KCSIE September 2025: changes and possible actions for schools

We now have the finalised version of Keeping Children Safe in Education 2025 with minimal changes from either the July draft or the 2024 version of the guidance.  

While there is relief that we do not have to manage last minute changes, the frustrations that this is another year with a ‘technical changes’ only document continue. The world of safeguarding is changing fast, including, but not exclusively, within online safety, and we are left with a document that feels increasingly outdated.  We are told that further iterations of the guidance will reflect changes in the Children’s Wellbeing and Schools Bill, learnings from the recent Casey Audit and subsequent inquiries and the Violence Against Women and Girls strategy, but none of this, even where the information is already published, has been included in the new guidance. Further, it is not clear if we are to expect these further ‘iterations’ as ‘drip fed’ updates throughout the school year or as part of the 2026 update.

When our basic statutory document is in this state, it is beginning to have serious implications for our ability to safeguard the children in our care.

So what should schools do?

The bottom line is very little, directly related to KCSIE, beyond updating policies to reflect the changes we have, including changes in other statutory and non-statutory guidance, and to be aware of the possibility of further changes coming during the academic year.

Changes to Keeping Children Safe in Education 2025:

• The revised guidance on Relationships, Sex and Health Education was published over the summer for introduction in September 2026 and is linked in KCSIE. Please read my blog on this guidance for more information.

• The information included about ‘gender questioning’ pupils is unchanged. This was ‘under review’ this time last year and despite, or possibly because of, the ruling of the supreme court we are still awaiting clear guidance. Annexe F and paragraph 204 indicates that once this guidance is published, signposting will be added to KCSIE 2025 e.g.  there will be an update.

• The one substantive change in the guidance relates to alternative provisions and reflects the new guidance in this area released in February 2025. This clarifies that:

• School should obtain written information from the AP regarding appropriate safeguarding checks on their staff including written confirmation of any changes e.g. staff changes, that may put a child at risk.  Commissioning schools can then check and assure themselves that the appropriate safeguarding checks have been carried out on staff.

·       School should always know where a child is based during school hours, so have records of the address of the AP and any subcontracted provisions or satellite sites. This needs to be supported by frequent (at least half termly) reviews on attendance and to confirm that the placement continues to be appropriate, safe and meet the child’s needs.

·       If there is a safeguarding concern, the placement should be reviewed immediately and terminated, if necessary. (para 169-70 and partly repeated under Part 3: Safer recruitment in paragraph 331)

In Annexe F, these paragraphs are indicated as being about cyber resilience rather than AP. I assume that this is an error.

• Under the information on the 4 C online safety risks (Content, contact, conduct and commerce), the list of content risks has been extended to included ‘misinformation, disinformation (including fake news) and conspiracy theories’ as additional areas of risk. (page 38, para 135). This feels a bit like stating the obvious, which the vast majority of teachers are well aware of, without adding anything to our understanding of how to respond to or manage these risks.

• Still under online safety on page 40 in para 142, we are pointed to the government document ‘Plan technology for your School’ to support self-assessment for filtering and monitoring standards. Then the following paragraph condenses several paragraphs into one using bullet points. This impacts the paragraph numbering when compared to KCSIE 2024. The final bullet points adds a link to the new guidance on Generative AI. There is a missed opportunity to say more about this and its impact on children’s safeguarding.

  This is followed by a few additional words, in paragraph 144, on the role of the Cyber Security standards for schools and colleges.

• Working Together to improve attendance is now a statutory document and schools must work with LA children’s services where school absence indicates a safeguarding concern (paragraph 177). This ignores the fact for most schools the difficulty is meeting social care thresholds and gaining support when there are concerns about educational neglect and other safeguarding issues related to attendance.

• Paragraph 199 clarifies the changes in the role of the Virtual head from September 2024 to include a non-statutory responsibility to promote the educational achievement of all children in kinship care.

