Source · Prevention of Future Deaths

Matilda Pomfret-Thomas

Ref: 2026-0025 Date: 15 Jan 2026 Coroner: Henry Charles Area: Hampshire, Portsmouth Southampton Responses identified: 4 / 3 View PDF

A lack of regulation, registration, and clear guidance for doulas creates confusion about their role, risks them working outside clinical boundaries, and poses challenges for midwives and patient care.

Date 15 Jan 2026
56-day deadline 12 Mar 2026 est.
Responses identified 4 of 3
Child Death (from 2015)

Coroner's concerns

AI summary
A lack of regulation, registration, and clear guidance for doulas creates confusion about their role, risks them working outside clinical boundaries, and poses challenges for midwives and patient care.
View full coroner's concerns
Doulas provide continuity of care and give emotional, informational and practical support throughout pregnancy, labour and after the birth of a baby: those words come from Doula UK’s website. Doula UK is the largest representative body for Doulas, but it is not a regulatory body, it does not represent all doulas, indeed many doulas are not members of Doula UK. Doula UK have put in place membership requirements, training offers and much guidance, but the role of a doula is clearly diffuse in practical terms and capable of multiple understandings not just by doulas but their clients and midwives. It appears that doulas have been increasingly used and increasingly offer services - as here
- on a paid basis. As MNSI (Maternity & Newborn Safety Investigations - formerly HSIB) put it in their report into this birth, “MNSI acknowledges that there is no regulation of doula care or any guidance on how the two services interact with each other. MNSI considers the dynamics of a situation, where a third party are involved can provide additional challenges for staff, such as making clinical recommendations against personal recommendations or views and providing usual care that could be viewed as interference rather than surveillance.” MNSI have identified 12 cases in which there was evidence that doulas worked outside of the defined boundaries of their role and in which the care or advice provided by the doula was considered to have potentially had an influence on the poor outcome for the family. There was evidence given at the inquest by experienced midwifery professionals highlighting that provision of guidance would be helpful for all involved with a birth at which a doula was present. The issues of doula registration, regulation and training are therefore points of concern I would commend for review.

Responses

4 respondents
National Institute for Health and Care Excellence Other
15 Jan 2026 PDF
Noted

NICE acknowledged the concerns but stated that the registration, regulation, and training of doulas are not their responsibility and are better addressed by other bodies such as the NMC, RCM, and RCOG. (AI summary)

View full response
Dear Mr Charles, Re: Regulation 28 Prevention of Future Deaths Report in respect of Matilda Pomfret- Thomas

I write in response to your regulation 28 report, dated 15 January 2026, regarding the very sad death of Matilda Pomfret-Thomas. I would like to express my sincere condolences to Matilda’s family.

We have reflected on the circumstances surrounding Matilda’s death and senior clinical advisers within our patient safety team have reviewed the concerns raised in your report, which we note has also been sent to the Nursing and Midwifery Council (NMC).

The registration, regulation and training of Doulas is not the responsibility of NICE and is better addressed by the Nursing and Midwifery Council (NMC), Royal College of Midwives (RCM) and the Royal College of Obstetricians and Gynaecologists (RCOG).

I hope that this clarification is helpful and I would like to reiterate my sincere condolences to Matilda’s family.
Developing Doulas
18 Feb 2026 PDF
Disputed

Developing Doulas submitted a voluntary response, disputing the perception that the doula's presence negatively impacted midwifery services. They argued that the doula acted within a non-clinical support role and that difficulties highlight the need for strengthening communication and collaborative working with non-clinical supporters. (AI summary)

