Independent Inquiry into Child Sexual Abuse

Police forces and local authorities in England and Wales must collect data on all cases of known or suspected child sexual exploitation and child sexual exploitation by networks. These data should be separated from other data sets, including data on child sexual abuse, and be disaggregated by the sex, ethnicity and disability of both the victim and perpetrator. This disaggregated data should be used by police forces to inform problem profiling and activities to disrupt and investigate offenders. Local authorities should take account of the disaggregated data when commissioning services for children. The UK government and the Welsh Government should take steps to ensure that these data are being collected and disaggregated in a consistent and accurate way by police forces and local authorities.

In July 2022, HM Government noted the recommendation, stating that the Home Office was working with police to improve the collection, analysis and use of child sexual exploitation data (Home Office response, Jul 2022; Home Office, Jul 2022). It highlighted funding for dedicated regional analysts and a mandatory duty from March 2022 for forces to record the ethnicity of suspects arrested in grooming gang investigations, with the first publications expected in late 2023 (Home Office response, Jul 2022). The record holds no update since the government's response of July 2022 (Home Office response, Jul 2022; Home Office, Jul 2022).

The Chair and Panel recommend that the National Police Chiefs' Council ensures that complaints relating to child sexual abuse are no longer 'disapplied' by police forces on the grounds that the incident involved took place more than 12 months before the complaint was submitted.

The recommendation asks police forces not to disapply child sexual abuse complaints after 12 months. The Independent Inquiry into Child Sexual Abuse, summarising a response of January 2019 on a web page archived in October 2022, reported that National Police Chiefs' Council lead Chief Constable Craig Guildford advised chief officers to change their approach, and that statutory guidance issued by the Independent Office of Police Conduct in February 2020 omitted disapplication (The Independent Inquiry into Child Sexual Abuse, Oct 2022). Earlier, in December 2018, HM Government stated that the recommendation was directed to the council, which had responded separately (HM Government response, Dec 2018).

The Home Office should coordinate the development of a national plan of action addressing child sexual abuse and exploitation overseas by UK nationals and residents of England and Wales, involving input from all lead governmental agencies in the field.

The Inquiry recommended coordinating a national action plan against overseas child sexual abuse. In January 2021, HM Government stated that the Home Office would implement the recommendation within its forthcoming Tackling Child Sexual Abuse Strategy (Home Office response, Jan 2021; Home Office, Jan 2021). It noted that this strategy would set out actions involving the National Crime Agency (NCA), the intelligence community, and the third sector to prevent offending abroad (Home Office response, Jan 2021). In October 2022, the Independent Inquiry into Child Sexual Abuse reported that the department had confirmed implementation through that strategy (Independent Inquiry into Child Sexual Abuse, Oct 2022).

The Church of England should make changes and improvements to the way in which it responds to safeguarding complaints (whether related to allegations of abuse, or a failure to comply with or respond to the Church's safeguarding policies and procedures) to: disapply the 12-month time-limit for all complaints with a safeguarding element brought under the Clergy Discipline Measure; reintroduce the power to depose from holy orders where a member of the clergy is found guilty of child sexual abuse offences; introduce a mandatory 'code of practice' to improve the way that safeguarding issues are handled across the Clergy Discipline Measure and capability procedures, including a framework for responding to issues that do not amount to misconduct; make clear that penalty by consent must never be used in relation to such complaints; ensure confidentiality agreements are not put in place in relation to such complaints; and ensure that those handling such complaints are adequately and regularly trained.

The Independent Inquiry into Child Sexual Abuse reported in October 2022 that the Church of England stated in March 2021 that it endorses proposals to replace the Clergy Discipline Measure 2003 with a new set of provisions (The Independent Inquiry into Child Sexual Abuse, Oct 2022). The inquiry noted that these provisions would include a disciplinary process, a mandatory code of practice, and the removal of the 12-month time limit for safeguarding-related complaints (The Independent Inquiry into Child Sexual Abuse, Oct 2022). It also recorded that the church intended to bring forward legislation to reintroduce the power to depose from holy orders as soon as practicable, while the National Church Institutions' Legal Office had taken steps to introduce new training for diocesan complaint handlers (The Independent Inquiry into Child Sexual Abuse, Oct 2022).

The Catholic Bishops' Conference of England and Wales should request that the Holy See redraft the canonical crimes relating to child sexual abuse as crimes against the child.

The Independent Inquiry into Child Sexual Abuse reported in October 2022 that the Catholic Council for the Inquiry confirmed in September 2021 that revised canonical penal legislation would come into force on 8 December 2021 (The Independent Inquiry into Child Sexual Abuse, Oct 2022). The inquiry recorded in October 2022 that the council accepted the recommendation and asked the Holy See to redraft canonical crimes, framing child sexual abuse as an offence against human dignity rather than clerical obligations (The Independent Inquiry into Child Sexual Abuse, Oct 2022).

The Catholic Bishops' Conference of England and Wales and the Conference of Religious should publish a national policy for complaints about the way in which a safeguarding case is handled. The policy should deal with communication with complainants during the complaints process and set out an escalation process for all complainants to have their complaint assessed by an independent adjudicator, if they are unhappy with how their complaint has been handled.

The Independent Inquiry into Child Sexual Abuse reported in October 2022 that the Catholic Council for the Inquiry stated in April 2021 that a framework and template for complaints, including clear communication and an escalation process, was ratified by the Bishops in November 2020 (The Independent Inquiry into Child Sexual Abuse, Oct 2022). It also reported in October 2022 that by November 2021, the CSSA website had launched containing the National Safeguarding Standards, the National Safeguarding policy, and practice guidance documents (The Independent Inquiry into Child Sexual Abuse, Oct 2022).

The government should introduce legislation to: change the definition of full-time education, and to bring any setting that is the pupil's primary place of education within the scope of the definition of a registered educational setting; and provide the Office for Standards in Education, Children's Services and Skills (Ofsted) with sufficient powers to examine the quality of child protection when it undertakes inspections of suspected unregistered institutions.

The UK Government has provided no direct response on the record, but in December 2023 the Independent Inquiry into Child Sexual Abuse reported that the government stated on 2 March 2022 that it had considered responses to a 2020 consultation on proposals to amend registration requirements for independent education settings and would publish its response (The Independent Inquiry into Child Sexual Abuse, Dec 2023). The Inquiry also reported that the government noted a prior commitment by the Department for Education to increase the powers available to Ofsted when conducting inspections under section 97 of the 2008 Act, including in the Integrated Communities Action Plan 2019 (The Independent Inquiry into Child Sexual Abuse, Dec 2023).

The government should amend the Sentencing Act 2020 to provide a mandatory aggravating factor in sentencing in the case of the commission of an offence under Part 1 of the Sexual Offences Act 2003 relating to a child, where (1) the child was exploited, (2) 'exploitation' means the child was controlled, coerced, manipulated or deceived into sexual activity and (3) two or more persons were concerned in the exploitation.

The Home Office and the Ministry of Justice stated in May 2026 that the Crime and Policing Act 2026 includes provisions to "legislate to make grooming an aggravating factor in the sentencing of child sexual offences" (Home Office and Ministry of Justice, May 2026). HM Government had previously stated in July 2022 that the factors set out in the recommendation were already adequately covered by existing criminal law and sentencing guidelines (Home Office response, Jul 2022; Home Office, Jul 2022).

As referenced in its Tackling Child Sexual Abuse Strategy, the government should publish an enhanced version of its Child Exploitation Disruption Toolkit as soon as possible. This Toolkit must: specify that the core element of the definition of child sexual exploitation is that a child was controlled, coerced, manipulated or deceived into sexual activity; include specific guidance on building effective problem profiles for child sexual exploitation and child sexual exploitation by networks, as differentiated from other forms of exploitation; specifically state the sources and types of data that agencies should use to build problem profiles; and indicate the minimum frequency at which problem profiles should be updated.

In July 2022, HM Government stated that it had accepted and delivered on the recommendation, having published an enhanced Child Exploitation Disruption Toolkit on 19 July 2022 (Home Office response, Jul 2022; Home Office, Jul 2022). It explained that the updated toolkit highlights key signs of child sexual exploitation such as coercion and deception, and provides guidance to support local services in building effective problem profiles (Home Office response, Jul 2022). The record holds no update since the government's response of July 2022 (Home Office response, Jul 2022; Home Office, Jul 2022).

The Department for Education should ban the placement in semi-independent and independent settings of children aged 16 and 17 who have experienced, or are at heightened risk of experiencing, sexual exploitation. This should be implemented without delay.

In July 2022, HM Government did not accept the recommendation, stating that it did "not believe that a blanket ban would aid local authorities in making these decisions" (Home Office response, Jul 2022; Home Office, Jul 2022). It stated that local authorities are best placed to decide on placements in a child's best interests, noting they have statutory duties to assemble placements that manage individual risks while Ofsted holds them to account (Home Office response, Jul 2022). The record holds no update since the government's response of July 2022 (Home Office response, Jul 2022; Home Office, Jul 2022).

The Inquiry was told that children should only be placed in custody as a last resort. However, it was concerned to hear evidence that some children are remanded in custody because of a lack of appropriate community provision. Given that the proportion of children in custody on remand is so high, this is an issue of significant concern. The Chair and Panel recommend that the Youth Custody Service commissions research into why the child remand population is as high as it is. If the reason is a lack of appropriate community provision (nationally or in certain areas), or otherwise unrelated to a genuine need for those children to be remanded in custody, the Chair and Panel recommend that the Youth Custody Service, with appropriate partner agencies, puts an action plan in place to address this.

The Inquiry asked the Youth Custody Service to research why child remand is high. The Independent Inquiry into Child Sexual Abuse, summarising a Ministry of Justice response of July 2019 on a web page archived in October 2022, recorded that the Police, Crime, Sentencing and Courts Act 2022 received Royal Assent in April 2022, with section 157 tightening legal tests for remanding children to custody (The Independent Inquiry into Child Sexual Abuse, Oct 2022). In January 2022, the department published its review of custodial remand for children, which examined factors behind the rising remand proportion, highlighted the "ethnic disproportionality of remand", and committed to considering greater use of bail and local authority provision (The Independent Inquiry into Child Sexual Abuse, Oct 2022).

The Chair and Panel recommend that the Department for Education and the Youth Custody Service conduct a full review of the practice of placing children for justice and welfare reasons together in SCHs to establish whether it increases the risk of sexual abuse to children. If so, appropriate action should be taken, including consideration of alternative models. The review should be completed within three months, and an action plan should be published within six months.

The Inquiry asked the Department for Education to review mixed placements in secure children's homes. In May 2021, HM Government stated in a response published by the department that it commissioned research and internal data analysis to review placement practice (Department for Education, May 2021). It reported that existing evidence did not suggest placing children on justice and welfare grounds together presents greater risk than single-purpose homes (Department for Education, May 2021). It concluded that "we do not believe the evidence supports the need to change placement practice at this time", while planning to keep the issue under review (Department for Education response, May 2021). The record holds nothing dated later than the response of May 2021 (Department for Education response, May 2021).

The Chair and Panel consider that the use of pain compliance techniques should be seen as a form of child abuse, and that it is likely to contribute to a culture of violence, which may increase the risk of child sexual abuse. The Chair and Panel recommend that the Ministry of Justice prohibits the use of pain compliance techniques by withdrawing all policy permitting its use, and setting out that this practice is prohibited by way of regulation.

The recommendation asks the Ministry of Justice to prohibit pain compliance techniques. The Independent Inquiry into Child Sexual Abuse, summarising a response of July 2019 on a web page archived in October 2022, recorded that the department confirmed in April 2021 that the Youth Custody Service had established the Independent Restraint and Behaviour Panel (The Independent Inquiry into Child Sexual Abuse, Oct 2022). It noted that in June 2020 the department published the Charlie Taylor Review alongside a response stating it would remove pain-inducing techniques from the Minimising and Managing Physical Restraint (MMPR) syllabus (The Independent Inquiry into Child Sexual Abuse, Oct 2022). However, the review recommended that staff may still use pain-inducing techniques to prevent serious physical harm, and the sources do not mention prohibition by regulation (The Independent Inquiry into Child Sexual Abuse, Oct 2022).

The Chair and Panel recommend that the Ministry of Justice and the Department for Education share policy responsibility for managing and safeguarding children in custodial institutions. This is to ensure that standards applied in relation to children in custody are jointly focussed on discipline and securing child welfare.

