Child protection developments – update for the public sector

Child safeguarding has been a priority issue for the government and regulators in recent years.

As well as moving up the political agenda, there has been a shift in public attitudes, with a broader understanding and acknowledgement towards the victims of abuse and exploitation. Safeguarding and protection is widely discussed. Media interest continues to press for answers and solutions.

Only this week, we have seen the Tech Secretary, Liz Kendall, address the House of Commons promising action against the social media platform X after its AI tool (Grok) was used to create sexualised images of women and children. She referred to the findings of the Internet Watch Foundation, which reported images of topless children on the platform and referred to this as “child sexual abuse”. Ofcom have also confirmed that they will be investigating.

This heightened focus has resulted in new and proposed changes to policy, regulation and legislation. As a result of numerous consultations, inquiries, reports and audits, there have been several developments which will impact all aspects of the public sector.

Here, we highlight the key impacts following recent developments.

Independent Inquiry into Child Sexual Abuse inquiry (IICSA)

In October 2022, the IICSA published its final report setting out 20 recommendations to protect future generations of children from sexual abuse. The inquiry, led by Professor Alexis Jay OBE concluded that systemic failures across public services had contributed to abuse being undetected and unchallenged. 

Since winning the election in 2024, the Labour government has now begun to translate IICSA’S recommendations into concrete reform proposals, which if implemented promise significant implications for child protection, civil justice, and the legal landscape for survivors of abuse.

One of the key proposals is the formation of a Child Protection Authority (CPA) to provide national oversight to address fragmentation in safeguarding intelligence, data and lessons learned from serious cases. The CPA is envisaged to make multi-agency child protection clearer and more unified; bringing together insights from local authorities, health, police, social care and inspection bodies to improve outcomes for children, and stronger accountability.  

Frontline enforcement will remain with the police and prosecutors, but the CPA is expected to work closely with and support existing inspectorates to drive improvements in multi-agency practice. 

There are also proposals around the limitation and burden of proof, with plans to introduce legislation to remove the three-year limitation period for personal injury claims arising from child sexual abuse. Alongside this, the burden of proof on limitation issues will shift: this responsibility will now fall to the defendant to show that proceeding would be fundamentally unfair. 

While these reforms mark clear progress on IICSA’s recommendations, they also raise questions about scope, implementation and effectiveness. For example:

• How broad will the Child Protection Authority’s powers extend in practice, and how will it balance oversight with local autonomy?
• How will courts interpret the new limitation regime and fair hearing protections?
• How effectively will duties on tech providers as prescribed by the Online Safety Bill be enforced and will they work in practice to deliver the stronger age verification and broader protections envisaged by IICSA, particularly in relation to grooming? 
• Is further reform, including for example a national redress scheme essential to fully deliver on the spirit of IICSA’s report?

To read more detail about the key recommendations, see our article Developments in child protection following the Independent Inquiry into Child Sexual Abuse

National Audit on Group-based Child Sexual Exploitation and Abuse 

Baroness Casey published the National Audit on Group-based Child Sexual Exploitation and Abuse in June 2025 (the Audit). 

This highlighted repeat patterns of scandal and public outrage leading to bursts of government focus, but then no sustained improvement. The intention of the Audit was to provide an opportunity for the government, policing, justice and safeguarding agencies and the country as a whole to draw a line in the sand between all previous reviews and to commit to a series of significant actions. 

Independent Inquiry into Grooming Gangs

On 9 December 2025 the Independent Inquiry into Grooming Gangs was established in response to recommendation 2 of Baroness Casey’s Audit. 

Baroness Longfield CBE is to Chair the Inquiry with panellists Zoe Billingham CBE and Eleanor Kelly CBE. The Chair is to consult on the draft terms of reference and the final terms of reference are to be published in March, when the Inquiry will be formally established. 

The purpose of the Inquiry is to identify failings in historic and current practice in tackling grooming gangs in local areas across England and Wales. It will identify systemic, institutional and individual failures and make recommendations for improvement both nationally and at local level. It will look at how ethnicity, religion and culture play a role in responses at local and national level as well as other issues outlined in the Audit.

To read more detail about the 12 recommendations within the Audit, see our article Developments in child protection following the Grooming Gangs audit and inquiry 

Comment 

Since the IICSA report, government policy in England and Wales has shifted towards implementing fundamental reforms in child protection. The proposed Child Protection Authority, mandatory reporting duties, amendments to the Limitation Act and the Online Safety Act, recognise shortcomings highlighted by the Inquiry. 

Whether these reforms will deliver structural improvements will depend on robust and well thought out implementation, multi-agency cooperation, and ongoing engagement with survivors and safeguarding professionals.

The recommendations of Baroness Casey’s Audit and the findings of the Independent Inquiry will affect every part of the public sector. We anticipate significant issues arising in relation to data protection, the Equality Act, malicious prosecution, misfeasance and Human Rights Act claims.

We will continue to track developments in these areas and will provide regular updates.