FGM Mandatory Reporting Duty: What Schools and DSLs Must Know

What Is FGM?

Female genital mutilation (FGM) is a collective term for procedures that involve the partial or total removal of the external female genitalia, or other injury to the female genital organs, for non-medical reasons. It is also called female circumcision or female genital cutting.

FGM is illegal in England and Wales under the Female Genital Mutilation Act 2003 (as amended by the Serious Crime Act 2015). It is illegal to carry out FGM, to arrange for FGM to be carried out on a UK national or permanent resident (whether in the UK or abroad), or to fail to protect a girl at risk. There is no legal defence based on cultural, religious, or traditional grounds.

In 2022–23, the NHS reported 8,658 FGM-related attendances across NHS services in England.^[1] The true prevalence is substantially higher — many women never seek NHS care, and girls at risk may not be identified until adulthood.

The Mandatory Reporting Duty: Section 5B Serious Crime Act 2015

The mandatory reporting duty was introduced by section 5B of the Serious Crime Act 2015, which came into force on 31 October 2015. It created, for the first time in England and Wales, a legal obligation for specific regulated professionals to report known cases of FGM to the police.

This is distinct from the general duty to safeguard. It is a criminal law obligation. Failure to comply is a criminal offence.

What the Duty Requires

A regulated professional must make a report to the police if, in the course of their work, they discover that an act of FGM appears to have been carried out on a girl who is under 18 years of age at the time of the discovery.

Element	Detail
Who must report	Regulated professionals: teachers (all, including supply/agency), social workers, healthcare professionals
Who the duty protects	Girls under 18 only. Adult women: no mandatory duty, though other safeguarding duties may apply
What triggers the duty	Discovery that FGM appears to have been carried out — disclosure or physical signs (see below)
Where to report	The police (101 for non-emergency; 999 if the girl is in immediate danger)
Timescale	Within one month of the discovery. Early reporting is strongly encouraged
Consent required	None — from the girl, parents, or anyone else
Professional discretion	None — the duty is mandatory; it cannot be overridden by professional judgement

What Triggers the Duty: Two Routes

The duty is triggered in exactly two circumstances. Both require that the professional makes the discovery in the course of their work.

Route 1: Disclosure

A girl under 18 tells you — in words, actions, or drawings — that FGM has been carried out on her. This includes:

• A direct verbal statement ("I had the operation done")
• An indirect statement or reference to it having happened
• A disclosure to another professional that is then shared with you in the course of your work

You do not need to confirm or investigate the disclosure. If a girl under 18 tells you FGM has been carried out on her, the duty is triggered immediately.

Route 2: Physical Signs

You observe physical signs that FGM appears to have been carried out on a girl under 18. In a school context this is most likely to arise during a medical examination or PE lesson, or be reported by a member of staff who has observed signs while providing personal care.

Teachers are not expected to examine girls for physical signs — this would be inappropriate and is not required. However, if physical signs are observed incidentally, the duty applies.

What Does NOT Trigger the Mandatory Duty

Future risk of FGM does not trigger the mandatory reporting duty. If you have concerns that a girl may be at risk of FGM — for example, she is being taken abroad during school holidays, or family members have expressed intentions — this is a child protection matter that must be referred to children's services (MASH) and the police, but under the general safeguarding framework, not the mandatory reporting duty.

The HM Government Multi-Agency Statutory Guidance on FGM (2020) is clear on this distinction: the mandatory duty applies only where FGM has already been carried out on a girl under 18.^[2]

Who Must Report: The Role of Teachers

In schools, the mandatory reporting duty applies to all teachers. This includes:

• Qualified teachers with Qualified Teacher Status (QTS)
• Supply and agency teachers working in the school
• Teachers in further education colleges
• Head teachers and deputy head teachers

The duty applies to the individual teacher, not to the school as an institution. This means a teacher cannot discharge their legal obligation by simply telling the DSL and assuming the DSL will report. The duty sits with the teacher personally.

