethnicity- or as we described it, ‘structural racism’. The devastating outcome for black and brown people was described by Sir Patrick Valance as ‘entirely foreseeable’, given what was known of existing health inequality.

The fact that the inquiry has not accepted the role of structural racism is a missed opportunity .

FEMHO continues to believe that the first step in pandemic planning must be to acknowledge existing health inequality along the lines of race and ethnicity. The report’s failure to do this, sadly, means that history will repeat itself.

As it stands, FEMHO must conclude that the recommendations are a whitewash.”

Ade Adeyemi on behalf of FEMHO, quotes from Module 2 hearings regarding structural racism "if it quacks like a duck"

[FROM UK COVID-19 INQUIRY M2 [Transcript Ref: [107 – 8/12] (Friday 6 October 2023)

https://covid19.public-inquiry.uk/hearings/core-uk-decision-making-and-political-governance-module-…

CTI: I mean, what you're describing, Professor Nazroo was here yesterday, he would term that structural racism. Is that how you define it?

ADE: If it quacks like a duck and it walks like a duck, it's a duck]

Cyrilia Davies Knight, partner at Saunders law representing FEMHO, comments: The main point of advocacy for our client FEMHO, in Module 2 of the Covid-19 Inquiry was that there was no consideration of health inequality due to race and ethnicity - or as they described it, ‘structural racism’. Former Chief Scientific Advisor, Sir Patrick Valance said in his evidence to the Inquiry that it was ‘entirely foreseeable’ that there was a disproportionately adverse outcome among black and brown people, given what was known of existing health inequality.

Our client is of the view that the inquiry’s failure to accept the role of structural racism, properly so called, is very disappointing. They believe that this failure effectively means that not much progress will have been made for the next pandemic and there remains a heightened risk to members of their community.

Isabel Gregory, solicitor at Saunders Law, adds: “The evidence heard in Module 2 was a stark reminder that structural inequalities, left unaddressed, cost lives. FEMHO, and the ethnic minority healthcare workers it represents - as well as their families and wider communities - bore the brunt of the pandemic on the frontline and suffered disproportionately, but it didn’t have to be that way. The fact that the heightened risk of disparate impact has been recognised as foreseeable is welcomed; but it is disappointing that the report has not gone further in commenting on the underlying reasons for this (in particular the role of structural racism) nor the concrete recommendations so urgently needed to address and reduce future risk of harm.

The sad fact is that there has been opportunity after opportunity after opportunity to act on these issues but very little has changed. FEMHO understandably fears that, in the absence of an acknowledgement of the role of structural racism or robust recommendations, this will amount to another missed opportunity rather than the turning point they hoped it would be.”

About Saunders Law

Saunders Law offer expert legal representation and assistance in Public Inquiries and are well-known and highly regarded for our expertise and our thorough, compassionate, approach to complex cases. In addition to the Covid-19 Inquiry, our recent work has included representing Core Participants in the Grenfell Tower Inquiry, Infected Blood Inquiry and the Undercover Policing Inquiry.