1. The Annual Cycle and Why 2026 Is Different
Keeping Children Safe in Education is revised every year by the Department for Education. Most annual updates are incremental: a phrase tightened here, a reference updated there, reflecting changes to related legislation or working together arrangements. DSLs who have managed transitions from one edition to the next will recognise the rhythm — read the summary of changes annex, identify what has moved, update policies, brief governors and staff before the September start date.
KCSIE 2026 does not follow that pattern. It is one of the more substantial revisions since the 2022 edition absorbed child-on-child sexual violence from the standalone 2021 guidance. The changes in 2026 sit in four areas: the structure of the document itself, the scope of regulated activity for volunteers, online safety and artificial intelligence, and the broadened definition of child-on-child abuse. Each of these carries genuine operational implications rather than presentational ones.
KCSIE 2026 was published on 7 July 2026 and comes into force on 1 September 2026. Until 31 August 2026, schools and colleges must continue to work to KCSIE 2025 in full. Preparation work — auditing materials, briefing staff, arranging DBS checks — can and should begin now, but no live policy should carry a KCSIE 2026 reference until the guidance is actually in force.
Learning Objective
By the end of this module you will be able to: identify every confirmed substantive change in KCSIE 2026; explain the practical implication of each change for policy, training, induction and recording; apply the changes to a realistic school scenario; and complete a before-1-September readiness checklist for your own setting.
2. Structural Changes: Annexes Relettered and All Staff Read Part One
The most immediately visible change in KCSIE 2026 is structural. Two things have happened simultaneously and it is easy to treat them as minor housekeeping. They are not.
2.1 The old Annex A has been withdrawn
Previous editions of KCSIE included an Annex A that offered a condensed reading of Part One. It was explicitly designed so that staff who do not work directly with children — site managers, catering staff, administrative teams — could read a shorter summary rather than the full Part One text. That annex has been withdrawn entirely in KCSIE 2026. It no longer exists. There is no shortened alternative.
The practical consequence is straightforward but significant: from 1 September 2026, every member of staff in a school or college must read Part One in full. Verify the exact scope of "all staff" in the current KCSIE 2026 text on GOV.UK, as the guidance sets out precisely who this duty covers.
Many schools will have induction packs, reading records and sign-off sheets that divide staff into two groups: those who read Part One and those who read the condensed Annex A summary. Both groups must read Part One in full from September. Any record that shows a member of staff has read only the summary will no longer demonstrate compliance.
2.2 The annexes have been relettered
With the old Annex A gone, the remaining annexes have shifted. What was Annex B (further information) is now Annex A. What was Annex C (the role of the designated safeguarding lead) is now Annex B. A new Annex C has been added, carrying the summary of changes to this edition. The old Annex D (homestay guidance) has moved into Part Three rather than remaining a standalone annex. The old Annex E (supervised and unsupervised regulated activity) has been removed, consistent with the removal of the supervision exemption described in Section 3 below. What was Annex F (summary of changes) becomes the new Annex C.
Any internal document — child protection policy, safer recruitment procedure, staff handbook, governor terms of reference, induction checklist — that cites a KCSIE annex by letter will be pointing to the wrong section once KCSIE 2026 is in force. Always cross-check the exact annex mapping against the official KCSIE 2026 text on GOV.UK before updating live documents.
Policy, training and induction implications
- Update the child protection policy to remove any reference to a condensed reading route and to reflect the new annex lettering.
- Revise the staff induction sign-off form so that it records full Part One reading for every new starter, including support, site and administrative staff.
- Audit annual training records to identify any existing staff whose file shows only the condensed Annex A summary — plan to bring them into the full Part One cycle by September.
- Check governor and trustee documentation, DSL role descriptions, and safer recruitment procedures for references to old annex letters.
- Update training slides and CPD handouts that cite KCSIE by annex letter.
3. The Supervision Exemption for Volunteers Is Removed
This is the change with the largest single operational footprint for many schools. Section 139 of the Crime and Policing Act 2026 removes the supervision exemption from the definition of regulated activity with children. KCSIE 2026 reflects this legislative change and sets 1 September 2026 as the date on which schools must be compliant.
Until 31 August 2026, a volunteer working under close and regular supervision by a person who is in regulated activity could be treated as not being in regulated activity themselves. This meant that some schools permitted volunteers to work in classrooms, run sessions or support trips without an enhanced DBS check that included children's barred list information, on the basis that a member of staff was always present.