The recommendation asks the Ministry of Justice to share policy responsibility for children in custody. The Independent Inquiry into Child Sexual Abuse, summarising a response of July 2019 on a web page archived in October 2022, reported that the department accepted the principle behind the recommendation (The Independent Inquiry into Child Sexual Abuse, Oct 2022). According to the Inquiry, the department stated its ambition was to replace all Youth Offender Institutions and Secure Training Centres with secure schools and Secure Children’s Homes, for which the Department for Education has policy responsibility, while interim work was being conducted to ensure a child-focused ethos (The Independent Inquiry into Child Sexual Abuse, Oct 2022).

Nottingham City Council and its child protection partners should commission an independent, external evaluation of their practice concerning harmful sexual behaviour, including responses, prevention, assessment, intervention and workforce development. An action plan should be set up to ensure that any recommendations are responded to in a timely manner and progress should be reported to City's Safeguarding Children Partnership.

The Inquiry asked Nottingham City Council to commission an independent evaluation of practice regarding harmful sexual behaviour. The Independent Inquiry into Child Sexual Abuse reported in a web page archived in October 2022 that the council stated in July 2021 that the National Society for the Prevention of Cruelty to Children (NSPCC) had undertaken an independent external evaluation of its practice (The Independent Inquiry into Child Sexual Abuse, Oct 2022). The Inquiry recorded in that October 2022 update that an action plan had been developed to disseminate learning and recommendations (The Independent Inquiry into Child Sexual Abuse, Oct 2022). In the same October 2022 update, the Inquiry noted the council's September 2020 statement that audit findings were broadly positive, but the record does not mention prevention, assessment, intervention, or workforce development (The Independent Inquiry into Child Sexual Abuse, Oct 2022).

The Chair and Panel recommend that the Department of Health and Social Care develops a national policy for the training and use of chaperones in the treatment of children in healthcare services. The Chair and Panel recommend that the Care Quality Commission considers compliance with national chaperone policies (once implemented) in its assessments of services.

HM Government stated in July 2019 that NHS England had developed and published chaperone guidance notes to establish clear principles across healthcare settings, and that the Department of Health and Social Care would continue to require the Care Quality Commission to assess providers' chaperone policies during inspections (HM Government, Jul 2019). In October 2022, the Independent Inquiry into Child Sexual Abuse recorded that the guidance had been produced and that the department would maintain these inspection requirements (The Independent Inquiry into Child Sexual Abuse, Oct 2022).

The Chair and Panel recommend that the Welsh Government develops a national policy for the training and use of chaperones in the treatment of children in healthcare services. The Chair and Panel recommend that Healthcare Inspectorate Wales considers compliance with national chaperone policies (once implemented) in its assessments of services.

The Independent Inquiry into Child Sexual Abuse, in a summary of January 2020 responses archived in October 2022, reported that the Welsh Government published guidance for health boards and trusts on good working practice for the use of chaperones during intimate examinations or procedures within NHS Wales (The Independent Inquiry into Child Sexual Abuse, Oct 2022). In the same October 2022 update, it noted that these good working practice guidelines were developed in response to the recommendation in its Interim Report (The Independent Inquiry into Child Sexual Abuse, Oct 2022).

The Chair and Panel recommend that the Department for Education introduces arrangements for the registration of staff working in care roles in children's homes. Registration should be with an independent body charged with setting and maintaining standards of training, conduct and continuing professional development, and with the power to enforce these through fitness to practise procedures. The Chair and Panel recognise that registration may require a period of phasing in, and therefore recommend that priority be given to professional registration of children's home managers.

In November 2022, Claire Coutinho, Minister answering for the Department for Education, stated that the recommendation was "being closely considered" and that the department would set out its response in an implementation strategy in due course (Claire Coutinho, Nov 2022). The Independent Inquiry into Child Sexual Abuse recorded in October 2022 that the department had published findings from a call for evidence and literature review in July 2021, and had confirmed it would keep the recommendation under review (The Independent Inquiry into Child Sexual Abuse, Oct 2022).

The Chair and Panel recommend that the Home Office ensures that the Safeguarding Vulnerable Groups Act 2006 is amended so that, where a fitness to practise hearing has been conducted by the keeper of a relevant register and has resulted in removal of a practitioner from that register for reasons relating to harm or risk of harm to children: the keeper of the register has a duty to refer that information to the Disclosure and Barring Service (DBS), and the DBS, on receiving the referral, has a duty to automatically bar the practitioner from working with children, allowing them the opportunity to make representations to the DBS if they consider the bar to be disproportionate or unfair.

The Inquiry recommended mandatory register referrals and automatic child barring for deregistered practitioners. HM Government stated in July 2019 that the Home Office had asked the Disclosure and Barring Service (DBS) to maintain close engagement with professional bodies, having rejected the proposed statutory duties in December 2018 as disproportionate and unnecessary (HM Government response, Dec 2018; HM Government, Jul 2019). In October 2022, the Independent Inquiry into Child Sexual Abuse found that supervisory authorities have no legal duty to refer cases to the DBS and that not all regulators routinely share information regarding child safeguarding concerns (Independent Inquiry into Child Sexual Abuse, Oct 2022).

The Chair and Panel recommend that the Youth Custody Service takes steps to ensure that its training provides staff with an appropriate understanding of safeguarding in the context of the secure estate, and that this is regularly reviewed and updated.

The recommendation asks the Youth Custody Service to regularly review and update staff safeguarding training. In October 2022, The Independent Inquiry into Child Sexual Abuse recorded that the Ministry of Justice stated in May 2022 that the service was drafting guidance to complement mandatory safeguarding training for new staff, subject to targeted public consultation (The Independent Inquiry into Child Sexual Abuse, Oct 2022). The department also stated in May 2022 that the service intended to publish a Safeguarding Strategy outlining longer term training plans (The Independent Inquiry into Child Sexual Abuse, Oct 2022). In its October 2022 record, the inquiry noted that the service had published a national safeguarding review in October 2019 recommending localized training to address emerging sector needs (The Independent Inquiry into Child Sexual Abuse, Oct 2022).

As the Inquiry set out in its Interim Report, professional registration of the workforce in settings responsible for the care of vulnerable children complements regulation of institutions by a separate, independent regulator. The Government has agreed in principle that professional regulation of staff in children's homes in England could provide an effective additional means of protecting children. It has indicated that it will be conducting an evidence-gathering exercise to inform further action. The Chair and Panel now recommend that the Ministry of Justice introduces arrangements for the professional registration of staff in roles responsible for the care of children in YOIs and STCs. The Interim Report recommendation already applies to staff working with children in SCHs.

The recommendation asks for professional registration of staff caring for children in custodial institutions. The Independent Inquiry into Child Sexual Abuse reported in October 2022 that the Ministry of Justice stated in May 2022 that it was considering the review of evidence on professional registration (The Independent Inquiry into Child Sexual Abuse, Oct 2022). In November 2021, the department concluded that review of stakeholder evidence and stated that it would notify the Inquiry of the outcome as soon as possible (The Independent Inquiry into Child Sexual Abuse, Oct 2022). It had previously consulted across the youth justice sector and worked with the Department for Education to explore options for establishing a register (The Independent Inquiry into Child Sexual Abuse, Oct 2022).

The Chair and Panel note that Prison Service Instruction (PSI) 08/2012, which sets out the mandatory actions for YOIs and STCs for 'maintaining a safe and secure environment', has expired. The Chair and Panel recommend that the Ministry of Justice revises and publishes this PSI to provide clear guidance on how custodial institutions must respond to allegations of child sexual abuse. This should include a requirement for all allegations to be referred to a child protection professional who is independent of the institution. The Chair and Panel also recommend that all institutions, including those which are privately run, publish their safeguarding local procedures in full as well as regular reports about their use, to aid scrutiny and increase transparency.

The Inquiry recommended that the Ministry of Justice revise expired Prison Service safeguarding guidance. In an update published in October 2022, the Independent Inquiry into Child Sexual Abuse reported that the Ministry of Justice stated in May 2022 that early work had started on a framework to replace Prison Service Instruction (PSI) 08/2012, and guidance titled "Keeping Children Safe in Secure Settings" was being drafted (The Independent Inquiry into Child Sexual Abuse, Oct 2022). The Inquiry also noted the department's July 2019 statement that the Youth Custody Service had replaced some aspects relating to the behaviour management of children (The Independent Inquiry into Child Sexual Abuse, Oct 2022). Referring allegations to an independent child protection professional and publishing local safeguarding procedures are not mentioned in the sources (The Independent Inquiry into Child Sexual Abuse, Oct 2022).

The Church of England should introduce appropriate guidance which deals with safeguarding within the context of a religious community affiliated to the Church. It must ensure that these organisations meet adequate requirements for safeguarding and child protection. The needs of victims should be prioritised when designing safeguarding policies and practices. The regulation and management of religious communities should include a mandatory requirement both to have and to follow safeguarding guidance. The requirement to comply with this safeguarding guidance should be the same as would be expected in any other Church institution. There needs to be clarity in respect of how safeguarding should be managed in these communities, along with appropriate auditing of compliance.

This recommendation asks the Church of England to introduce mandatory safeguarding guidance for affiliated religious communities. The Independent Inquiry into Child Sexual Abuse, summarising a June 2019 response from the Church on a web page archived in August 2023, reported that the General Synod would consider Amending Canon No. 40 in July 2020 (The Independent Inquiry into Child Sexual Abuse, Aug 2023). It noted that this amendment would add canon provisions for religious communities and that the National Safeguarding Team planned to revise practice guidance alongside new regulations (The Independent Inquiry into Child Sexual Abuse, Aug 2023). The summary highlighted plans to strengthen the safeguarding responsibilities of episcopal visitors, but did not mention auditing compliance or prioritising the needs of victims (The Independent Inquiry into Child Sexual Abuse, Aug 2023).

The Church of England should amend the current canon requiring clerics to comply with the Bishop's Guidance on Safeguarding. The use of the words 'due regard' in Canon C30 is an acceptable term of art, but lacks sufficient clarity. Very few individuals who gave evidence to the Inquiry said they understood what this meant, including the Archbishop of Canterbury himself.

The Inquiry asked the Church of England to amend its canon on safeguarding due regard. In legislation enacted in October 2021, the Church of England repealed provisions imposing a "duty to have due regard to House of Bishops’ guidance" under several church measures (Church of England response, Oct 2021). It substituted a requirement to comply with a safeguarding code of practice, though Canon C30 itself is not mentioned in the text (Church of England response, Oct 2021). The enactment provided that these repeals would come into force on days jointly appointed by the Archbishops of Canterbury and York (Church of England response, Oct 2021). The record holds nothing dated later than the response of October 2021 (Church of England response, Oct 2021).

Individuals engaged in regulated activity who have failed to undergo a DBS check or complete compulsory training should not be permitted to hold voluntary offices within the Church. Failure by ordained clergy to comply with either requirement should result in disciplinary proceedings.

The recommendation calls for barring non-compliant volunteers and disciplining non-compliant clergy. In a summary of a June 2019 response archived in August 2023, the Independent Inquiry into Child Sexual Abuse reported that the Church of England stated its National Safeguarding Team would review the Parish Safeguarding Handbook and key pieces of guidance by the end of December 2019 (The Independent Inquiry into Child Sexual Abuse, Aug 2023). The Inquiry noted that this review was intended "to ensure that this position is reflected clearly" (The Independent Inquiry into Child Sexual Abuse, Aug 2023).

If religious organisations have undertaken internal reviews or enquiries into individual safeguarding incidents, their findings should be sent to the national review body (set up under the Children and Social Work Act 2017).

Religious organisations should send internal safeguarding review findings to the national review body. In an update archived in August 2023, the Independent Inquiry into Child Sexual Abuse reported that the Church of England stated in July 2022 that all independent learning lessons case reviews commissioned by the Archbishops' Council had been shared with the Child Safeguarding Practice Review Panel (The Independent Inquiry into Child Sexual Abuse, Aug 2023). It also recorded in August 2023 that the church's National Director of Safeguarding would meet with the panel every six months, while updated review arrangements were due to be detailed in a forthcoming House of Bishops policy scheduled for consultation in September 2022 and approval in December 2022 (The Independent Inquiry into Child Sexual Abuse, Aug 2023).

Nottingham City Council should assess the potential risks posed by current and former foster carers directly provided by the council in relation to the sexual abuse of children. They should also ensure that current and former foster carers provided by external agencies are assessed by those agencies. Any concerns which arise should be referred to the appropriate body or process, including the Disclosure and Barring Service, the local authority designated officer (LADO) or equivalent, the fostering panel and the police. Nottinghamshire County Council should assess the potential risks posed by current and former residential care staff and foster carers, which are directly provided by the council, in relation to the sexual abuse of children. They should also ensure that current and former staff in residential care provided by external agencies, and current and former foster carers provided by external agencies, are assessed by those agencies. Any concerns which arise should be referred to the appropriate body or process, including the Disclosure and Barring Service, the relevant regulatory body, the local authority designated officer (LADO), the fostering panel and the police.