View full response
Voluntary Submission in Response to Prevention of Future Deaths Report (Ref: 2026-
0025) Re: Matilda Pomfret-Thomas Dated 18 February 2026 To: HM Assistant Coroner Henry Charles Hampshire, Portsmouth and Southampton I write in a personal and professional capacity as a practising doula of fourteen years and as a Doula Training Course Facilitator and Co-Owner of Developing Doulas. I am not a statutory recipient of the Regulation 28 Report and therefore am not responding under Regulation 29 of the Coroners (Investigations) Regulations 2013. However, given that the report raises concerns regarding the role and presence of doulas, I consider it important, in the interests of balanced learning and prevention, to provide the following voluntary submission. This response addresses the Prevention of Future Deaths (PFDR) report specifically in relation to its references to the presence and role of a doula during this birth, and the suggestion that this presence “negatively impact[ed] upon the eƯective provision of midwifery services in terms of building a rapport conducive to eƯective advice and care being given.” The PFDR records that the doula did not actively discourage midwife access, that she was supporting the parents in accordance with the agreed birth plan, and that she was nonetheless perceived by members of the midwifery team as, “in eƯect, a buƯer.” It further suggests that this support was perceived as grounds for hope that a home birth remained possible. This description highlights the importance of clearly distinguishing between perception and responsibility. As described in the report, the doula’s actions were consistent with a non-clinical support role: supporting the parents’ stated wishes and birth plan, without restricting access, providing clinical advice, or exercising authority over decision-making. A perception of her presence as a “buƯer” reflects the experience of the clinical team, rather than evidence of obstruction or causal action on the part of the doula. Responsibility for building and maintaining a rapport that enables the delivery of eƯective clinical advice and care rests with the clinician who holds clinical responsibility. This responsibility is non-delegable and applies regardless of who else is present to support the family. Where clinical concern arises - particularly in the context of deteriorating fetal wellbeing - the duty to communicate risk clearly, to support informed decision-making, and to escalate care appropriately remains with the healthcare professionals involved.

The background of a previous traumatic birth is, I believe, highly relevant in understanding why this family elected for a home birth and chose to engage a doula. Many families who have experienced birth trauma seek additional non-clinical support in order to feel safer and more able to engage with care. The presence of such support should not impede eƯective communication of clinical concern or timely escalation. Support for a birth plan, or expressions of hope for a particular outcome, should not be understood as a barrier to clinical leadership or decision-making. If clinicians experience diƯiculty carrying out their role eƯectively when a doula is present, this points to a need for improved training, confidence, and support in working alongside non-clinical supporters, rather than indicating an inherent risk associated with the presence of a doula. It is also relevant to consider whether similar perceptions would arise if the supporter present were a partner, parent, sibling, or other family member - all of whom are commonly present at births and are not typically characterised as barriers to care. Doulas aƯiliated to Doula UK and other membership organisations operate within established professional guidelines and codes of conduct that emphasise clear boundaries, respect for clinical roles, and support for informed choice. The doula profession is unregulated not because of an absence of standards, but because it is a non- clinical support role. In this respect, it is comparable to other support professions such as counselling and advocacy, where practice is governed by professional ethics rather than statutory regulation. From a prevention perspective, learning would be better directed toward strengthening clinicians’ skills in trauma informed care, communication of risk, and the maintenance of clear clinical responsibility in complex and emotionally charged situations. Care should be taken to avoid attributing causal significance to non-clinical supporters in a way that risks obscuring professional responsibility or diverting attention from the systemic and professional learning that PFDRs are intended to promote. Furthermore, while the MNSI report referenced within the PFDR is relevant, it is important to distinguish the nature of the evidence it contains. The twelve references to doulas associated with poor outcomes reflect the perceptions and reporting of healthcare providers only. MNSI has confirmed that, in these cases, neither the families aƯected by the outcomes nor the doulas involved were invited to provide their perspectives. It is not appropriate to form conclusions or develop eƯective or strategic responses on the basis of evidence that is so heavily weighted toward a single source. While it is entirely possible that, in some cases, a doula may have made a mistake or influenced a decision, it

is not possible to establish this as fact where information has been collated solely from one professional perspective. The evidence supporting the benefits of doula care is well established, as is the importance of doulas remaining independent from the maternity system. In an underfunded, under resourced, and highly litigated system, this independence can sometimes give rise to resentment, misunderstanding, or projection. These systemic pressures do not negate the value of doula support, but they do highlight the need for improved shared understanding. The most constructive way forward, in my own well-researched opinion - is through better training for healthcare professionals to understand why families seek doula support, to feel confident and clear about their own roles and responsibilities, and to understand the role, boundaries, and purpose of the doula. This includes recognising where roles diƯer, where they intersect, and how they can collaborate eƯectively in the interests of safety and family centred care. The MNSI itself has acknowledged the importance of improved shared understanding between healthcare professionals and doulas. Meaningful prevention of future deaths depends on balanced learning, clear accountability, and a commitment to strengthening systems and relationships, rather than attributing undue causal weight to the presence of non-clinical support. I also wish to add this context from professional experience. I have worked as a doula for fourteen years, and the challenges highlighted in this report are, regrettably, not new. Over that time, I have witnessed many more examples of eƯective, collaborative working between doulas and healthcare professionals than instances of defensiveness or hostility within birthing environments. However, I have also experienced situations in which I have been wrongly accused of influencing decision-making or providing clinical advice, particularly where healthcare professionals have felt aƯronted or insuƯiciently confident to include a doula as part of the wider care team. There is currently a lack of clear processes for addressing such situations when they arise, within most local trusts, and as a result doulas are often left to live with misunderstanding and misrepresentation without recourse. These dynamics can have wider consequences. They can further harm what may already be a fragile relationship between a service user and the maternity system, and can contribute to a deepening loss of trust when families experience rejection of a doula they have chosen and employed to support them.

