Late additions to (KCSIE) guidance rendered school safeguarding policies “out of date” at the start of term, leaders have warned.
These concerns come amid wider criticism of the growing volume of guidance and documents that schools are expected to keep up with.
Designated safeguarding leads (DSLs) previously raised fears that changes to KCSIE announced in July left schools with an “unrealistic deadline” - just 56 days - to implement safeguarding updates before the start of the new academic year.
However, it later emerged that the final version of KCSIE, published on 1 September, contained further additions that had not been previously announced.
This has led to warnings that schools are being “set up to fail” as they strain to keep up with “ever-expanding requirements”.
Changes to volunteer vetting
Schools had been told in July that existing volunteers could undertake regulated activity before enhanced DBS certificates had been returned, providing schools carried out a standalone barred list check.
However, the final KCSIE document says that schools subject to the must not allow staff to start work in such settings until they have received an enhanced DBS certificate, including barred list information.
Prejudice-based harm duty
Another update made to the final guidance is a requirement for all staff to recognise that children may experience prejudice-based harm, including racism, faith-based prejudice and other forms of discrimination.
Sexual abuse definition
And under “indicators of neglect” in the final version of KCSIE, the definition of sexual abuse was widened from “forcing or enticing” to “forcing, causing or inciting”, with new lines confirming that children are more likely to know their abuser than not, and that under-13s can never legally consent to sexual activity.
Additions to the final guidance also include a requirement for all staff to recognise that faith-targeted abuse and discrimination could have a “significant” impact on pupils’ sense of safety and wellbeing, alongside an expanded definition of child-on-child abuse.
Laura Phillips, head of safeguarding at Lift Schools, emphasised that some of the additions should be classified as expansions of existing policy rather than “significant changes”.
However, “anything that is in a document such as KCSIE, if included, should be classed as being important”, she said.
‘Out of date’ policies
While safeguarding leaders have welcomed the clarifications, the manner in which they were introduced has drawn criticism.
Keziah Featherstone, executive trust leader at The Mercian Trust in the West Midlands, told Vlog the additions to KCSIE were undeniably important, but making these changes as term began was “incredibly frustrating”.
Christine Kane, deputy head of safeguarding at Marlborough College, said: “My concern is the way the changes were introduced. The amendments to KCSIE 2026 were not clearly identified or highlighted against the July draft, meaning schools had to identify the changes themselves.
“Many schools had already completed safeguarding Inset training, updated policies and briefed governors based on the draft guidance.”
Ms Kane said that updates were made to the document after the school term had started, and further guidance was added to in October.
Because KCSIE 2026 came into force for schools on 1 September, “some safeguarding policies were effectively out of date within weeks of the start of term”, Ms Kane added.
She said that schools always adapt to changing safeguarding risks, but that there is a “legitimate question” as to whether the volume of changes is making it harder for schools to implement guidance.
Richard Lundie, DSL at The Wensleydale School in Yorkshire, told Vlog he was only aware of the updates because he had “learned from my experience as a safeguarding lead not to trust the pre-release that comes out before the summer”.
“I planned my safeguarding training the day before delivering it to ensure I captured everything that was in KCSIE, but that’s from my prior knowledge. I know that the people that write KCSIE tend to throw things in over the summer holidays that wouldn’t necessarily get noticed”, he added.
Growing responsibilities
KCSIE, and schools’ safeguarding responsibilities, have grown substantially in recent years. The document itself has expanded from in 2018 to 198 pages this year.
The expansion reflects schools’ increasing responsibilities as safeguarding partners, but is also raising questions as to whether the document has become too big.
At a Labour Party conference fringe event in September, Russell Hobby, CEO of The Kemnal Academies Trust, referenced KCSIE when discussing workload in schools.
Mr Hobby said: “What I would really emphasise hard [to the DfE] is stop making policies longer. KCSIE is one of the longest documents...I don’t believe those extra pages make children safer.”
Ms Featherstone stressed that the role of a DSL has “massively widened” in recent years and “many schools need more than one DSL to keep up”.
“Patience does wear thin when there is no warning and updated guidance goes out just as we start term again”, she said.
Thomas Michael, a West Midlands DSL, said schools needed time to “digest and to understand” KCSIE.
“Having it land on the first day of the new academic year doesn’t give you any time at all,” he said.
A Department for Education spokesperson said: “We recognise the vital role safeguarding leads play in keeping children safe and the importance of giving schools and colleges sufficient time to prepare for any significant changes.
“That is why we always publish a ‘for info’ version ahead of the guidance coming into force. We made some minor factual amendments to the guidance, as is usual practice, none of which were intended to place any new burdens or duties on schools.”
Schools ‘set up to fail’
Earlier this month, Pepe Di’Iasio, general secretary of the Association of School and College Leaders, told a Conservative Party conference fringe event that he would like to see “massive deregulation” from the DfE, referencing “ever-expanding requirements” in KCSIE as an example of the burden on schools.
On the latest additions to KCSIE, Mr Di’Iasio told Vlog: “Nothing is more important to schools than safeguarding, but if new requirements are being added quietly at the last minute then they are being set up to fail.”
He said that KCSIE is “undoubtedly lengthy”, but this reflects the complexity of safeguarding in schools, and that any material changes need to be “clearly signposted”, allowing schools the requisite time to ensure all staff are aware and informed.
“This is something that needs careful consideration over weeks and months - it cannot be done at the last minute”, he said.
Vlog understands that the DfE is now considering how it can provide more helpful supporting communications alongside future updates.