From 1 September 2026, that position no longer applies. A volunteer who teaches, trains, instructs, cares for or supervises children, or who works in a specified place such as a school in circumstances that give the opportunity for contact with children, is now in regulated activity regardless of whether someone else is in the room. Refer to the current KCSIE 2026 text on GOV.UK for the precise definition of regulated activity as it applies from September.
The DBS flowchart that many schools used to navigate whether a volunteer needed an enhanced check with barred list information has been deleted from the guidance, because it described a legal position that no longer exists.
Policy, training, induction and recording implications
- Conduct a full audit of every volunteer currently used by your school. For each one, apply the new definition of regulated activity in KCSIE 2026 and determine whether they now require an enhanced DBS check with children's barred list information.
- For volunteers newly in scope, arrange enhanced DBS checks before September. Schools should also have a clear interim risk management plan for any volunteer who is still awaiting a check on 1 September.
- Remove any internal guidance, volunteer induction pack, or risk assessment that references the old supervision exemption or the deleted DBS flowchart.
- Update the safer recruitment policy and procedure to reflect the new definition. Include a section on volunteers that makes clear the supervision exemption no longer applies.
- Brief governors on this change: it carries significant HR, recruitment and potential cost implications, particularly for schools that use a large number of volunteers for reading support, sports coaching or trips.
- Record the volunteer audit in writing, with the decision outcome and rationale for each volunteer documented, so that the process is evidenceable.
4. Online Safety: Nudes and Semi-Nudes, AI-Generated Imagery, and the Annual Filtering Review
4.1 Terminology and scope of nudes and semi-nudes
KCSIE 2026 replaces the terms "indecent image" and "sexting" in the context of peer sharing incidents. The replacement phrase throughout the guidance is "making or sharing nudes or semi-nudes". The definition is wider than many DSLs will expect. It covers photographs, videos and livestreams that were taken by the child themselves; taken or created by another person; digitally altered; or generated entirely by artificial intelligence without any real photograph of the child ever having existed.
That final category — an AI-generated image of a child that is nude or semi-nude — has significant practical implications. A pupil who is the subject of an AI-generated nude image is a victim of image-based abuse even if no camera was ever pointed at them. The instinct in some schools has been to treat AI-generated imagery as less serious because it is "not real". KCSIE 2026 is clear that this instinct is wrong. Verify the exact wording on this in the official KCSIE 2026 text on GOV.UK.
4.2 Consensual and non-consensual sharing
KCSIE 2026 makes an important operational distinction between consensual and non-consensual sharing of nude or semi-nude images. All incidents require a safeguarding response — that is not the point at which the two paths diverge. What differs is the nature and proportionality of the response. A school that logs a "consensual" sharing incident but applies no safeguarding process to it does not meet the KCSIE 2026 standard. Check the relevant section of KCSIE 2026 on GOV.UK for the detailed guidance on how to calibrate the response, including referral thresholds and the role of CSAM considerations.
4.3 Annual filtering and monitoring review
The expectation to review filtering and monitoring at least once every academic year is confirmed in KCSIE 2026. This is not a new principle, but the 2026 edition strengthens the accountability framing: governing bodies are directly accountable for the outcome of the review, not just for ensuring that a review takes place. The review should cover all internet-connected devices accessible to pupils in all relevant locations, including any personal devices that can connect to the school network.
The review must produce a formal written record. Monitoring alerts should be reaching the DSL and being acted upon, not simply being logged. Where AI tools are accessible to pupils, filtering and monitoring must be capable of reaching them. Check the precise expectations set out in the current KCSIE 2026 text on GOV.UK.
Policy, training and recording implications
- Update the online safety policy and child protection policy to use the phrase "nudes and semi-nudes" throughout, and to state explicitly that AI-generated imagery is within scope.
- Brief all staff that a deepfake nude image of a pupil is recorded, responded to and, where appropriate, referred externally in exactly the same way as a photographed image.
- Check that your existing incident recording forms can capture AI-generated imagery as a category.
- Incorporate AI-generated image abuse and image-based misogyny into RSHE and online safety curriculum planning, using PSHE Association–endorsed resources.
- Confirm that pupil reporting routes (for example a worry box, online report form or pastoral referral) make sense to a pupil reporting an image that was never a photograph of them.