For reports intended to prevent future harm, it is essential that they accurately represent the underlying issues at play. Without doing so, there is a risk that learning is misdirected, and that opportunities to address the real systemic and relational challenges - rather than their symptoms - are missed. It is also important to acknowledge the context in which midwives practise. Midwives already carry a heavy burden of responsibility and the weight of potential legal recourse. Without appropriate understanding of the doula role, of independent advocacy, and of trauma aware responses to families who have chosen to employ a doula, it is understandable that some midwives may experience fear or anxiety about a doula’s presence. Women and birthing people/families arrive in maternity services as whole people, with complex histories, values, and lived experiences long before pregnancy and birth. The vast majority of doulas support informed decision making, which may include decisions to decline certain interventions. In most cases, a desire to decline intervention exists prior to the involvement of a doula, rather than being created by it. When families experience a lack of autonomy within maternity services, this is frequently described as infantilising and disempowering. Independent support is often sought precisely because families wish to engage more fully, not less, in decision making about their care. Understanding this motivation is essential if maternity services are to respond in ways that build trust, rather than deepen fear or division. In conclusion, meaningful prevention of future harm depends on accurate representation, shared understanding, and clarity of roles and responsibilities. Where diƯiculties arise in births involving doulas, learning should focus on strengthening trauma-informed communication, confidence in clinical leadership, and collaborative working with non- clinical supporters. Attributing disproportionate causal weight to the presence of a doula risks obscuring these core issues and diverting attention from the systemic improvements that are necessary to support safe, respectful, and truly family-centred maternity care. These themes are explored further in Michelle Quashie’s article Safety: Self-Determined and Human Rights Compliant in The Practising Midwife (available via All4Maternity), and in Milly Morris’s dissertation Doulas and Midwives: A Powerful Alliance, both of which oƯer valuable context for this discussion.
Department of Health and Social Care Central Government
4 Mar 2026 PDF
Noted

The Department of Health and Social Care acknowledged concerns about unregulated doulas, clarified their current status as non-regulated professionals, and outlined the roles of other bodies like the NMC and NICE. They stated that NHS England will not be producing guidance for midwives' interactions with doulas. (AI summary)

View full response
Dear Mr Charles,

Thank you for the Regulation 28 report of 15th January 2026 sent to the Secretary of State / the Department of Health and Social Care about the death of Matilda Gwen Pomfret- Thomas. I am replying as the Minister with responsibility for secondary care.

Firstly, I would like to say how saddened I was to read of the circumstances of Matilda’s death and I offer my sincere condolences to their family and loved ones. The circumstances your report describes are concerning and I am grateful to you for bringing these matters to my attention.

The report raises concerns over the absence of formal regulation, registration, and training for doulas, highlighting risks to patient safety where unregulated birth support roles are involved. The report suggests a lack of regulation & standardised training creates variability in knowledge, capability, and adherence to safe practice.

In preparing this response, my officials have made enquiries with NHS England and the NMC to ensure we adequately address your concerns.

There is no legal requirement doulas to have any training or qualifications. The role is usually performed by people from a wide variety of backgrounds, who are not subject to oversight by the Nursing and Midwifery Council (NMC) or General Medical Council (GMC), or other professional regulatory oversight. However, if the role of a doula is carried out by a regulated healthcare professional, they would be subject to regulatory oversight by the relevant regulator. Even if a healthcare professional is acting in a personal role, they cannot ‘opt out’ of their core duties and responsibilities.

