Part Four of the new Keeping Children Safe in Education guidance (KCSiE 2026) has been updated to make clear who leads when an allegation is made against an individual that a school or trust does not employ, such as a supply teacher, trainee teacher or contracted staff member. This is a welcome clarification which reflects good practice in the sector.

What does the updated paragraph 452 say?

Paragraph 452, under the heading 'Supply teachers, trainee teachers, and all contracted staff', has been updated from both the 2025 version and the draft 2026 version that the DfE consulted on. The new paragraph reads (italicised part is new):

"In some circumstances schools and colleges will have to consider an allegation against an individual not directly employed by them; for example, supply teachers, trainee teachers or contracted staff provided by an employment agency or business. Where this applies, schools and colleges share safeguarding responsibilities with the employment agency or business. Schools and colleges remain responsible for gathering the facts and managing the safeguarding process, while working closely with the employment agency or business, which will usually lead on any disciplinary action."

Why does this clarification matter?

In our experience, this is how it has usually worked. However, we have seen a few examples where neither party took the lead or where the school and employment business disagreed on who should lead and what steps should be taken. It is important to avoid these situations, so this simple clarification to the guidance is welcome.

What should schools and trusts do now?

Rather than wait until this is a live issue in your school or trust, we recommend contacting your supply agencies now to let them know of this change and to make clear that you will be leading. Most agencies will be aware of this change, but it does not hurt to make sure. Telling them now makes it much easier when you need to deal with an allegation in the future.

Updating your policies and procedures

You will also need to update your managing allegations procedure ready for September to reflect this change. We have already updated our model which forms part of our suite of policies.