- Schedule the annual filtering and monitoring review with a named senior leader as lead, with the DSL and IT lead contributing, and produce a written record that governors can receive formally.
- Where your school uses generative AI tools with pupils, complete a Data Protection Impact Assessment for each tool and confirm filtering and monitoring coverage reaches it.
5. Child-on-Child Abuse: Serious Violence, Misogyny and AI-Generated Imagery
5.1 A broadened definition
KCSIE 2026 expands the categories of behaviour that fall within the child-on-child abuse framework. Serious violence, misogyny and AI-generated imagery are now explicitly named. This matters because it moves these issues from the margins — where some schools have treated them as pastoral or behaviour concerns rather than safeguarding ones — into the centre of the statutory framework.
Misogyny as a safeguarding concern connects to the wider Violence Against Women and Girls agenda, which receives new and expanded content in KCSIE 2026. The guidance draws a direct line between unchallenged misogynistic attitudes, harmful sexual behaviour and, at the most serious end, sexual violence. The implication is that early intervention in peer misogyny — in the corridor, in the classroom, in online spaces — is safeguarding work, not just pastoral work. Check the exact wording of the relevant section of KCSIE 2026 on GOV.UK for the full framing.
5.2 Part Five rewritten
Part Five of KCSIE 2026 has been substantially rewritten. It is now organised around the concept of a progressive continuum, running from harmful sexual behaviour at one end through sexual harassment to sexual violence at the other. The guidance is explicit that behaviour at the lower end of this continuum — including misogynistic comments, sexual jokes, unwanted touching or image sharing — can escalate into more serious abuse if it is not responded to. DSLs should read Part Five of KCSIE 2026 in full: the rewritten text contains both a changed narrative and changed expectations for how schools should respond. Do not assume that familiarity with the 2025 version of Part Five is sufficient.
5.3 Weapons reporting
KCSIE 2026 introduces a confirmed duty relating to weapons-related concerns. Where a member of staff has a concern that a child is carrying, has used or has expressed an intention to use a weapon, they are required to report that concern to the DSL or a deputy DSL. The DSL then assesses the risk and takes appropriate action. This is an internal escalation duty — it does not create a freestanding mandatory external reporting obligation — but it does establish a clear recording and decision-making expectation. Verify the precise requirements against the relevant section of KCSIE 2026 on GOV.UK, and ensure your internal escalation procedure captures this.
Policy, training and recording implications
- Update the child-on-child abuse section of your child protection policy to include serious violence, misogyny and AI-generated imagery within the list of recognised categories.
- Brief staff on the continuum model in Part Five, with clear examples of what early-stage harmful behaviour looks like and how to record and refer it.
- Review curriculum PSHE/RSHE planning to ensure misogyny, consent and image-based abuse are addressed in age-appropriate ways across key stages.
- Ensure your internal escalation procedure for weapons-related concerns is documented and that all staff, including non-teaching staff, know how and to whom to report.
- Review case recording arrangements to ensure that a weapons-related concern triggers a written record, a DSL risk assessment, and a documented decision.
6. Case Study: Ashford Mead Community School — Updating Policy for September
Ashford Mead Community School is an 11–16 secondary with 820 pupils in the East Midlands. The DSL, Sara, has been in post for three years. Her deputy DSL, James, leads on online safety. The school uses a cohort of approximately 40 volunteers across the year: reading support volunteers in Years 7 and 8, sports coaches for the after-school programme, and two parent volunteers who help with the school library one morning a week.
When Sara reads the final KCSIE 2026 guidance in July, she identifies four areas that require immediate action before September:
Challenge 1: Part One reading records
The school's current induction system divides new starters into two tracks. Teaching staff and teaching assistants receive the full KCSIE Part One document as part of induction. Non-teaching staff — including the site team, catering staff and administrative office team — have historically been given the condensed Annex A summary and their records show they have read that. Sara calculates that 14 current staff members have Part One summary records rather than full Part One records.
Sara's first action is to update the induction checklist so there is a single track for all new starters: full Part One, with a dated sign-off. She then plans a briefing for September's training day at which all 14 staff with summary records will read Part One as a group activity, with refreshed sign-off records produced on the day.
