This article is part of a suite of charity law updates on the Autumn 2026 Charity Commission guidance. 

The Charity Commission updated its safeguarding guidance in October 2026, reaffirming that safeguarding is a governance priority for all charities. This section explains what trustees must have in place, what has changed for regulated activity with children, and the key actions to take now.

What's changed? 

The Charity Commission's guidance on safeguarding and protecting people was updated on 8 October 2026. The guidance reaffirms that safeguarding should be a governance priority for all charities and is a fundamental part of operating for the public benefit.

Trustees must take reasonable steps to protect from harm all people who come into contact with the charity, including beneficiaries, staff, volunteers and others. The Commission can hold trustees to account if things go wrong and will assess whether trustees followed the guidance and the law.

The Commission expects all charities to have appropriate safeguarding policies and procedures in place, followed by all trustees, staff, volunteers and beneficiaries. Charities must know how to spot and handle concerns, have a clear system for referring or reporting to relevant agencies, maintain a risk register identifying safeguarding risks and how they'll be managed, and conduct periodic reviews of safeguarding policies, procedures and practice. 

Trustees should ensure policies are responsive to change, reviewed at least annually and always following a serious incident, and made available to the public.

Two significant changes to Disclosure and Barring Service (DBS) arrangements also took effect in 2026:

• From 21 January 2026, self-employed individuals (such as nannies, tutors and sports coaches) can now apply for an enhanced DBS check through a DBS Umbrella Body, which they can then share with current or potential employers. 
• From 1 September 2026, the supervision exemption for regulated work with children no longer applies. Certain staff and volunteers who teach, train, instruct, care for or supervise children frequently or overnight will now be classed as carrying out regulated activity, even if supervised. Trustees should ensure their charity reviews affected roles and updates its DBS checking arrangements where necessary.

Safeguarding children or adults at risk

Where a charity works with children (anyone under the age of 18) or adults at risk, whether online or in person, additional safeguarding requirements apply. An adult at risk is a person aged 18 or over who has needs for care and support (whether or not the local authority is meeting any of those needs), is experiencing or is at risk of abuse or neglect, and as a result of those care and support needs is unable to protect themselves from either the risk of, or the experience of, abuse or neglect.

Safeguarding requirements for charities working with children or adults at risk:

• Trustees must ensure that the charity has appropriate safeguarding policies and procedures that align with the relevant local authority safeguarding partnership or board.
• All staff and volunteers to receive regular training on child protection or working with adults at risk.
• A safeguarding lead is appointed to liaise with local authority safeguarding partnerships or boards.
• Concerns, complaints, whistleblowing and allegations are managed effectively.
• Clear policies on when DBS checks are required, the level of check needed and how the resulting information is handled.

Online safeguarding risks

Charities operating online must ensure that risks connected to content, contact and conduct are managed and reflected in their policies and practices. 

The guidance draws attention to the Online Safety Act 2023: charities that use social media or deliver online services in certain ways (for example, by running an instant messaging service or online forum where users can post content and communicate with each other) may need to comply with the Act and put in place measures to protect users, particularly children.

Grant-making charities

Charities that make grants to, or work in partnership with, other organisations must carry out proper due diligence to ensure that any grant recipient or partner body has appropriate safeguarding procedures in place. 

This applies to delivery partners, trading subsidiaries (including charity shops), organisations the charity funds and connected charities. Trustees should ensure there are clear lines of responsibility and reporting between all bodies involved and should have a written agreement setting out the relationship, the role of each organisation and the monitoring and reporting arrangements. Where a charity funds work overseas, the Commission expects enhanced due diligence on safeguarding.

Key action points

• Review your charity's safeguarding policies and procedures to ensure they are current, compliant with relevant legislation and statutory guidance, and reviewed at least annually and following any serious incident.
• In light of the changes to DBS arrangements effective in 2026, review all roles within the charity to determine whether any are now classed as regulated activity and whether DBS checking arrangements need to be updated, in particular, roles involving the teaching, training, instruction, care or supervision of children.
• If your charity operates online services or uses social media, assess whether the Online Safety Act 2023 applies and, if so, ensure your social media policy and safeguarding procedures reflect its requirements.
• Ensure there is a clear process for reporting safeguarding concerns to the relevant agencies (such as the police, local authority safeguarding partnerships and the Charity Commission) and that all trustees, staff and volunteers understand how to raise a concern.
• Confirm that safeguarding is a standing agenda item at trustee board meetings and that the board receives regular reports on safeguarding activity, training and any incidents or near-misses.
• If your charity works with children or adults at risk, ensure a safeguarding lead has been appointed, that safeguarding policies align with the relevant local authority safeguarding partnership or board, and that all staff and volunteers receive regular and up-to-date training on child protection or working with adults at risk.
• Where your charity makes grants to or works with partner organisations, ensure that due diligence on safeguarding is carried out before funding is provided and that written agreements include clear safeguarding requirements, reporting lines and monitoring arrangements.