The Inquiry asked local authorities to assess risks from foster carers and residential care staff. On its website archived in October 2022, the Independent Inquiry into Child Sexual Abuse reported that Nottingham City Council confirmed in July 2021 that risk reviews of internal and agency foster carers were complete, requiring no further referrals (The Independent Inquiry into Child Sexual Abuse, Oct 2022). It also recorded Nottinghamshire County Council stating in June 2021 that its review of foster carers was complete, while its review of current and former residential care staff remained ongoing (The Independent Inquiry into Child Sexual Abuse, Oct 2022).

The Home Office should introduce legislation permitting the Disclosure and Barring Service to provide enhanced certificates to UK nationals and residents of England and Wales applying for: 1. work or volunteering with UK-based organisations, where the recruitment decision is taken outside the UK; or 2. work or volunteering with organisations based outside the UK, in each case where the work or volunteering would be a regulated activity if in the UK.

The Inquiry recommended legislation permitting Disclosure and Barring Service (DBS) enhanced certificates for overseas work. In January 2021, HM Government stated that it was "not persuaded" that replacing the International Child Protection Certificate (ICPC) with enhanced certificates would make accessing criminal records more effective for overseas employers (Home Office response, Jan 2021; Home Office, Jan 2021). In April 2023, Simon Bailey CBE QPM reported in the Independent Review of the Disclosure and Barring Regime that he found no reason to depart from the government's response, but expected it to review the matter (Simon Bailey CBE, QPM, Apr 2023).

The Home Office should introduce legislation making it mandatory for: (a) all UK nationals and residents of England and Wales to provide a prospective employer overseas with an enhanced DBS certificate before undertaking work with children overseas which if in the UK would be a regulated activity and (b) UK government departments and agencies to require their overseas partners to ensure that UK nationals and residents of England and Wales obtain an enhanced DBS certificate before undertaking work with children overseas which if in the UK would be a regulated activity.

The Inquiry recommended mandatory enhanced criminal record checks for personnel working with children abroad. In January 2021, HM Government stated that it would not introduce the proposed legislation, explaining that foreign employers must operate within their own legal regimes (Home Office response, Jan 2021). It concluded that an extraterritorial approach would not increase safeguarding and would be "almost impossible to monitor and subsequently very difficult to enforce" (Home Office response, Jan 2021; Home Office, Jan 2021). Simon Bailey CBE QPM found in April 2023 that the final report did not repeat this proposal for mandatory certificates (Simon Bailey CBE, QPM, Apr 2023).

The Home Office should ensure explanatory guidance is issued, providing clarity to recruiting organisations and individuals concerning the use of the Disclosure and Barring Service scheme for work and volunteering outside the UK.

The Inquiry asked the Home Office to clarify overseas Disclosure and Barring Service checks. Writing on behalf of the department in April 2022, Daniel Rapport, for the Treasury Solicitor (Government Legal Department), stated that the service was finalising a guidance leaflet to be published by the end of May (Daniel Rapport, Apr 2022). That update described guidance developed specifically for the aid sector and charities, but did not mention individuals, with publication of the leaflet still outstanding (Daniel Rapport, Apr 2022). In January 2021, HM Government stated that the department would work with the service to reinforce guidance directing applicants ineligible for its certificates to the International Child Protection Certificate (ICPC) (Home Office response, Jan 2021; Home Office, Jan 2021).

Government, political parties and other Westminster institutions must have whistleblowing policies and procedures which cover child sexual abuse and exploitation. Every employee must be aware that they can raise any concerns using these policies and that the policies are not limited to concerns specific to a person's employment.

In September 2020, HM Government reported that all government departments had whistleblowing policies in place, supported by a civil service model policy that specifically covers the abuse or mistreatment of children (Cabinet Office response, Sep 2020; Cabinet Office, Sep 2020). It stated in September 2020 that parliamentary procedures remain a matter for both Houses, while noting that an additional cross-government campaign was planned for 2021 (Cabinet Office response, Sep 2020). The record holds no update since the government's response of September 2020 (Cabinet Office response, Sep 2020).

The Cabinet Office must ensure that each government department reviews its child safeguarding policy or policies in light of the expert witness report of Professor Thoburn. There must also be published procedures to accompany their policies, in order that staff know how to enact their department's policy. All government departments must update their safeguarding policies and procedures regularly, and obtain expert safeguarding advice when doing this.

In September 2020, HM Government reported that all departments had been made aware of the recommendation and that Civil Service HR had launched a model safeguarding policy and a "Health Check" process (Cabinet Office response, Sep 2020; Cabinet Office, Sep 2020). It stated that a review of departmental use of these tools was planned for later that year (Cabinet Office response, Sep 2020). The record holds no update since the Cabinet Office's response of September 2020 (Cabinet Office response, Sep 2020; Cabinet Office, Sep 2020).

All political parties registered with the Electoral Commission in England and Wales must ensure that they have a comprehensive safeguarding policy. All political parties must also ensure that they have procedures to accompany their policies, in order that politicians, prospective politicians, staff and volunteers know how to enact their party's policy, which must be published online. All political parties must update their policies and procedures regularly, and obtain expert safeguarding advice when doing this. The Electoral Commission should monitor and oversee compliance with this recommendation.

In September 2020, HM Government partially accepted the recommendation, agreeing that political parties should maintain and publish comprehensive child safeguarding policies, but stating that the Electoral Commission was "not an appropriate regulator" (Cabinet Office response, Sep 2020; Cabinet Office, Sep 2020). It advised in September 2020 that individual parties should work directly with safeguarding experts to review their procedures (Cabinet Office response, Sep 2020). The record holds no update since the government's response of September 2020 (Cabinet Office response, Sep 2020; Cabinet Office, Sep 2020).

The government should publish, without further delay, the interim code of practice in respect of child sexual abuse and exploitation as proposed by the Online Harms White Paper (published April 2019).

The Inquiry asked the government to publish an interim code of practice on child sexual abuse. In November 2020, HM Government stated that it was working with law enforcement agencies and other bodies to produce interim codes to bridge the gap until a regulator is operational (Home Office response, Nov 2020). In that November 2020 response, it confirmed that the interim code would be published alongside the full government response to the Online Harms White Paper (Home Office response, Nov 2020; Home Office, Nov 2020). The record holds nothing dated later than the response of November 2020 (Home Office response, Nov 2020).

The Church of England should create the role of a diocesan safeguarding officer to replace the diocesan safeguarding adviser. Diocesan safeguarding officers should have the authority to make decisions independently of the diocesan bishop in respect of key safeguarding tasks, including: escalating incidents to the National Safeguarding Team, statutory authorities and the Charity Commission; advising on the suspension of clergy in safeguarding matters; investigating and/or commissioning investigations into safeguarding incidents; risk assessments and associated plans for church officers and members of the congregation; and supporting complainants in safeguarding-related issues. Diocesan safeguarding officers should be employed locally, by the Diocese Board of Finance. The diocesan safeguarding officer's work should be professionally supervised and quality assured by the National Safeguarding Team. The National Safeguarding Team should set the broad requirements for anyone applying to be a diocesan safeguarding officer (adapting as required the existing requirements in respect of diocesan safeguarding advisers). It should be enshrined in policy that those who are volunteers and who do not follow the directions of diocesan safeguarding officers should be removed from responsibility of working with children.

The Independent Inquiry into Child Sexual Abuse recorded that the Church of England stated in March 2021 that it would amend Canon C30 and associated regulations to establish diocesan safeguarding officers with independent decision-making authority (The Independent Inquiry into Child Sexual Abuse, Oct 2022). The Inquiry noted in October 2022 that the Church also planned to pilot a regional supervision model and expected revisions to its policy on allegations against church officers to take effect by June 2022 (The Independent Inquiry into Child Sexual Abuse, Oct 2022).

The Church in Wales should make clear that the operational advice of provincial safeguarding officers must be followed by all members of the clergy and other Church officers. It should be enshrined in policy that those who are volunteers and who do not follow the directions of provincial safeguarding officers should be removed from working with children.

The Independent Inquiry into Child Sexual Abuse reported in October 2022 that the Church in Wales stated in January 2022 that its timetable for adopting updated procedural guidance was delayed (The Independent Inquiry into Child Sexual Abuse, Oct 2022). It had previously stated in April 2021 that it introduced a new Disciplinary Tribunal cause of action and would revise policies to make clear that provincial safeguarding officers' operational advice must be followed (The Independent Inquiry into Child Sexual Abuse, Oct 2022). It also stated in April 2021 that it would revise procedural guidelines to establish that volunteers who do not follow directions should be removed from working with children (The Independent Inquiry into Child Sexual Abuse, Oct 2022).

The Church in Wales should introduce record-keeping policies relating to safeguarding, complaints and whistleblowing. These should be implemented consistently across dioceses. The Church should develop policies and training on the information that must be recorded in files. The Church should provide its provincial safeguarding officers with the right to see personnel files of clergy, office holders, employees or others if concerns and complaints are raised about child protection or safeguarding.

The Church in Wales stated in January 2022 that its timetable for adopting updated procedural guidance had slipped, according to an update published by the Independent Inquiry into Child Sexual Abuse in October 2022 (The Independent Inquiry into Child Sexual Abuse, Oct 2022). In that October 2022 update, the inquiry recorded that the church had stated in April 2021 that its national online safeguarding case management system launched in January 2020, and that it agreed guidance was needed to make clear that provincial safeguarding officers may inspect lay personnel files as well as clergy files (The Independent Inquiry into Child Sexual Abuse, Oct 2022).

The Church of England and the Church in Wales should agree and implement a formal information-sharing protocol. This should include the sharing of information about clergy who move between the two Churches.

As reported by the Independent Inquiry into Child Sexual Abuse in October 2022, the Church of England announced in June 2021 that the updated edition of the House of Bishops' handling of Clergy Personal Files policy supports the recommendation on data sharing with the Church in Wales and clarifies the lawful basis for processing clergy data (The Independent Inquiry into Child Sexual Abuse, Oct 2022). The Inquiry also recorded that the Bishops of the Church in Wales approved a corresponding clergy personal files policy taking effect immediately in July 2021, aiming to achieve the full sharing of personnel files between the two churches (The Independent Inquiry into Child Sexual Abuse, Oct 2022).

The Church of England, the Church in Wales and statutory partners should ensure that information-sharing protocols are in place at a local level between dioceses and statutory partners.

The Church of England stated in March 2021, as summarised by the Independent Inquiry into Child Sexual Abuse in October 2022, that it would develop template information-sharing agreements for dioceses to adapt and use with statutory partners (The Independent Inquiry into Child Sexual Abuse, Oct 2022). It also stated that a proposed agreement with the police was being reviewed by all parties, with work expected to conclude by December 2021 (The Independent Inquiry into Child Sexual Abuse, Oct 2022). The inquiry also reported that the Church in Wales stated in April 2021 that discussions were continuing regarding coordinated national conversations with other statutory partners (The Independent Inquiry into Child Sexual Abuse, Oct 2022).

The Church in Wales should introduce independent external auditing of its safeguarding policies and procedures, as well as the effectiveness of safeguarding practice in dioceses, cathedrals and other Church organisations. Audits should be conducted regularly and reports should be published. The Church of England should continue independent external auditing of its safeguarding policies and procedures, as well as the effectiveness of safeguarding practice in dioceses, cathedrals and other Church organisations. Audits should continue to be conducted regularly and reports should continue to be published.

In March 2026, Marsha De Cordova, representing the Church Commissioners, stated that an independent safeguarding audit programme had reviewed the National Safeguarding Team and 22 dioceses, with 17 reports published, remaining reports due soon, and diocesan audits scheduled to run until early 2028 (Marsha De Cordova, Mar 2026). Previously, the Independent Inquiry into Child Sexual Abuse recorded in October 2022 that the Church of England had committed to five-yearly audits, while the Church in Wales planned to audit casework and establish external reviews (The Independent Inquiry into Child Sexual Abuse, Oct 2022).

The Catholic Bishops' Conference of England and Wales and the Conference of Religious in England and Wales should each nominate a lead member of the clergy for safeguarding to provide leadership and oversight on safeguarding matters to their respective Conferences and the wider Roman Catholic Church in England and Wales.

