In what has now become an annual event the DfE has once again issued a new version of Keeping Children Safe in Education (KCSIE) for implementation from 1 September 2025. The final version was published 1 September 2025, the day of implementation.
Although the changes this year are described as “technical”, as was the 2024 iteration, it is stated that future iterations will reflect the progress into legislation of the Children’s Wellbeing and Schools Bill, the emerging further learnings from the Casey Audit (the National Audit on Group-based Child Sexual Exploitation and Abuse – https://www.gov.uk/government/publications/national-audit-on-group-based-child-sexual-exploitation-and-abuse ) and subsequent inquiries, the Violence Against Women and Girls Strategy, introduced by the Conservative government in 2021, and the interactions between these advances.
The substantive changes
So turning to the main changes for September 2025; it is only Parts Two, Three, Four and Five which contain these changes: –
Part Two – the management of Safeguarding
Online safety
It is essential that children are safeguarded from potentially harmful and inappropriate online material. An effective whole school approach to online safety empowers a school to protect and educate pupils, students, and staff in their use of technology and establishes mechanisms to identify, intervene in, and escalate any concerns where appropriate.
The breadth of issues classified within online safety is considerable and ever evolving, but can be categorised into four areas of risk:
- content: being exposed to illegal, inappropriate, or harmful content, for example: pornography, racism, misogyny, self-harm, suicide, anti-Semitism, radicalisation, extremism, misinformation, disinformation (including fake news) and conspiracy theories.
- contact: being subjected to harmful online interaction with other users; for example: peer to peer pressure, commercial advertising and adults posing as children or young adults with the intention to groom or exploit them for sexual, criminal, financial or other purposes.
- conduct: online behaviour that increases the likelihood of, or causes, harm; for example, making, sending and receiving explicit images (e.g. consensual and non-consensual sharing of nudes and semi-nudes and/or pornography, sharing other explicit images and online bullying, and
- commerce: risks such as online gambling, inappropriate advertising, phishing and or financial scams. Schols are advised that if they feel that pupils, students or staff are at risk, to report it to the Anti-Phishing Working Group (https://apwg.org/).
Online safety and the school’s approach to it should be reflected in the child protection policy which should include appropriate filtering and monitoring on school devices and school networks. Schools should have a clear policy on the use of mobile and smart technology, which will also reflect the fact that many children have unlimited and unrestricted access to the internet via mobile phone networks (i.e. 3G, 4G and 5G). This access means some children, whilst at school, sexually harass, bully, and control others via their mobile and smart technology, share indecent images consensually and non-consensually (often via large chat groups) and view and share pornography and other harmful content. Schools should carefully consider how this is managed on their premises and reflect this in their mobile and smart technology policy and their child protection policy
The 2025 guidance adds disinformation, misinformation and conspiracy theories to the list of content risks under online safety.
- Disinformation is the deliberate creation and spread of false or misleading content, such as fake news.
- Misinformation is the unintentional spread of this false or misleading content (Cabinet Office, Department for Science, Innovation and Technology, 2023)
Filtering and monitoring
KCSIE 2025 includes a link to the government “plan technology for your school” service, which schools can use to assess themselves against the filtering and monitoring standards, and helpfully can receive personalised recommendations on how to meet them.
A link is added to the DfE guidance on the use of generative AI in education (2025). This guidance explains how filtering and monitoring requirements apply to the use of generative AI in education and supports schools to use generative AI safely.
Alterative provision
The updated guidance provides additional information to clarify and reflect existing alternative provision guidance, highlighting how schools should:
- gain written confirmation from the alternative provider that appropriate staff safeguarding checks have been carried out, as well as written information about any arrangements that may put the child at risk
- have records of the address of the alternative provider and any subcontracted provision or satellite sites the child may attend
- regularly review any alternative provision placements to make sure the placement continues to be safe and meets the child’s needs. If safeguarding concerns occur, the placement should be immediately reviewed and ended if necessary.
Children who are absent from education
The updated guidance makes clear that the DfE’s “Working together to improve school attendance” guidance is now placed on a statutory footing.
Virtual School Heads
Paragraph 199 has been amended to clarify that from September 2024, the role of Virtual School Heads was further extended to include a non-statutory responsibility to promote the educational achievement of all children in kinship care. Non-statutory guidance on “Promoting the education of children with a social worker and children in kinship care arrangements” contains further information on the roles and responsibilities of Virtual School Heads.
Part Three – Safer recruitment
The changes contained in Part 3 are updated links to GOV.UK page when carrying out safer recruitment checks, such that reference to TRA’S Employer Access Service, and Employer Secure Access have been removed and updated from Paragraphs 260, 266 and 319 respectively.
Paragraph 331 now contains additional information that clarifies and reflects the existing AP Guidance such that schools should obtain written confirmation from the alternative provision provider that appropriate safeguarding checks have been carried out on individuals working at the establishment, i.e. those checks that the school would otherwise perform in respect of its own staff. This includes written confirmation that the alternative provider will inform the commissioning school of any arrangements that may put the child at risk (i.e. staff changes), so that the commissioning school can ensure itself that appropriate safeguarding checks have been carried out on new staff.
Part Four – Safeguarding concerns or allegations made about staff, including supply teachers, volunteers and contractors
Paragraph 422 has been amended to correct the title of the Information Commissioners guidance on employment records which provides practical advice on record retention – The Information Commissioner’s Employment Practices Code
Part Five – Child-on-child sexual violence and sexual harassment
In the general scheme of things this may be viewed as a minor change:-
A link is added to the Lucy Faithfull Foundation’s “Shore Space” an online resource which works to prevent harmful sexual behaviour. Shore Space offers a confidential chat service supporting young people who are concerned about their own or someone else’s sexual thoughts and behaviour.
Next steps
In light of these amendments, it is advised that all schools and academy trusts update their policies and ensure all staff receive training.
The policy should include the necessary amendments; not every word of every change is required to be reflected in your policy, but your policy is designed to achieve strong safeguarding practice that reflects what happens on the ground.
Staff training is essential to ensure strong and positive safeguarding; all staff need to be updated about the changes to this year’s version of KCSIE, but consider how this can be done in a practical and engaging way.
It is for individual governing bodies and academy trusts to collectively to measure outcomes; by measuring and ensuring staff knowledge, remembering that knowledge and practice is the key not attendance or staff confirmation that they have read something. It is governing bodies and proprietors, (academy trusts), who have the ultimate responsibility for strategic leadership and safeguarding and promoting the welfare of children.
For assistance with all your Safeguarding and Child Protection issues please contact our team of specialist lawyers at schoolsupport@wslaw.co.uk or on 0345 070 7437.