However, in practice, the school's reporting will typically be coordinated through the DSL, and where a teacher informs the DSL and the DSL makes the police report on the same day, the teacher's duty is treated as discharged. Schools should have a clear protocol in place so this happens promptly.

Teaching Assistants and Other Staff

The mandatory reporting duty does not currently extend to teaching assistants, learning support staff, or other non-teaching school staff. However, all school staff have a general safeguarding duty, and any concern about FGM must be reported to the DSL immediately regardless of the person's role.

How to Report: Practical Steps for DSLs

1. Listen and record. If a girl discloses, follow standard disclosure protocol: listen carefully, do not promise secrecy, use open questions, record verbatim as soon as possible. Do not interrogate or investigate.
2. Inform the DSL immediately. The teacher must inform the DSL on the same day. The DSL should be available or have a deputy.
3. Report to the police. Call 101 (non-emergency police line) to report. If the girl is in immediate danger, call 999. The police have trained officers for FGM referrals. You do not need to have forensic certainty — reporting on reasonable grounds is sufficient.
4. Refer to children's services (MASH). A police report under the mandatory duty does not replace a referral to children's services. Make both. The MASH referral triggers a child protection assessment; the police report initiates the criminal investigation.
5. Inform the girl. Where safe to do so, tell the girl what action you are taking. Use trauma-informed language. Do not imply she or her family are criminals, but be honest that you have a legal obligation to report.
6. Record everything. Document the disclosure or observed signs, the date and time, who was present, what actions were taken, and when. Keep records securely.
7. Do not contact the family. Do not alert the girl's parents or carers that a report has been made. This could increase risk to the girl, compromise a police investigation, or prompt the family to remove her from the UK.

KCSIE 2025 and FGM

Keeping Children Safe in Education 2025 (Part 1 and Annex B) explicitly lists FGM as a specific safeguarding issue requiring particular attention from schools and DSLs.^[3] KCSIE 2025 requires DSLs to:

• Understand the indicators that a girl may be at risk of FGM
• Know how to activate the mandatory reporting duty
• Be aware of the FGM Protection Order — a civil order that can be applied for through the family courts to protect a girl at risk
• Know the referral pathways for both confirmed and suspected cases

KCSIE 2025 also reminds schools that a girl asking for time off before school holidays to visit family in countries where FGM is practised, or withdrawing from swimming or PE, or showing signs of distress around toilet use, are all indicators that should prompt a conversation with the DSL.

Indicators a Girl May Be at Risk (Future Risk — Refer to MASH)

The following are indicators that a girl may be at risk of FGM. These do not trigger the mandatory reporting duty (which applies only to confirmed cases) but must be referred to children's services as a child protection concern:

• A family member has undergone FGM
• The girl is from a community where FGM is known to be practised
• The girl mentions a forthcoming "special ceremony" or "holiday"
• The family requests an extended period of absence from school, particularly before or during school holidays, to travel to a country where FGM is practised
• A girl talks about becoming a "real woman" or references cultural rites of passage
• An older sibling has already undergone FGM

Where there is an immediate risk that FGM will be carried out — for example, the family intends to take the girl abroad within days — contact the police immediately (999 or 101). An FGM Protection Order can be applied for as an emergency measure through the family courts to prevent removal from the UK.

Five Myths About the FGM Mandatory Reporting Duty

Frequently Asked Questions

Who to Contact

Sources: [1] NHS England (2023). Female Genital Mutilation (FGM) Enhanced Dataset 2022–23. digital.nhs.uk. [2] HM Government (2020, updated 2022). Multi-Agency Statutory Guidance on Female Genital Mutilation. gov.uk. [3] Department for Education (2025). Keeping Children Safe in Education 2025. gov.uk. [4] Serious Crime Act 2015, s.5B. legislation.gov.uk. [5] Female Genital Mutilation Act 2003 (as amended). legislation.gov.uk. Last reviewed: May 2026.