The Independent Inquiry into Child Sexual Abuse reported in October 2022 that the Catholic Council for the Inquiry stated in April 2021 that the role description for the Lead Bishop for the Catholic Bishops’ Conference of England and Wales was approved in March 2021, with Bishop Paul Mason appointed for a term of three years (The Independent Inquiry into Child Sexual Abuse, Oct 2022). It noted in October 2022 that the Conference of Religious had also approved the role description for the Lead Safeguarding Religious and appointed Fr David Smolira SJ as the first lead, with both positions intended to model a "One Church" strategy (The Independent Inquiry into Child Sexual Abuse, Oct 2022).

The Catholic Bishops' Conference of England and Wales should ensure that safeguarding training is mandatory for all staff and volunteers in roles where they work with children or victims and survivors of abuse. It should also be a requirement that regular refresher training is completed. The training should consider the impact of child sexual abuse, including the impact of trauma and the perspective of victims and survivors, and should be developed in conjunction with the Survivor Advisory Panel.

The Independent Inquiry into Child Sexual Abuse reported in October 2022 that the Catholic Council for the Inquiry stated in April 2021 that baseline safeguarding training was already mandatory for clergy and parish safeguarding representatives, supplemented by biennial refresher training (The Independent Inquiry into Child Sexual Abuse, Oct 2022). It also recorded in October 2022 that the reach of mandatory training was being extended to volunteers under a new standards-based approach, with the Survivors' Reference Panel acting as a key player in this work (The Independent Inquiry into Child Sexual Abuse, Oct 2022).

The Catholic Bishops' Conference of England and Wales and the Conference of Religious should publish a clear framework for dealing with cases of non-compliance with safeguarding policies and procedures. That framework should identify who is responsible for dealing with issues of non-compliance at all levels of the Church, and include the measures or sanctions for non-compliance.

The Independent Inquiry into Child Sexual Abuse recorded in October 2022 that the Catholic Council for the Inquiry stated in September 2021 that all Catholic dioceses and religious orders had been invited to enter contractual arrangements with the new Catholic Safeguarding Standards Agency by the end of that year (The Independent Inquiry into Child Sexual Abuse, Oct 2022). It reported in October 2022 that this agency would provide an audit function with powers of sanction to handle non-compliance, with recruitment for an audit team underway as of late 2021 (The Independent Inquiry into Child Sexual Abuse, Oct 2022). It added in October 2022 that work to redraft the General Decree for Safeguarding was continuing as of September 2021 following requests for clarification from the Holy See (The Independent Inquiry into Child Sexual Abuse, Oct 2022).

The Catholic Safeguarding Advisory Service should have the effectiveness of its audit programme regularly validated by an independent organisation which is external to the Church. These independent reports should be published.

The Independent Inquiry into Child Sexual Abuse reported, in an update archived in October 2022, that the Catholic Council for the Inquiry stated in September 2021 that the Catholic Safeguarding Standards Agency Board remained committed to independent verification of its audit processes (The Independent Inquiry into Child Sexual Abuse, Oct 2022). It recorded that the agency planned to undertake a formal process to appoint a suitable external body in spring 2022 and publish review outcomes on its website, following the November 2021 launch of national safeguarding standards (The Independent Inquiry into Child Sexual Abuse, Oct 2022).

The Catholic Safeguarding Advisory Service should review its policies and procedures manual and the documents within it to ensure that they are consistent, easier to follow and more accessible.

The record holds no direct response from the Catholic Safeguarding Advisory Service (The Independent Inquiry into Child Sexual Abuse, Oct 2022). The Independent Inquiry into Child Sexual Abuse reported that in November 2021 the CSSA website had launched containing the National Safeguarding Standards, the National Safeguarding policy, and practice guidance documents (The Independent Inquiry into Child Sexual Abuse, Oct 2022). It recorded that the Catholic Council for the Inquiry had stated in September 2021 that national safeguarding policies and procedures were live documents that remained "subject to review and refinement", following revisions published in early 2020 to reduce complexity (The Independent Inquiry into Child Sexual Abuse, Oct 2022).

Lambeth Council should develop and publish a comprehensive action plan which details the actions that it will take in response to the issues raised throughout the Inquiry's investigation report. The action plan should be developed and published within six months of the publication of this investigation report, and should be accompanied by timescales for completing identified actions as soon as possible.

The London Borough of Lambeth accepted the recommendation in December 2021, publishing an action plan approved by Full Council in which it stated that it had considered lessons learned and formulated actions to "safeguard against the failures of the past being repeated" while charting the course children and young people deserve (London Borough of Lambeth response, Dec 2021). The record holds no update since the council's response of December 2021 (London Borough of Lambeth response, Dec 2021).

All Lambeth Council elected members should receive training on: (i) safeguarding and (ii) corporate parenting. Newly elected members should receive training on these matters as soon as possible following their election. Training should be mandatory and repeated on a regular basis. The training content should be regularly reviewed and updated.

In December 2021, the London Borough of Lambeth accepted the recommendation, setting out plans in its action plan for all newly elected councillors to complete mandatory corporate parenting and safeguarding training during induction, followed by annual refreshers (London Borough of Lambeth response, Dec 2021). It also stated in December 2021 that it would review mandatory training requirements and monitor completion to report non-compliance through formal mechanisms (London Borough of Lambeth response, Dec 2021). The record holds no update since the London Borough of Lambeth's response of December 2021 (London Borough of Lambeth response, Dec 2021).

Lambeth Council should review the application of recruitment and vetting procedures for all current foster carers directly provided by Lambeth Council, to ensure that the procedures have been followed correctly. In addition, Lambeth Council should seek assurances from external agencies and other local authorities, in which children in the care of Lambeth Council have been placed, that recruitment and vetting procedures have been followed correctly for all foster carers and residential children's homes' staff working with children.

In its December 2021 action plan, the London Borough of Lambeth stated that it would ensure foster carers, councillors, and staff working with children have appropriate and up-to-date Disclosure and Barring Service certificates and "implement an online DBS process that enables better monitoring of compliance in line with safer recruitment practice" (London Borough of Lambeth response, Dec 2021). The record holds no update since the council's response of December 2021 (London Borough of Lambeth response, Dec 2021).

All religious organisations should have a child protection policy and supporting procedures, which should include advice and guidance on responding to disclosures of abuse and the needs of victims and survivors. The policy and procedures should be updated regularly, with professional child protection advice, and all organisations should have regular compulsory training for those in leadership positions and those who work with children and young people.

The Independent Inquiry into Child Sexual Abuse reported in December 2023 that the Muslim Council of Britain stated in June 2022 that it was producing mosque-specific safeguarding guidance and templates planned for publication by late 2022 (The Independent Inquiry into Child Sexual Abuse, Dec 2023). The Inquiry also recorded that the Christian Congregation of Jehovah's Witnesses stated in February 2022 that its child protection policy was reviewed regularly and had been updated following the investigation report (The Independent Inquiry into Child Sexual Abuse, Dec 2023). In the same month, the Baptist Union of Great Britain stated that it was working to gather more safeguarding data across its churches to direct support for abuse victims and prioritise resources (The Independent Inquiry into Child Sexual Abuse, Dec 2023).

The Department for Education should review and publish an updated version of its guidance on child sexual exploitation. The update should specify that the core element of the definition of child sexual exploitation is that a child was controlled, coerced, manipulated or deceived into sexual activity. It should also include detailed information on: the role of the internet in the perpetration of child sexual exploitation; and how to identify and respond to child sexual exploitation perpetrated by networks of offenders. The Welsh Government should also update its guidance on child sexual exploitation to provide detailed information on how to identify and respond to child sexual exploitation perpetrated by networks of offenders.

In July 2022, HM Government stated on behalf of the Department for Education that it accepted the recommendation in principle, explaining that it did "not propose making changes immediately" before considering findings from broader child protection reviews (Home Office response, Jul 2022; Home Office, Jul 2022). It added in July 2022 that any future revision to guidance would address the inquiry's proposals on network offending and the role of the internet alongside those wider findings (Home Office response, Jul 2022). The record holds no update since the department's response of July 2022 (Home Office response, Jul 2022; Home Office, Jul 2022).

The Department for Education and the Welsh Government must ensure that their updated national guidance makes clear that signs that a child is being sexually exploited must never be treated as indications that a child is only 'at risk' of experiencing this harm. In line with this, local authorities in England and Wales should ensure that their assessment of risk and harm enables them to accurately distinguish between: children who are at risk of experiencing sexual exploitation; children who are experiencing or have already experienced sexual exploitation; and children who have experienced sexual exploitation and are at risk of experiencing further abuse.

In July 2022, HM Government accepted the recommendation in principle, stating that it did "not propose making changes immediately" while it considered recommendations from the Independent Review of Children’s Social Care and other national reviews (Home Office response, Jul 2022; Home Office, Jul 2022). It added that any future revision to child sexual exploitation guidance would incorporate findings from inspections by HM Inspectorate of Constabulary and Fire and Rescue Services and Ofsted (Home Office response, Jul 2022). The record holds no update since HM Government's response of July 2022 (Home Office response, Jul 2022; Home Office, Jul 2022).

The Department for Education and the Welsh Government should: require all residential special schools to be inspected against the quality standards used to regulate children's homes in England and care homes in Wales; reintroduce a duty on boarding schools and residential special schools to inform the relevant inspectorate of allegations of child sexual abuse and other serious incidents, with professional or regulatory consequences for breach of this duty; if the recommendation above is implemented, residential special schools will automatically be subject to this duty; and introduce a system of licensing and registration of educational guardians for international students which requires Disclosure and Barring Service and barred list checks to be undertaken.

The Inquiry called for strengthened residential school inspections, mandatory abuse reporting, and educational guardian licensing. The Independent Inquiry into Child Sexual Abuse, summarising a June 2022 response on a page archived in July 2022, reported that the UK government planned to strengthen National Minimum Standards (NMS) rather than adopt children's homes quality standards, while considering reporting rules alongside wider mandatory reporting policies and reviewing guardian licensing options (The Independent Inquiry into Child Sexual Abuse, Jul 2022). According to the Inquiry's summary, the Welsh Government also stated in June 2022 that it intended to use regulation-making powers to regulate care and support in residential special schools potentially by December 2023, incorporating notification duties and progressing guardian measures alongside boarding school standards (The Independent Inquiry into Child Sexual Abuse, Jul 2022).

The Department for Education and the Welsh Government should: introduce a set of national standards for local authority designated officers in England and Wales to promote consistency; and clarify in statutory guidance that the local authority designated officer can be contacted for informal advice as well as when a concern or allegation needs to be referred.

The recommendation calls for national standards and clarified statutory guidance for designated officers. The Independent Inquiry into Child Sexual Abuse, summarising a June 2022 response from the UK Government on a web page archived in July 2022, reported that the government was considering the scope and timetable for reviewing the statutory guidance Working Together to Safeguard Children, including revised content on the role of local authority designated officers and a full public consultation (The Independent Inquiry into Child Sexual Abuse, Jul 2022). It also recorded that the Welsh Government stated in June 2022 that designated officers already adhere to professional standards as qualified social workers, and Social Care Wales was working on national minimum standards for safeguarding training (The Independent Inquiry into Child Sexual Abuse, Jul 2022).

The Department for Education and the Welsh Government should: amend the Independent School Standards to include the requirements that there is an effective system of governance, based on three principles of openness to external scrutiny, transparency and honesty within the governance arrangements, and the ability of governors to have difficult conversations both internally and with those providing external scrutiny; amend the Independent School Standards to stipulate that the proprietor cannot be the designated safeguarding lead; and amend the current system of registration of independent schools to apply the same standards to registrants as those applying to open a free school or early years provision.

The Inquiry recommended strengthening independent school governance, safeguarding roles, and school registration standards. In a summary of a June 2022 response archived in July 2022, the Independent Inquiry into Child Sexual Abuse reported that the UK government agreed in principle to revise governance standards and bar proprietors from acting as designated safeguarding leads (The Independent Inquiry into Child Sexual Abuse, Jul 2022). The Inquiry noted the government intended to consult on revised standards in 2023, update safeguarding guidance, and explore aligning independent school registration with free school standards (The Independent Inquiry into Child Sexual Abuse, Jul 2022). It also recorded that the Welsh Government agreed to amend its regulations and registration processes across all points of the recommendation (The Independent Inquiry into Child Sexual Abuse, Jul 2022).

The Department for Education and the Welsh Government should: set nationally accredited standards and levels of safeguarding training in schools; make the highest level of safeguarding training mandatory for headteachers, designated safeguarding leads in England or designated safeguarding persons in Wales, designated safeguarding governors, or the proprietor or head of the proprietorial body; and undertake an urgent review in order to improve the provision and effectiveness of relationships, sex and health education (RSHE) for children with special educational needs and disabilities, both for children who are in mainstream settings and for those in special schools.