Any organisation that holds a register for doulas is an independent, representative body and as such, they do not fall under Government oversight. Therefore, any decisions about the practice requirements for the professions they represent are a matter for those organisations and their members. I note that your report has also been sent to the Nursing and Midwifery Council (NMC) as the independent regulator of midwives in the UK. I understand that the NMC’s ‘Principles for supporting women's choices in maternity care’ includes information on the role of doulas, which were developed to support midwives and organisations providing personalised care for women during pregnancy, birth and the postnatal period. The NMC has also worked with Doula UK to launch a video resource intended to clarify the distinct roles that midwives and doulas play for women and families, in addition to setting out how the professions can work together to support positive maternity experiences. The maternity principles and video are available at:

maternity-care/. The National Institute for Heath and Care Excellence (NICE) publishes clinical guidance to improve health and social care, including the Guideline on Intrapartum care (2023). That guidance covers the care of women and their babies during labour and immediately after birth in all settings and addresses issues around planning the place of birth. The NHS supports women having someone with them during labour and birth when they choose it. This is often their life partner, but equally may be another relative, friend or a doula. The Nursing and Midwifery Council (NMC) Standards of proficiency for midwives (2019) expects midwives to be able to work with women, their partners and families, and by extension therefore with a doula. That said, Doulas must not undertake midwifery or other clinical care. Given the unregulated nature of the Doula role, and that the support they give during labour and birth carries no additional status than for anyone else, NHS England will not be producing guidance for midwives’ interactions with doulas. I hope this response is helpful. Thank you for bringing these concerns to my attention.
NMC Regulator / Inspectorate
10 Mar 2026 PDF
Action Taken

The NMC has updated its guidance and collaborated with Doula UK to launch a video resource clarifying the distinct roles of midwives and doulas to support positive maternity experiences. They stated that doula registration, regulation, and training are beyond their remit and a matter for government policy. (AI summary)

View full response
Dear Sir

Regulation 28 Prevention of Future Deaths report dated 15 January 2026 in relation to Matilda Gwen Pomfret-Thomas

I would like to begin by offering my heartfelt condolences to the family of Matilda for their tragic loss.

Your report identifies two specific areas where you consider action is necessary in respect of the role of doulas and the support they provide through pregnancy, labour and after the birth of a baby. As Chief Executive and Registrar of the Nursing and Midwifery Council (NMC), I take the matters of concern set out in your report very seriously, whilst recognising that some of the issues raised sit outside our remit.

Our vision is to provide safe and effective midwifery education and practice across the four countries of the UK. I set out below the steps we will be taking, and have already taken, to the address some of the issues in relation to the relationship between midwifery professionals and doulas (or other ‘unregulated professionals’) highlighted by your investigation.

Actions arising from your report

1. There was evidence given at the inquest by experienced midwifery professionals highlighting that provision of guidance would be helpful for all involved with a birth at which a doula was present.

Our role is to protect the public and maintain confidence in the nursing and midwifery professions. We support midwives to deliver safe and effective midwifery care through our regulatory processes. We do this by setting the standards of conduct and performance through the Code and competencies through the standards of proficiency for midwives, which specify the knowledge, understanding and skills that midwives must demonstrate at the point of qualification and after registration, when caring for women, newborn infants, partners and families throughout the maternity journey and across all care settings.

2

Doulas are not a regulated profession and do not fall within the remit of the Nursing and Midwifery Council. We therefore cannot set standards of training or produce guidance on the role of doulas and other unregistered birth workers. However, as the regulator of midwives we will continue working with others to provide information which supports both the public’s and professionals’ understanding of these different roles and the standards of care people should expect from registered midwives.

Action taken to support the role of midwives

Through our regulation of midwifery professionals, and our ongoing relationships with senior midwifery professionals across the four nations of the United Kingdom, we have already identified some of the issues that may arise where women choose to engage the services of unregulated birth support professionals, instead of or in addition to registered midwives.

In August 2025, we launched our “Principles for supporting women's choices in maternity care” webinar, with supporting frequently asked questions from our launch webinar factsheet. This all sets out a series of principles that have been developed to support midwives and organisations providing personalised care for women during pregnancy, birth and the postnatal period, wherever the care takes place. We have addressed the following points:

• Doulas are not regulated practitioners

• Doulas and other birth workers may have a range of names and titles, such as ‘birthkeeper’, ‘birthworker’, and ‘mother’s helper’, for example. In addition, some may have formerly practised as midwives but are no longer registered.

• The role of doulas and other non-registered birth workers is to provide psychological and social support but they are not there to provide midwifery care and advice which is the role of a registered midwife.

The NMC has also worked with Doula UK to launch a video resource intended to clarify the distinct roles that midwives and doulas play for women and families, in addition to setting out how the professions can work together to support positive maternity experiences. The maternity principles and video are available at: https://www.nmc.org.uk/standards/guidance/principles-for-supporting- womens-choices-in-maternity-care/.

2. The issues of doula registration, regulation and training are therefore points of concern I would commend for review. We are not taking any action in respect of the issue of doula registration, regulation and training as this is beyond the remit of the Nursing and Midwifery Council and is a matter for government policy.