• In Part 3 there are changes to the online links replacing TRA’s employer access service with new links.

• There is an additional link to the Lucy Faithful Foundation’s Shore Space confidential chat service to support young people concerned about sexual thoughts and behaviours.

• There is a new clarification hidden within Annexe F about the definition of extremism. In the 2024 guidance, there was a review pending regarding the so-called ‘Gove definition’ of extremism which was produced in response to a statement by Michael Gove in the House of Commons on March 14^th, 2024. This had no legal basis as the law cannot be changed simply by a minister making a statement in Parliament. There is a due process which needs to be followed and was not. This seems to have been quietly dropped and the guidance has returned to the definition used within the PREVENT guidance.  

• CEOP and the National Crime Agency’s online safety resources have been rebranded from Thinkuknow to CEOP Education.

There are a few additional word changes, such as replacing ASD with Autism.

What changes are not included yet but may be added during the year.

• We are still awaiting clarification on the support for trans and gender questioning pupils. This guidance should be updated at some point this year and then signposted in KCSIE.

• There is nothing on mandatory reporting as recommended by the Independent Inquiry into Child Sexual Abuse (IICSA) led by Prof. Alexis Jay. We know that this is being included in the Policing and Crime Bill and could have been highlighted here.

• The Online Safety Act has finally passed Parliament and is beginning to be implemented but the changes involved are not reflected here. There has been some fiddling with the online safety section of KCSIE, including links to the guidance on the use of Generative AI, but it is not substantial or reflective of the rapid changes happening in the real world.

• There is no new guidance on reasonable force or indication of possible links to future guidance, despite the launch of a consultation on the ‘Use of reasonable force and other restrictive interventions’ guidance in February 2025. It is not clear what is happening with this?

• There is nothing on support for additionally vulnerable groups, such as highly mobile children or young carers.

• There has been no action on the issues about the DSL role, workload and the need for supervision which were highlighted in the 2024 consultation. Changes in this area were not dependent on legislation passing Parliament but still have not been acted upon.

  
  

Possible actions for schools

• Consider how other statutory and non-statutory guidance for example on Alternative provisions or Generative AI will impact safeguarding in your setting. Ensure that these are reflected in policies and staff training.

• Update your safeguarding policy to include clear information on safeguarding any pupils attending alternative provisions. Check all those involved with placing children in such provisions are aware of the additional safeguarding vulnerabilities of these children and have clear lines of communication with the alternative provision to ensure that they know where the children are based each day and safeguarding information is shared effectively.

• Add the additional information to your safeguarding and online safety policies about the additional content risks.

o   Misinformation where false information is shared by accident without intent to cause harm

o   Disinformation where false information is deliberately shared to mislead and cause harm

o   Fake news is purposely crafted, sensational, emotionally charge misleading or totally fabricated information that mimics the forms of mainstream news.

There are obviously grey areas between these where we are asked to consider people’s intentions and motivations which may not be clear, even to them.

 Also consider how these elements will be reflected in your staff training and within the curriculum.

• Check that your filtering and monitoring meets the requirements of the government technology control plan and cybersecurity standards.

• If you have not already done so, look at the government guidance on Generative AI and consider the implications for your school.

•   Ensure that you are using the Working Together to improve attendance document.

• Ensure that you discuss with your virtual headteacher how they can support you to promote educational outcomes for children in kinship placements.

Stay up to date

This year, I am offering a monthly online DSL update at 4pm on the second Tuesday of each month (September-July).

These monthly update webinars for DSLs include

• All the information coming out from the DfE and elsewhere summarised

• Key points highlighted

• the actions needed for schools

• All links are included

• A copy of the slides will be sent after the webinar.

You can buy

• a monthly ticket via Eventbrite at £15.00 per session

• Or purchase a 'season ticket' for the whole year at £150.00 to get a free webinar and reduce admin hassle by emailing seainclusion@btinternet.com