The Inquiry asked the Department for Education to establish accredited school safeguarding training standards. The Independent Inquiry into Child Sexual Abuse, in a summary of June 2022 published in July 2022, recorded that the UK Government pledged to consider setting accredited standards and had strengthened guidance for headteachers and designated safeguarding leads (The Independent Inquiry into Child Sexual Abuse, Jul 2022). The summary noted that the government also planned an evaluation of relationships and sex education, including in special schools, though training for school governors or proprietors was not mentioned (The Independent Inquiry into Child Sexual Abuse, Jul 2022). It also reported that the Welsh Government was developing training standards through Social Care Wales for independent schools and considering reviewing its Relationships and Sexuality Education Code for children with additional learning needs (The Independent Inquiry into Child Sexual Abuse, Jul 2022).

The Department for Education and the Welsh Government should: require schools to inform the relevant inspectorate when they have referred a member of staff to the Disclosure and Barring Service, the Teaching Regulation Agency or the Education Workforce Council; and include in the national standards for local authority designated officers a requirement that local authority designated officers should share information on referrals from schools with the relevant inspectorate (see recommendation 2)

The Inquiry asked ministers to require schools to notify inspectorates of staff safeguarding referrals. The Independent Inquiry into Child Sexual Abuse, summarising a June 2022 response from the UK Government in an update archived in July 2022, reported that the government was cautious about introducing mechanisms limited to Disclosure and Barring Service (DBS) and Teaching Regulation Agency (TRA) referrals, but would consider requiring local authority designated officers to share referral information with inspectorates in updated guidance (The Independent Inquiry into Child Sexual Abuse, Jul 2022). The Inquiry also recorded that the Welsh Government accepted the recommendation in principle in June 2022, noting that it required new statutory powers before it could mandate compliance (The Independent Inquiry into Child Sexual Abuse, Jul 2022).

The Department for Education should amend the Teachers' Disciplinary (England) Regulations 2012 to bring all teaching assistants, learning support staff and cover supervisors within the misconduct jurisdiction of the Teaching Regulation Agency. The Department for Education and the Welsh Government should amend Keeping Children Safe in Education and Keeping Learners Safe to: provide more detailed guidance as to the quality, nature and degree of supervision required for supervised volunteers working with children in schools; and make clear that Disclosure and Barring Service checks are free of charge for supervised volunteers, and should be obtained wherever practicable. The Department for Education and the Welsh Government should amend the regulations to provide that inclusion on the children's barred list automatically disqualifies the individual from being a governor or proprietor of any school. The Home Office should amend the Safeguarding Vulnerable Groups Act 2006 so that proprietors and members of the proprietorial body and governors should be checked against the children's barred list.

The Inquiry asked the Department for Education to extend misconduct jurisdiction and strengthen school safeguarding rules. The Independent Inquiry into Child Sexual Abuse, summarising a UK Government response of June 2022 on a web page archived in July 2022, reported that anyone undertaking teaching work can already be referred to the Teaching Regulation Agency (TRA) regardless of role (The Independent Inquiry into Child Sexual Abuse, Jul 2022). It recorded that the government incorporated free Disclosure and Barring Service (DBS) volunteer checks into guidance, agreed in principle to consider supervision guidance, and would consider barring checks for governors alongside the Home Office (The Independent Inquiry into Child Sexual Abuse, Jul 2022). It also noted that the Welsh Government accepted the recommendation in principle in June 2022 and would review guidance and regulations regarding governors (The Independent Inquiry into Child Sexual Abuse, Jul 2022).

The Welsh Government should: update the Independent School Standards as a matter of urgency; update the national minimum standards for boarding schools as a matter of urgency; legislate so that all residential special schools are judged against the quality standards in place for care homes in Wales; ensure that all teachers and learning support staff in independent schools in Wales are required to register with the Education Workforce Council; and consider extending the duty to report a child at risk of harm in section 130 of the Social Services and Well-being (Wales) Act 2014 to independent school staff.

The Inquiry asked the Welsh Government to update independent school standards, registration, and reporting duties. The Independent Inquiry into Child Sexual Abuse, summarising a June 2022 response from the Welsh Government in an update of July 2022, reported that work was ongoing to draft legislation amending independent school regulations and requiring staff to register with the Education Workforce Council (EWC) (The Independent Inquiry into Child Sexual Abuse, Jul 2022). It also noted that the government had begun work to extend the duty to report to independent schools and intended to regulate care in residential special schools, with an implementation date to be agreed, while updating boarding school standards was not mentioned (The Independent Inquiry into Child Sexual Abuse, Jul 2022).

The government should amend Section 21 of the Sexual Offences Act 2003 so as to include clergy within the definition of a position of trust. This would criminalise under s16-s20 sexual activity between clergy and a person aged 16-18, over whom they exercise pastoral authority, involving the abuse of a position of trust.

The Inquiry recommended amending sexual offences legislation to include clergy within positions of trust. In a letter of October 2019, published by the Ministry of Justice in November 2019, Chris Philp MP, Parliamentary Under-Secretary of State for Justice, stated that existing criminal law provided protections against sexual abuse and that a cross-government review of offences had been conducted (Chris Philp MP response, Oct 2019). The Minister explained that the government was considering the review's findings and would announce next steps in due course (Chris Philp MP, Nov 2019). Amending Section 21 to include clergy was not mentioned in the letter (Chris Philp MP response, Oct 2019; Chris Philp MP, Nov 2019).

The government should require industry to pre-screen material before it is uploaded to the internet to prevent access to known indecent images of children.

The Inquiry asked the government to require companies to pre-screen material uploaded to the internet. In November 2020, HM Government stated that an interim code of practice on tackling child sexual exploitation and abuse (CSEA) set out its expectation that companies prevent access to known abuse material (Home Office response, Nov 2020; Home Office, Nov 2020). It noted that pre-screening is one way of preventing access, while recognising that responses vary according to the service offered (Home Office response, Nov 2020). The code builds upon voluntary principles launched with international partners to drive collective industry action (Home Office response, Nov 2020). The record holds nothing dated later than the response of November 2020 (Home Office response, Nov 2020).

The Chair and Panel recommend that the Ministry of Justice, Home Office and Attorney General commission a joint inspection of compliance with the Victims' Code in relation to victims and survivors of child sexual abuse. The Victims' Commissioner should be consulted on the inspection approach to ensure that it is fully informed by the experiences of victims and survivors of child sexual abuse.

HM Government stated in July 2019 that the Ministry of Justice had launched a compliance framework for the Victims' Code on 1 April 2019, with the Criminal Justice Board expected to receive its first national report in early 2020 (HM Government, Jul 2019). In October 2022, the Independent Inquiry into Child Sexual Abuse recorded that the department had paused framework development in October 2020 because of operational pressures during the pandemic, and that the Criminal Justice Joint Inspectorate had suspended joint inspections (The Independent Inquiry into Child Sexual Abuse, Oct 2022). The inquiry noted that the department was looking to restart work and renew engagement with the board subject to operational capacity, and had published a response to its Victims Bill consultation in May 2022 (The Independent Inquiry into Child Sexual Abuse, Oct 2022).

The Chair and Panel recommend that the Association of British Insurers (ABI) considers whether a register of public liability insurers could be introduced to assist claimants in child sexual abuse cases in locating the insurers relevant to their claim, and how it would operate. The Chair and Panel recommend that the ABI sets out its consideration of the issue and the conclusions it has reached in a written update within 12 months of the publication of this report.

The Independent Inquiry into Child Sexual Abuse reported that the Association of British Insurers responded in April 2019, raising questions about the merits of a register of public liability insurers and the challenges of introducing one (The Independent Inquiry into Child Sexual Abuse, Oct 2022). The inquiry noted in October 2022 that the response was referred to in the Accountability and Reparations Investigation report and at an investigation hearing in November 2019 (The Independent Inquiry into Child Sexual Abuse, Oct 2022).

The Chair and Panel recommend that the Ministry of Justice provides in primary legislation that victims and survivors of child sexual abuse in civil court cases, where they are claiming compensation in relation to the abuse they suffered, are afforded the same protections as vulnerable witnesses in criminal court cases. The Chair and Panel understand that cost is already a barrier to victims and survivors considering a civil claim. In considering how to fund the implementation of this recommendation, the Ministry of Justice must ensure that this barrier is not further increased. The Chair and Panel recommend that the Civil Procedure Rule Committee amends the Civil Procedure Rules to ensure that judges presiding over cases relating to child sexual abuse consider the use of protections for vulnerable witnesses.

In July 2019, HM Government stated that a Civil Justice Council subcommittee had drafted a consultation document and would produce a final report that autumn, after which the Ministry of Justice would liaise with the Civil Procedure Rule Committee regarding witness protections (HM Government, Jul 2019). The Independent Inquiry into Child Sexual Abuse recorded in October 2022 that the council published its report in February 2020, the Civil Procedure Rules were amended in April 2021 to require special measures for vulnerable court parties, and provisions in the Domestic Abuse Act 2021 enabled special measures directions in civil cases involving specified offences (The Independent Inquiry into Child Sexual Abuse, Oct 2022).

The Chair and Panel recommend that any police officer (or staff equivalent) who wants to progress to the Chief Officer cadre must first be required to: have operational policing experience in preventing and responding to child sexual abuse; and achieve accreditation in the role of the police service in preventing and responding to child sexual abuse. The Home Office should amend entry requirements using its powers under the Police Regulations 2003 to achieve this. The Chair and Panel recommend that the College of Policing develops the training content and accreditation arrangements.

HM Government confirmed in July 2019 that the College of Policing had made progress in delivering non-legislative changes, having rejected the recommendation in December 2018 because mandatory entry requirements were "not practical and would not achieve the desired aim" (HM Government response, Dec 2018; HM Government, Jul 2019). In October 2022, the Independent Inquiry into Child Sexual Abuse recorded that the Home Office had not identified any need for legislative change but would keep this under review (The Independent Inquiry into Child Sexual Abuse, Oct 2022).

The Ministry of Justice should revise the Victims' Code to make clear that victims and survivors of child sexual abuse must be advised by the police that: 1. They are entitled to seek civil compensation through the civil courts and, if they wish to do so, should seek legal advice - they should be signposted to specialist lawyers identified by the Ministry of Justice. 2. They are entitled to assistance completing any application to the CICA, should they require it. Such assistance should be provided by independent sexual violence advisers or other suitably qualified and trained persons. 3. At the conclusion of any criminal proceedings, the court may make orders for the payment of criminal compensation by convicted offenders to their victims. 4. They are entitled to be referred to organisations supporting victims of sexual abuse. They should be signposted to the support services available in their local area. The College of Policing should make changes to its guidance (currently Authorised Professional Practice) to require police officers to provide oral and written information on each of these matters. The Ministry of Justice should also provide further information on how the new compliance framework, and any other developments, will improve compliance with the Code for victims and survivors of child sexual abuse.

In April 2020, HM Government reported that proposed revisions to the Victims' Code were undergoing public consultation, and that the College of Policing would review guidance for officers once the updated code was introduced (Ministry of Justice response, Apr 2020; Ministry of Justice, Apr 2020). It stated in April 2020 that while victims should be advised regarding civil claims, the Law Society was best placed to help them instruct a solicitor rather than the department accrediting lawyers (Ministry of Justice response, Apr 2020). The record holds no update since the Ministry of Justice's response of April 2020 (Ministry of Justice response, Apr 2020).

The Local Government Association and the Association of British Insurers should each produce codes of practice for responding to civil claims of child sexual abuse. The codes should include recognition of the long-term emotional and psychiatric or psychological effects of child sexual abuse on victims and survivors, and acknowledgement that these effects may make it difficult for victims and survivors to disclose that they have been sexually abused and to initiate civil claims for that abuse. The codes should also include guidance that: 1. claimants should be treated sensitively throughout the litigation process; 2. the defence of limitation should only be used in exceptional circumstances; 3. single experts jointly instructed by both parties should be considered for the assessment of the claimants' psychiatric, psychological or physical injuries; and 4. wherever possible, claimants should be offered apologies, acknowledgement, redress and support.

In August 2021, the Association of British Insurers published a code of practice for responding to civil claims of child sexual abuse, stating that the guidance was produced to improve aspects of the civil claims process within insurers' control, including approaches to limitation, apologies, and the use of confidentiality agreements (Association of British Insurers response, Aug 2021). The record holds no update since the Association of British Insurers' response of August 2021 (Association of British Insurers response, Aug 2021).