Where we receive evidence of any concerns that may be relevant to public safety, we may decide to refer matters to the police or other appropriate authorities for further investigation, particularly where there is evidence of a poor outcome. We will raise this report at the next meeting of the Maternity Regulation Oversight Group (MROG), an internal group that meets regularly to oversee our regulatory response to concerns raised. The next meeting is on 11 March.

3

Conclusion

Thank you for sharing the areas of concern that you have identified, during your investigations, with us. I hope my setting out of our responses with respect of each concern has been helpful.

Once again, I would like to offer my condolences to Matilda’s family for their tragic loss.

Report sections

Investigation and inquest
On 15 November 2023 I commenced an investigation into the death of Matilda Gwen POMFRET-THOMAS aged 15 Days. The investigation concluded at the end of the inquest on 04 December 2025. The medical cause of death was Hypoxic Ischaemic Encephalopathy. The narrative conclusion of the inquest was as follows: Matilda Pomfret Thomas sadly died on 13th November 2023 at Naomi House and Jacks Place, Stockbridge Roads, Sutton Scotney, Winchester, Hampshire by reason of Hypoxic Ischaemic Encephalopathy. She was 15 days old at the date of her death. She was born on 29th October 2023 at Queen Alexandra Hospital following a difficult labour at home. The Hypoxic Ischaemic Encephalopathy had developed over a period of hours. Meconium had been observed, decelerations were later observed. was not taken to hospital following those complications becoming apparent until 12.13 on the 29th October 2023. The background is of a traumatic first birth that impacted upon decision making for this second pregnancy and birth. Matilda’s parents had seen a home birth as the best way forward. Labour started in the early hours of 29th October 2023 and there was prompt midwife attendance. An initial and appropriate offer at 7.19 of transfer to hospital upon meconium being found was not accepted, thereafter the implications of a deteriorating situation involving decelerations against a background of the presence of meconium – including further clear signs of it at 10am, requiring hospital transfer, was not communicated in such a way as to lead to a transfer to hospital. An element of what occurred is that the presence and work of a doula did on this occasion negatively impact upon the effective provision of midwifery services in terms of building a rapport conducive to effective advice and care being given.
Circumstances of the death
Please see the narrative conclusion. The birth of the family’s first child had been traumatic and, for the birth of their second child, they were focussed on achieving a different birth experience and elected to use a doula to provide them with support at a home birth. The hospital’s preference was for a hospital delivery, there was discussion as to what circumstances would result in the mother being blue lighted to hospital. Signs of fetal distress developed but the mother was not immediately transferred to hospital. A difficult atmosphere had developed, the midwives felt access was being restricted by the doula: I found that she did not actively discourage midwife access but that she was seen as, in effect, a buffer by members of the midwifery team. The doula was following the birth plan. The doula was supporting the parents per the birth plan, and this appears to have been perceived as grounds for hope that a home birth was still possible.
Inquest conclusion
Matilda Pomfret Thomas sadly died on 13th November 2023 at Naomi House and Jacks Place, Stockbridge Roads, Sutton Scotney, Winchester, Hampshire by reason of Hypoxic Ischaemic Encephalopathy. She was 15 days old at the date of her death. She was born on 29th October 2023 at Queen Alexandra Hospital following a difficult labour at home. The Hypoxic Ischaemic Encephalopathy had developed over a period of hours. Meconium had been observed, decelerations were later observed. was not taken to hospital following those complications becoming apparent until 12.13 on the 29th October 2023. The background is of a traumatic first birth that impacted upon decision making for this second pregnancy and birth. Matilda’s parents had seen a home birth as the best way forward. Labour started in the early hours of 29th October 2023 and there was prompt midwife attendance. An initial and appropriate offer at 7.19 of transfer to hospital upon meconium being found was not accepted, thereafter the implications of a deteriorating situation involving decelerations against a background of the presence of meconium – including further clear signs of it at 10am, requiring hospital transfer, was not communicated in such a way as to lead to a transfer to hospital. An element of what occurred is that the presence and work of a doula did on this occasion negatively impact upon the effective provision of midwifery services in terms of building a rapport conducive to effective advice and care being given.

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Report details

Reference
2026-0025
Date of report
15 January 2026
Coroner
Henry Charles
Coroner area
Hampshire, Portsmouth Southampton

Responses identified

Responses identified 4 of 3
All listed responses identified

Organisations named in PFD reports are normally expected to respond within 56 days. Deadline: 12 Mar 2026 (estimated).

Sent to

Department of Health and Social Care
NICE
Nursing and Midwifery Council

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