Challenge 2: Volunteer DBS audit
Sara and James review the volunteer list against the new definition of regulated activity. The sports coaches — who take full sessions without a member of staff present — were already on enhanced DBS with barred list information. The reading support volunteers present a more complex picture: they have historically been supervised by a classroom teacher, and on that basis some were not processed for an enhanced DBS with barred list check.
Under the new position, supervision by a staff member does not affect whether a volunteer is in regulated activity. Sara identifies eight reading support volunteers who need enhanced DBS with barred list information before September. She contacts the DBS umbrella body used by the MAT and puts eight applications into the pipeline in July. She documents the decision outcome for each volunteer in writing and produces an interim risk management plan confirming that these volunteers will not work unsupervised until their updated checks have been received.
The library volunteers present a closer call. Sara checks the relevant section of KCSIE 2026 on GOV.UK to confirm whether their role meets the definition of regulated activity, and takes advice from the HR lead before deciding. She records the decision and its rationale.
Challenge 3: Online safety policy — AI imagery
James reviews the school's online safety policy and finds that it uses the term "sexting" throughout, does not mention AI-generated imagery and has a section that implies consent affects whether a safeguarding response is required. He drafts a revised policy section that: replaces "sexting" and "indecent image" with "nudes and semi-nudes"; explicitly names AI-generated and deepfake imagery within scope; and states clearly that all incidents require a safeguarding response, with the nature of the response varying according to the circumstances.
James also schedules a 30-minute staff briefing for the September training day, using two short fictional scenarios to illustrate: one where a Year 9 pupil reports receiving an AI-generated nude image of a classmate that was created without any photograph of that classmate; and one where two Year 10 pupils have shared images with each other that were originally consensual. He uses both scenarios to drive home the message that both incidents require the same recording and referral process to begin, with the DSL making the risk-based judgement on escalation.
Challenge 4: Annex references in documentation
Sara uses the school's document management system to search for "Annex B", "Annex C" and "Annex D" across all safeguarding-related documents. She finds 12 documents containing at least one reference. She works through each one methodically, cross-checking the old reference against the confirmed KCSIE 2026 annex mapping in the published guidance on GOV.UK and updating accordingly. The child protection policy, the DSL role description and the safer recruitment procedure take the most time; she completes them in August and schedules governor approval for the first full governing body meeting of the autumn term.
Reflection Questions
- Which of Sara and James's four challenges most closely matches a gap in your own school's current position?
- How would you approach a volunteer who has been working with your school for several years and is now told they need a new DBS check? What communication would you prepare?
- What does your current incident recording form look like for a nude/semi-nude incident? Does it have a field for AI-generated imagery? Does it prompt for the DSL risk assessment and decision?
7. Before 1 September 2026 — DSL Readiness Checklist
Use this checklist to track your school's readiness. Assign a named lead for each item and record the completion date. This checklist is a practical planning aid: always refer to the official KCSIE 2026 text on GOV.UK to confirm the precise requirement before marking any item complete.
Part One reading and annex references
Volunteers and regulated activity
Online safety — nudes, AI and filtering
Child-on-child abuse, misogyny and weapons
Governance and sign-off
8. Module Summary
KCSIE 2026 introduces the most substantial structural and substantive changes since the 2022 edition. The withdrawal of Annex A and the full Part One reading requirement together close a route that many schools have relied on for support staff induction for years. The removal of the volunteer supervision exemption changes the regulated activity landscape in a way that requires every DSL to audit their current volunteer cohort before September rather than carrying existing arrangements forward. The broadened online safety provisions — encompassing AI-generated imagery, the replacement of "sexting" with "nudes and semi-nudes", and the strengthened annual filtering review — respond to a genuine shift in the incidents that schools are actually encountering. And the expansion of child-on-child abuse to include serious violence, misogyny and AI-generated imagery, accompanied by a rewritten Part Five, repositions a range of peer behaviour as safeguarding work rather than pastoral work.
The before-1-September window is the time to audit, plan, commission DBS checks and brief governors. Live policy should not be switched to KCSIE 2026 until September. Every item on the checklist in Section 7 should be verified against the official KCSIE 2026 text on GOV.UK: paragraph numbers, annex references and precise definitions in this module are guides for learning, not authoritative replacements for the statutory text.
Official Source
The authoritative text for all KCSIE 2026 requirements is the Department for Education publication on GOV.UK: Keeping Children Safe in Education 2026, published 7 July 2026, in force from 1 September 2026. Always read the complete document before finalising any policy, induction record or training material.