The Department for Work and Pensions should work with the Association of British Insurers to introduce a national register of public liability insurance policies. The register should provide details of the relevant organisation, the name of the insurer, all relevant contact details, the period of cover, and the insurance limit. These requirements should apply to policies issued and renewed after the commencement of the register, and those against which a claim has already been made. The Financial Conduct Authority should make the necessary regulatory changes to compel insurers that provide public liability insurance to retain and publish details of all current policies.

In April 2020, HM Government reported that it had begun and would continue discussions with the Association of British Insurers on the feasibility of establishing a public liability register (Ministry of Justice response, Apr 2020; Ministry of Justice, Apr 2020). It stated that this work needed to be co-ordinated with other reform proposals to take a holistic approach to achieving justice for victims of child sexual abuse (Ministry of Justice response, Apr 2020). The record holds no update since the government's response of April 2020 (Ministry of Justice response, Apr 2020; Ministry of Justice, Apr 2020).

The Judicial College should revise its Guidelines for the Assessment of General Damages in Personal Injury Cases to include a freestanding section on the damages that may be appropriate in cases of child sexual abuse. This new section of the guidelines should advise the court to take into account the nature and severity of the abuse itself, any short-term and long-term physical, emotional and psychiatric or psychological injuries, and the general effect of the abuse on the claimant's capacity to function throughout their life. The latter may include the ability to sustain personal and sexual relationships, to benefit from education and to undertake paid employment.

The Independent Inquiry into Child Sexual Abuse reported in October 2022 that the Judicial College informed it that a revised edition of its Guidelines for the Assessment of General Damages in Personal Injury Cases was published on 11 April 2022 (The Independent Inquiry into Child Sexual Abuse, Oct 2022). The Inquiry noted in October 2022 that, according to the college, the new edition includes a section on sexual abuse incorporating factors such as the nature and duration of the abuse, physical and psychological effects, and the effect on personal and sexual relationships (The Independent Inquiry into Child Sexual Abuse, Oct 2022).

The Metropolitan Police Service should consider whether there are grounds for a criminal investigation into Lambeth Council's actions when providing information to the coroner about the circumstances surrounding LA-A2's death.

The Independent Inquiry into Child Sexual Abuse reported in December 2023 that the Metropolitan Police Service announced in July 2021 that it would assess whether there were grounds for a criminal investigation into Lambeth Council's actions (The Independent Inquiry into Child Sexual Abuse, Dec 2023). It noted in December 2023 that the force had received the recommendation and would examine the information provided to the coroner regarding the circumstances surrounding LA-A2's death (The Independent Inquiry into Child Sexual Abuse, Dec 2023).

We therefore recommend that that all institutions which sent children abroad as part of the child migration programmes should ensure that they have robust systems in place for retaining and preserving any remaining records that may contain information about individual child migrants, and should provide easy access to them.

The Inquiry asked child migration institutions to preserve records and provide easy access. The Independent Inquiry into Child Sexual Abuse, summarising responses of January 2020 on a webpage archived in June 2022, reported that Barnardos maintains a records service and had begun processing archive boxes to improve cataloguing and storage (The Independent Inquiry into Child Sexual Abuse, Jun 2022). It also reported that organisations including Action for Children and the Prince’s Trust provide former child migrants with access to their records free of charge (The Independent Inquiry into Child Sexual Abuse, Jun 2022).

The Chair and Panel recommend that the Department of Health and Social Care, the Department for Education, the Ministry of Justice and the Home Office work together to establish current levels of public expenditure, and the effectiveness of that expenditure on services for child victims and adult survivors of child sexual abuse in England.

In February 2020, HM Government reported that the Department of Health and Social Care, the Ministry of Justice, the Department for Education and the Home Office had reviewed public expenditure on services supporting victims and survivors of abuse, covering 2018/19 spending alongside ongoing and future commitments (Ministry of Justice, Feb 2020). The Independent Inquiry into Child Sexual Abuse noted in October 2022 that the departments had carried out this review, adding that the government's forthcoming strategy on child sexual abuse would seek to take a whole-system approach to providing support services (The Independent Inquiry into Child Sexual Abuse, Oct 2022).

The Chair and Panel recommend that the Welsh Government and the relevant UK government departments work together to establish current levels of public expenditure, and the effectiveness of that expenditure on services for child victims and adult survivors of child sexual abuse in Wales.

The Independent Inquiry into Child Sexual Abuse reported in October 2022 that the Welsh Government stated in February 2022 that it had obtained public expenditure for support services to victims and survivors of child sexual abuse in Wales, and had asked the National Independent Safeguarding Board for Wales to verify the sums and effectiveness of spend (The Independent Inquiry into Child Sexual Abuse, Oct 2022). The inquiry also recorded in October 2022 that the government had fully accepted the recommendation in December 2018 (The Independent Inquiry into Child Sexual Abuse, Oct 2022).

The International Underwriting Association of London should take the lead in the production of a code for the benefit of claimants who are bringing civil claims for child sexual abuse. The aim should be to produce a code, comparable to the Rehabilitation Code or for inclusion in that code, with the objective of ensuring that victims and survivors of child sexual abuse are able to access the therapy and support they need as soon as possible.

The Independent Inquiry into Child Sexual Abuse reported in October 2022 that the International Underwriting Association of London stated in April 2022 that work to source engaged survivors had resulted in challenges affecting the progression of the project (The Independent Inquiry into Child Sexual Abuse, Oct 2022). The association had previously stated in December 2021 that it agreed to fund survivor engagement through The Survivors Trust and hoped to finalise a draft rehabilitation code following those meetings, after establishing a working party in December 2020 to develop the code (The Independent Inquiry into Child Sexual Abuse, Oct 2022).

The Church of England and the Church in Wales should each introduce a Church-wide policy on the funding and provision of support to victims and survivors of child sexual abuse concerning clergy, Church officers or those with some connection to the Church. The policy should clearly set out the circumstances in which different types of support, including counselling, should be offered. It should make clear that support should always be offered as quickly as possible, taking into account the needs of the victim over time. The policy should take account of the views of victims and survivors. It should be mandatory for the policy to be implemented across all dioceses.

The Independent Inquiry into Child Sexual Abuse reported in October 2022 that the Archbishops' Council of the Church of England provided an update in February 2022 regarding its Interim Support Scheme for immediate help to victims and survivors, alongside plans for a national redress scheme (The Independent Inquiry into Child Sexual Abuse, Oct 2022). It also recorded that the Church had stated in March 2021 that its victim support policy was being revised to establish minimum levels of therapeutic support across church bodies, with implementation effective in January 2022 (The Independent Inquiry into Child Sexual Abuse, Oct 2022).

As we have set out in the institution-specific sections of the report, some institutions have still not apologised for their role in the child migration programmes. We recommend that they do so, as soon as possible. We recommend that they make such apologies not only through public statements but specifically to those child migrants for whose migration they were responsible.

In June 2022, the Independent Inquiry into Child Sexual Abuse recorded that multiple child migration institutions, including Barnardo's, Action for Children, the Church of England, and the Catholic Church in England and Wales, had published apologies for their roles in child migration (The Independent Inquiry into Child Sexual Abuse, Jun 2022). The Inquiry noted that while several organisations provided personal apologies, Father Hudson’s Care had not reached as many former migrants as it wished due to outdated contact details (The Independent Inquiry into Child Sexual Abuse, Jun 2022). The Inquiry further recorded that the Children’s Society decided against proactively tracing individuals to issue apologies, choosing instead to respond to people who make direct contact (The Independent Inquiry into Child Sexual Abuse, Jun 2022).

As a result, the Panel recommends that HMG establishes a Redress Scheme for surviving former child migrants, providing for an equal award to every applicant. This is on the basis that they were all were exposed to the risk of sexual abuse. Given the age of the surviving former child migrants, the Panel urges HMG to establish the Scheme without delay and expects that payments should start being made within 12 months. We also propose that no regard be had to any other payments of compensation that have been made in particular cases.

The Inquiry recommended creating an equal redress scheme for surviving former child migrants. In May 2023, HM Government reported that the Department for Health and Social Care (DHSC) had established an ex-gratia payment scheme offering an equal award to every applicant, with over 1,700 payments made since applications opened in March 2019 (Home Office response, May 2023). It had previously stated in July 2019 that eligible former child migrants receive £20,000 regardless of individual circumstances or other compensation, covering those alive on 1 March 2018 or their beneficiaries (HM Government response, Jul 2019). The record holds nothing dated later than the response of May 2023 (Home Office response, May 2023).

The Chair and Panel recommend that the Ministry of Justice revises Criminal Injuries Compensation Authority rules, so that awards are not automatically rejected in circumstances where an applicant's criminal convictions are likely to be linked to their child sexual abuse. Each case should be considered on its merits.

In April 2025, Parliamentary Under Secretary of State for Victims and Violence against Women and Girls Alex Davies-Jones stated that the Ministry of Justice decided to "make no change to it at this time" regarding the unspent convictions rule, concluding that altering the rule would breach the scheme's universality principle (Alex Davies-Jones MP, Apr 2025). HM Government had stated in May 2023 that it accepted the need to consider changes to the scheme and would consult on amending its scope and time limits (Home Office response, May 2023). The government had earlier reported in July 2019 that an ongoing review was examining eligibility rules, including concerns regarding unspent convictions (HM Government response, Jul 2019).

The Chair and Panel recommend that CICA ensures that claims relating to child sexual abuse are only considered by caseworkers who have specific and detailed training in the nature and impact of child sexual abuse.

HM Government stated in July 2019 that the Criminal Injuries Compensation Authority had adapted operational practices to better suit victims' needs and was providing specialist application support and named caseworkers for applicants affected by the pre-1979 same roof rule (HM Government, Jul 2019). The Independent Inquiry into Child Sexual Abuse, in a summary archived in October 2022, recorded that the government reported all operational staff receive training on child sexual abuse cases, and that the authority was considering options to extend dedicated caseworkers beyond complex and difficult cases (The Independent Inquiry into Child Sexual Abuse, Oct 2022).

The Chair and Panel recommend that the Ministry of Justice revises CICA rules so that all applicants who previously applied for compensation in relation to child sexual abuse - but were refused solely due to the 'same-roof' rule - should be entitled to reapply for compensation and have their claim approved by CICA.

The Ministry of Justice has provided no response to this recommendation on the record (The Independent Inquiry into Child Sexual Abuse, Oct 2022). In an update on its recommendations web page archived in October 2022, the Independent Inquiry into Child Sexual Abuse reported that the UK Government abolished the pre-1979 same-roof rule within the Criminal Injuries Compensation Scheme 2012 on 13 June 2019 (The Independent Inquiry into Child Sexual Abuse, Oct 2022).

The government should introduce legislation revising the Compensation Act 2006 to clarify that section 2 facilitates apologies or offers of treatment or other redress to victims and survivors of child sexual abuse by institutions that may be vicariously liable for the actions or omissions of other persons, including the perpetrators.

In April 2020, HM Government stated that the Ministry of Justice would explore amending the Compensation Act 2006 or taking alternative action to clarify that its provisions facilitate apologies in vicarious liability cases (Ministry of Justice response, Apr 2020; Ministry of Justice, Apr 2020). It noted that the statute was not intended to apply solely to claims in negligence and breach of statutory duty, and promised to provide an update in due course (Ministry of Justice response, Apr 2020; Ministry of Justice, Apr 2020). The record holds no update since the government's response of April 2020 (Ministry of Justice response, Apr 2020; Ministry of Justice, Apr 2020).

The Ministry of Justice should consult with the Sentencing Council, the Judicial College, the Crown Prosecution Service and other relevant bodies, in order to increase the use of CCOs, where appropriate, in cases involving child sexual abuse by, among other things, implementing guidance for the judiciary and prosecutors in the Crown Courts and Magistrates' Courts.

In April 2020, HM Government stated that consultations with the Judicial College, the Sentencing Council, and the Crown Prosecution Service concluded that existing guidance was sufficient, noting that prosecutors are reminded in legal guidance of their role in applying for compensation orders (Ministry of Justice response, Apr 2020; Ministry of Justice, Apr 2020). It also stated in April 2020 that it proposed to explore why courts make low numbers of compensation orders in child sexual abuse cases before deciding whether further steps or guidance would assist (Ministry of Justice response, Apr 2020). The record holds no update since the Ministry of Justice's response of April 2020 (Ministry of Justice response, Apr 2020; Ministry of Justice, Apr 2020).

The criteria for forfeiture of all honours must be formally extended to include convictions, cautions and cases decided by trial of the facts involving offences of child sexual abuse. This must be set out in a published policy and procedure, which must include a clear policy on how forfeiture decisions are made public. The Inquiry expects the Forfeiture Committee to take a lead on this matter.

The Inquiry asked the Cabinet Office to extend honours forfeiture criteria to child sexual abuse offences. In guidance updated in December 2025, the department specified forfeiture criteria covering sexual offences convictions and determinations following a trial of the facts, though cautions were not mentioned (Cabinet Office, Dec 2025). Previously, in September 2020, HM Government stated that the Committee on the Grant of Honours, Decorations and Medals was conducting an in-depth review of forfeiture policy (Cabinet Office response, Sep 2020; Cabinet Office, Sep 2020).

The Cabinet Office should re-examine the policy on posthumous forfeiture, in order to consider the perspectives of victims and survivors of child sexual abuse.

The Inquiry asked the Cabinet Office to re-examine posthumous honours forfeiture policy. In September 2020, HM Government stated in a response published by the department that the Committee on the Grant of Honours, Decorations and Medals was taking forward an "in-depth review of forfeiture policy in this area" (Cabinet Office response, Sep 2020; Cabinet Office, Sep 2020). It explained that policy changes are made on advice from the committee and stated that it would keep the Inquiry informed of progress (Cabinet Office response, Sep 2020). The response described a review of forfeiture policy, while posthumous forfeiture and the perspectives of victims and survivors were not mentioned in the sources (Cabinet Office response, Sep 2020). The record holds nothing dated later than the response of September 2020 (Cabinet Office response, Sep 2020).

The Chair and Panel recommend that the UK government ratifies the Council of Europe Convention on the Protection of Children against Sexual Exploitation and Sexual Abuse (the 'Lanzarote Convention') without further delay. They also recommend that ratification is followed, again without further delay, by action to implement the Lanzarote Convention. The Chair and Panel recommend that the Home Office, as the lead UK government department, publishes the timetable for ratifying the Lanzarote Convention and taking any additional steps required to make the UK fully compliant by June 2018.

The Independent Inquiry into Child Sexual Abuse, summarising the response of the UK Government of 20 June 2018 on its recommendations page for the interim report as archived in October 2022, recorded that the government ratified the Lanzarote Convention on that date (The Independent Inquiry into Child Sexual Abuse, Oct 2022). The record holds no update since the Inquiry's summary of October 2022 (The Independent Inquiry into Child Sexual Abuse, Oct 2022).

The Home Office should bring forward legislation providing for the establishment and maintenance by the National Crime Agency of a list of countries where children are considered to be at high risk of sexual abuse and exploitation from overseas offenders. This list should be kept under regular review. The list of countries should be made available to the police, and used routinely to help identify whether a person who has been charged with sexual offences against a child poses a risk to children overseas based on their travel history and/or plans. If the person is considered to pose a risk of sexual harm to children overseas, the police should submit an application for a foreign travel restriction order under the Sexual Offences Act 2003. The list of countries should be admissible in court and used when considering whether a foreign travel restriction order should be made under the Sexual Offences Act 2003 and if so, to which countries it should apply.

The Inquiry asked the Home Office to legislate for a high-risk countries list. The Police, Crime, Sentencing and Courts Act 2022, enacted in April 2022, provides that the Secretary of State may prepare, or direct a relevant person to prepare, a list of countries and territories outside the United Kingdom where children are at high risk of sexual abuse or exploitation (Police, Crime, Sentencing and Courts Act 2022, section 172: List of countries, Apr 2022). Earlier, in January 2021, HM Government stated in a response published by the department that it accepted the recommendation, had commissioned the National Crime Agency (NCA) to compile the list, and would bring forward legislation when parliamentary time allowed to assist police and courts with foreign travel prohibitions (Home Office response, Jan 2021; Home Office, Jan 2021).

The government should press the WeProtect Global Alliance to take more action internationally to ensure that those countries hosting indecent images of children implement legislation and procedures to prevent access to such imagery.

The Inquiry recommended pressing the WeProtect Global Alliance to curb child abuse material overseas. HM Government stated in November 2020 that, as a permanent member of the alliance's management board, it provides strategic leadership to direct prioritisation and engagement with partner countries and technology companies (Home Office response, Nov 2020; Home Office, Nov 2020). It explained that the alliance was preparing for a 2021 summit in Brazil and working with regional bodies and individual countries to develop effective legislation (Home Office response, Nov 2020). While the response detailed legislative guidance and international engagement, procedures to prevent access to hosted imagery were not mentioned (Home Office response, Nov 2020). The record holds nothing dated later than the response of November 2020 (Home Office response, Nov 2020).

The government should introduce legislation requiring providers of online services and social media platforms to implement more stringent age verification techniques on all relevant devices.

The Inquiry recommended that the government legislate for stricter online age verification across platforms and devices. In November 2020, HM Government stated that age assurance and age verification would play a key role in its upcoming regulatory framework for online services, though it did not mention devices (Home Office response, Nov 2020; Home Office, Nov 2020). It noted in November 2020 that platforms were expected to adopt proportionate tools to protect children and highlighted research it supported into the feasibility of identifying child users online (Home Office response, Nov 2020). It added in November 2020 that, ahead of legislation, it would publish guidance on embedding safety by design principles and develop practical advice for online companies (Home Office response, Nov 2020). The record holds nothing dated later than the response of November 2020 (Home Office response, Nov 2020).

The Inquiry recommends that the UK government and the Welsh Government improve data collected by children's social care and criminal justice agencies concerning child sexual abuse and child sexual exploitation by the introduction of one single core data set covering both England and Wales. In order to facilitate this, these agencies should produce consistent and compatible data about child sexual abuse and child sexual exploitation which includes: the characteristics of victims and alleged perpetrators of child sexual abuse, including age, sex and ethnicity; factors that make victims more vulnerable to child sexual abuse or exploitation; and the settings and contexts in which child sexual abuse and child sexual exploitation occur. Data concerning child sexual abuse and child sexual exploitation should be compiled and published on a regular basis. This should be capable of being collated nationally as well as at regional or local levels.

In January 2026, Jess Phillips, Minister, answering for the Home Office, stated that work remained in progress, reporting that the Children's Wellbeing and Schools Bill was passing through Parliament to introduce a new information sharing duty and consistent child identifier (Jess Phillips, Jan 2026). Previously, HM Government announced in April 2025 that updated survey data on adult experiences of child sexual abuse would be published by December 2025 (Home Office, Apr 2025). In its May 2023 response, it had accepted the recommendation in principle and pledged further improvements to police performance data (Home Office response, May 2023).

The Inquiry recommends that the UK government establishes a Child Protection Authority for England and the Welsh Government establishes a Child Protection Authority for Wales. Each Authority's purpose should be to: improve practice in child protection; provide advice and make recommendations to government in relation to child protection policy and reform to improve child protection; and inspect institutions and settings as it considers necessary and proportionate. The Child Protection Authorities in England and in Wales should also monitor the implementation of the Inquiry's recommendations.

In July 2026, HM Government (Department for Education) confirmed in a consultation response that it is committed to establishing a Child Protection Authority in England (Department for Education, Jul 2026). It had previously stated in an April 2025 progress update that it would create the authority using the Child Safeguarding Practice Review Panel as a foundation (Home Office, Apr 2025). Earlier, in May 2024, the Thirlwall Inquiry legal team found that the government had planned to achieve the recommendation's aims through existing mechanisms rather than creating a new body (The Thirlwall Inquiry legal team, May 2024).

The Inquiry recommends that the UK government creates a cabinet-level ministerial position for children. The Inquiry recommends that the Welsh Government ensures that there is cabinet-level ministerial responsibility for children.

In January 2026, Josh MacAlister, a Minister answering for the Department for Education, stated that the Secretary of State for Education is the Cabinet minister for children and that a Keeping Children Safe ministerial board has been established to drive cross-government focus on children's wellbeing, safety and opportunity (Josh MacAlister, Jan 2026). Earlier, in May 2024, the Thirlwall Inquiry legal team found that a Child Protection Ministerial Group had been established previously and that the work might come under that body (The Thirlwall Inquiry legal team, May 2024).

The Inquiry recommends that the UK government and the Welsh Government commission regular programmes of activity to increase public awareness about child sexual abuse and the action to take if child sexual abuse is happening or suspected in England and in Wales. The programmes should: challenge myths and stereotypes about child sexual abuse; make maximum use of different approaches including, but not limited to, public information campaigns, the use of positive role models and creative media, such as television drama; and be supported by continuous evaluation to measure their impact.

Home Office Minister Jess Phillips stated in a January 2026 written answer that targeted programmes were being supported to raise public awareness, including the #LookCloser, Stop It Now!, and ENOUGH campaigns (Jess Phillips, Jan 2026). HM Government had previously reported in an April 2025 progress update that work was in progress to step up national communications activity (Home Office, Apr 2025). In May 2023, it had accepted the recommendation in principle, noting that it would continue exploring effective ways to raise awareness (Home Office response, May 2023).

The Inquiry recommends (as originally stated in its Sexual Abuse of Children in Custodial Institutions: 2009-2017 Investigation Report, dated February 2019) that the UK government prohibits the use of any technique that deliberately induces pain (previously referred to by the Inquiry as 'pain compliance techniques') by withdrawing all policy permitting its use in custodial institutions in which children are detained, and setting out that this practice is prohibited by way of regulation.

In a January 2026 parliamentary answer, Jake Richards, Minister, answering for the Ministry of Justice, confirmed that the government rejected the recommendation and "will not be introducing legislation", stating that staff must be able to use these techniques as a last resort in emergencies to protect children and staff (Jake Richards, Jan 2026). HM Government had earlier reported in an April 2025 progress update that it would work with the Youth Custody Service on staff training and maintain oversight through an Independent Restraint Review Panel (Home Office, Apr 2025). It had first stated in May 2023 that custodial staff must be trained in safe pain-inducing techniques to prevent children from self-harming or causing physical harm to others (Home Office response, May 2023).

The Inquiry recommends that the UK government amends the Children Act 1989 so that, in any case where a court is satisfied that there is reasonable cause to believe that a child who is in the care of a local authority is experiencing or is at risk of experiencing significant harm, on an application by or for that child, the court may: prohibit a local authority from taking any act (or proposed act) which it otherwise would be entitled to take in exercising its parental responsibility for the child; or give directions for the purpose of determining a specific question which has arisen, or which may arise, in connection with any aspect of the local authority's exercise of parental responsibility for a child.

In January 2026, Josh MacAlister, Minister answering for the Department for Education, stated that the department will publish new national standards and statutory guidance for advocacy for children and young people, following a December 2025 consultation on establishing a Child Protection Authority (Josh MacAlister, Jan 2026). HM Government previously reported in April 2025 that introducing these advocacy standards and revised guidance would not require an amendment to the Children Act 1989 (Home Office, Apr 2025). In May 2023, it had accepted the recommendation in principle, stating that it would address the issues through reforms in its Stable Homes, Built on Love strategy (Home Office response, May 2023).

The Inquiry recommends (as originally stated in its Interim Report, dated April 2018) that the UK government introduces arrangements for the registration of staff working in care roles in children's homes, including secure children's homes. Registration should be with an independent body charged with setting and maintaining standards of training, conduct and continuing professional development, and with the power to enforce these through fitness to practise procedures.

In April 2025, HM Government stated that it would improve qualifications, standards, and training while continuing work to "determine whether registration of care staff is the right approach", noting that a registration regime would not succeed without these foundations (Home Office, Apr 2025). In May 2023, it had accepted that registration of staff working in care roles in children's homes was essential and stated that it was looking at how best to implement this (Home Office response, May 2023).

The Inquiry recommends (as originally stated in its Sexual Abuse of Children in Custodial Institutions: 2009-2017 Investigation Report, dated February 2019) that the UK government introduces arrangements for the professional registration of staff in roles responsible for the care of children in young offender institutions and secure training centres.

In January 2026, Jake Richards, Minister answering for the Ministry of Justice, stated that a planned decision on a youth custody registration framework had been deferred to allow a wider safeguarding review panel to report, with an official response to this recommendation now expected in autumn 2026 (Jake Richards, Jan 2026). HM Government had previously committed in April 2025 to assess framework options and announce a decision by March 2026, having accepted the recommendation in principle in May 2023 (Home Office response, May 2023; Home Office, Apr 2025).

The Inquiry recommends that the UK government enables any person engaging an individual to work or volunteer with children on a frequent basis to check whether or not they have been barred by the Disclosure and Barring Service from working with children. These arrangements should also apply where the role is undertaken on a supervised basis.

In May 2026, the Home Office and Ministry of Justice reported that the Crime and Policing Act 2026 removes the supervision exemption in the definition of regulated activity, enabling organisations to check whether individuals working or volunteering frequently with children on a supervised basis are on the barred list (Home Office and Ministry of Justice, May 2026). Earlier, in May 2024, the Thirlwall Inquiry legal team found that the government had accepted the recommendation subject to further assessment of feasibility and impact (The Thirlwall Inquiry legal team, May 2024).

The Inquiry recommends that the UK government takes steps to improve compliance by regulated activity providers with their statutory duty to refer concerns about the suitability of individuals to work with children to the Disclosure and Barring Service, including: all relevant regulators and inspectorates include compliance with the statutory duty to refer to the Disclosure and Barring Service in their assessment of safeguarding procedures during inspections; the National Police Chiefs' Council works with relevant regulators and inspectorates to ensure that there are clear arrangements in place to refer breaches of the duty to refer to the police for criminal investigation; and an information-sharing protocol is put in place between the Disclosure and Barring Service and relevant regulators and inspectorates.

In January 2026, Home Office Minister Jess Phillips stated that the government and the Disclosure and Barring Service were conducting an ongoing programme of work to improve compliance with the duty to refer, delivering workshops to more than 12,000 safeguarding staff and increasing referrals by over 50 percent regionally (Jess Phillips, Jan 2026). Previously, in May 2024, the Thirlwall Inquiry legal team examined the measure and recorded the government's acceptance without assessing it as fully implemented (The Thirlwall Inquiry legal team, May 2024).

The Inquiry recommends (as originally stated in its Children Outside the United Kingdom Phase 2 Investigation Report, dated January 2020) that the UK government introduces legislation permitting the Disclosure and Barring Service to provide enhanced certificates with barred list checks to citizens and residents of England and Wales applying for: work or volunteering with UK-based organisations, where the recruitment decision is taken outside the UK; or work or volunteering with organisations based outside the UK, in each case where the work or volunteering would be a regulated activity if in England and Wales.

In January 2026, Home Office minister Jess Phillips reported that legislation brought into force in December 2025 enabled ACRO Criminal Records Office to include an individual's barred list status on its International Child Protection Certificate for people seeking to work with children overseas (Jess Phillips, Jan 2026). HM Government had previously stated in April 2025 that it would enable those making decisions overseas to access Disclosure and Barring Service barred list data by 2026 (Home Office, Apr 2025). In May 2023, it accepted the recommendation in principle, committing to consider strengthening the disclosure regime in light of the Bailey Review (Home Office response, May 2023).

The Inquiry recommends that the UK government makes it mandatory for all regulated providers of search services and user-to-user services to pre-screen for known child sexual abuse material.

In January 2026, Kanishka Narayan, Minister for the Department for Science, Innovation and Technology, stated that under the Online Safety Act, Ofcom has powers to require regulated services to use accredited technology to detect and remove child sexual abuse content (Kanishka Narayan, Jan 2026). The Minister explained that Ofcom will be able to issue notices once minimum standards and an accreditation scheme are in place, with advice on minimum standards due to be published to the Secretary of State by April 2026 (Kanishka Narayan, Jan 2026). HM Government had previously stated in April 2025 that it was assessing whether additional measures, including pre-screening or device-level interventions, were needed for private channels (Home Office, Apr 2025).

The Inquiry recommends that the UK government and Welsh Government introduce legislation which places certain individuals - 'mandated reporters' - under a statutory duty to report child sexual abuse where they: receive a disclosure of child sexual abuse from a child or perpetrator; or witness a child being sexually abused; or observe recognised indicators of child sexual abuse. The following persons should be designated 'mandated reporters': any person working in regulated activity in relation to children (under the Safeguarding and Vulnerable Groups Act 2006, as amended); any person working in a position of trust (as defined by the Sexual Offences Act 2003, as amended); and police officers. For the purposes of mandatory reporting, 'child sexual abuse' should be interpreted as any act that would be an offence under the Sexual Offences Act 2003 where the alleged victim is a child under the age of 18. Where the child is aged between 13 and under 16 years old, a report need not be made where the mandated reporter reasonably believes that: the relationship between the parties is consensual and not intimidatory, exploitative or coercive; and the child has not been harmed and is not at risk of being harmed; and there is no material difference in capacity or maturity between the parties engaged in the sexual activity concerned, and there is a difference in age of no more than three years. These exceptions should not, however, apply where the alleged perpetrator is in a position of trust within the meaning of the 2003 Act. Where the child is under the age of 13, a report must always be made. Reports should be made to either local authority children's social care or the police as soon as is practicable. It should be a criminal offence for mandated reporters to fail to report child sexual abuse where they: are in receipt of a disclosure of child sexual abuse from a child or perpetrator; or witness a child being sexually abused.

In May 2026, the Home Office and Ministry of Justice reported that the Crime and Policing Act 2026 established a legal requirement for anyone in regulated activity relating to children in England to report child sexual abuse to the police or local authority, though guidance and work with regulators remain outstanding ahead of implementation (Home Office and Ministry of Justice, May 2026). HM Government had stated in May 2023 that it accepted the need for mandatory reporting in principle and agreed to implement a regime following a public consultation (Home Office response, May 2023).

The Inquiry recommends (as originally stated in its Interim Report, dated April 2018) that the UK government commissions a joint inspection of compliance with the Victims' Code in relation to victims and survivors of child sexual abuse, to be undertaken by His Majesty's Inspectorate of Constabulary and Fire & Rescue Services, His Majesty's Crown Prosecution Service Inspectorate and His Majesty's Inspectorate of Probation.

In January 2026, Ministry of Justice Minister Alex Davies-Jones stated that the government accepted the recommendation and the Criminal Justice Joint Inspectorates have confirmed the joint inspection of Victims' Code compliance will take place in 2026-27 (Alex Davies-Jones, Jan 2026). HM Government had previously reported in April 2025 that it asked the inspectorates to prioritise an inspection into the experiences of child sexual abuse victims in their business plan (Home Office, Apr 2025).

The Inquiry recommends that the UK government makes the necessary changes to legislation in order to ensure: the removal of the three-year limitation period for personal injury claims brought by victims and survivors of child sexual abuse in respect of their abuse; and the express protection of the right to a fair trial, with the burden falling on defendants to show that a fair trial is not possible. These provisions should apply whether or not the current three-year period has already started to run or has expired, except where claims have been: dismissed by a court; or settled by agreement. They should, however, only apply to claims brought by victims and survivors, not claims brought on behalf of victims and survivors' estates.

In May 2026, the Home Office and Ministry of Justice stated that provisions in the Crime and Policing Act 2026 will abolish time limits for victims bringing child sexual abuse claims regarding their own abuse, while placing the onus on defendants to show that a fair trial is not possible (Home Office and Ministry of Justice, May 2026). HM Government had committed in April 2025 to remove the three-year limitation period and reverse the burden of proof, having earlier stated in May 2023 that it would consult on options to reform limitation law (Home Office response, May 2023; Home Office, Apr 2025).

The Inquiry recommends that the UK government and the Welsh Government introduce a national guarantee that child victims of sexual abuse will be offered specialist and accredited therapeutic support. There should be sufficient supply of these services so that children in all parts of England and Wales can access support in a timely way. These services should be fully funded. Responsibility for commissioning these services should be given to local authorities. There must be no eligibility criteria for children to access these specialist therapeutic services other than having been a victim of child sexual abuse.

In January 2026, Dr Zubir Ahmed, answering for the Department of Health and Social Care, stated that up to £50 million is being invested to roll out the Child House model across all National Health Service regions in England, following an announcement by Wes Streeting in December 2025 (Wes Streeting, Dec 2025; Dr Zubir Ahmed, Jan 2026). HM Government had stated in April 2025 that it was developing proposals to improve therapeutic support across the health, social care, and justice sectors following the Spending Review (Home Office, Apr 2025). In May 2023, it had accepted the recommendation in principle and pledged to consult on possible systemic changes to therapeutic provision (Home Office response, May 2023).

The Inquiry recommends that the UK government directs the Information Commissioner's Office to introduce a code of practice on retention of and access to records known to relate to child sexual abuse. The retention period for records known to relate to allegations or cases of child sexual abuse should be 75 years with appropriate review periods. The code should set out that institutions should have: retention policies that reflect the importance of such records to victims and survivors, and that they may take decades to seek to access such records; clear and accessible procedures for victims and survivors of child sexual abuse to access such records; policies, procedures and training for staff responding to requests to ensure that they recognise the long-term impact of child sexual abuse and engage with the applicant with empathy.

In June 2026, Minister Josh MacAlister, answering for the Department for Education, stated that the government will lay regulations instructing the Information Commissioner's Office to produce a code of practice on the retention of personal data relating to child sexual abuse, with the regulator then preparing the code following consultation with an expert panel (Josh MacAlister, Jun 2026). Home Office Minister Jess Phillips had previously stated in January 2026 that the government was preparing the regulations and intended to lay them "as soon as possible" (Jess Phillips, Jan 2026). HM Government reported in April 2025 that the code cannot mandate organisations to keep records for 75 years, but will provide best practice guidance (Home Office, Apr 2025).

The Inquiry recommends that the UK government changes the Criminal Injuries Compensation Scheme to: include other forms of child sexual abuse, including online-facilitated sexual abuse; amend the rule on unspent convictions so that applicants with unspent convictions are not automatically excluded where offences are likely to be linked to the circumstances of their sexual abuse as a child; and increase the time limit for child sexual abuse applications so that applicants have seven years to apply from (a) the date the offence was reported to the police or (b) the age of 18, where the offence was reported whilst the victim was a child. In either circumstance, the claims officer's discretion to extend the time limit remains.

In April 2025, Parliamentary Under Secretary of State Alex Davies-Jones MP stated that she had "decided not to take forward the recommendations of the Inquiry on the Scheme", noting that changes restricted to child sexual abuse could undermine the universal system and disadvantage other victims (Alex Davies-Jones MP, Apr 2025; Alex Davies-Jones MP, Apr 2025). HM Government similarly reported in April 2025 that the principle of compensating based on injuries sustained rather than crime type made the Inquiry's recommendations difficult to implement (Home Office, Apr 2025). It had previously stated in May 2023 that it accepted the need to consider changes in principle and planned to consult on scope and time limits (Home Office response, May 2023).

The Inquiry recommends that the UK government establishes a single redress scheme in England and Wales, taking into account devolved responsibilities. The detailed rules of, and funding for, this redress scheme should reflect the following core elements. Eligibility Victims and survivors of child sexual abuse and exploitation that occurred in England and in Wales should be eligible to apply. Applicants must have experienced child sexual abuse and exploitation where there is a clear connection to State or non-State institutions in England and Wales. The scheme should be open to any victim of child sexual abuse that took place prior to its establishment. The scheme should deduct any previous award from any payment under the scheme (or in the case of payments made by the Criminal Injuries Compensation Authority, it may order that they be repaid). Applicants who have previously brought civil claims which have been rejected by the court should be excluded from applying to the scheme, save where their cases have been rejected due to limitation. Redress provided The scheme should provide payments to eligible applicants through a two-tier system, based on a fixed flat-rate recognition payment, with the option to apply for a second-tier payment. Process The application process must be accessible and straightforward, and be sensitive to the needs and vulnerabilities of victims and survivors of child sexual abuse. The process should provide for streamlined checks and verification of applications, but not be adversarial. There should be special provisions to accelerate awards for older or terminally ill applicants. Duration The scheme should run for five years. Funding The scheme should be funded by central and local government, in accordance with devolved funding principles, with voluntary contributions sought from non-State institutions.

The Inquiry recommended establishing a single redress scheme in England and Wales. In January 2026, Alex Davies-Jones, Minister, answering for the Ministry of Justice, stated that HM Government is "not currently taking forward any further steps" on the proposed national financial redress scheme (Alex Davies-Jones, Jan 2026). It had explained in April 2025 that establishing the scheme's scope posed major challenges in the fiscal environment, prioritising investment in therapeutic support and care (Home Office, Apr 2025). In May 2023, it had accepted the need to introduce a redress scheme acknowledging institutional failures, planning engagement to determine the details (Home Office response, May 2023).

The Inquiry recommends (as originally stated in its The Internet Investigation Report, dated March 2020) that the UK government introduces legislation requiring providers of online services and social media platforms to implement more stringent age verification measures.

In January 2026, Kanishka Narayan, Minister answering for the Department for Science, Innovation and Technology, stated that the Online Safety Act "already meets the Inquiry’s recommendations on age-verification and online safety measures" by requiring regulated services to apply age assurance to protect children from harmful content (Kanishka Narayan, Jan 2026). HM Government previously reported in April 2025 that it had completed a feasibility study on testing age assurance tools and was monitoring whether further intervention was needed to enforce minimum age limits on social media (Home Office, Apr 2025).