Section 175/157 Safeguarding Audits

These are statutory duties placed on schools and colleges in England, and they sit in the Education Act 2002.

Section 175 applies to maintained schools, local authorities, and further education institutions. It requires them to make arrangements to ensure that their functions are exercised with a view to safeguarding and promoting the welfare of children.

Section 157 places an equivalent duty on the proprietors of independent schools, which includes academies and free schools. In practice that duty is given detail through the independent school standards, which set out what a proprietor must have in place.

The wording differs, the expectation does not. Both create a duty to have arrangements in place, and the word arrangements is doing a great deal of work. A policy is not an arrangement. An arrangement is a policy that people know about, follow, and can evidence.

It is worth knowing that Keeping Children Safe in Education is itself issued under Section 175 of the Education Act 2002. When a school asks what its Section 175 duty requires in practice, KCSIE is a large part of the answer.

This matters right now, and any audit carried out this term should account for it.

The Department for Education published Keeping Children Safe in Education 2026 on 7 July 2026. It comes into force on 1 September 2026 and replaces the 2025 version, which remains in force until then. The changes are among the most extensive in recent years.

Areas to be aware of include changes reflecting the Children’s Wellbeing and Schools Act and Working Together to Safeguard Children 2026, new content relating to violence against women and girls, an expectation that child protection policies set out measures to tackle misogyny, and structural changes to the annexes.

Online safety has been strengthened significantly. Schools and colleges must now ensure the effectiveness of filtering and monitoring systems is reviewed at least once every academic year, and the guidance is explicit that this review should be undertaken by the senior leadership team member responsible for filtering and monitoring, supported by the designated safeguarding lead and IT. Cyber security standards are referenced, and artificial intelligence features more prominently.

The direction is clear. Safeguarding accountability is being pushed upward, toward named leaders and governing boards, and away from being something delegated to technical teams or absorbed quietly by a DSL. Our audits are framed against the 2026 guidance, so you are prepared rather than catching up.

An audit is only as good as its evidence, so we do not rely on a document review alone.

We examine records and files directly, including a sample of safeguarding case records and recruitment files, rather than accepting a summary. We speak to the designated safeguarding lead, senior leaders, and the governor or trustee with safeguarding responsibility. We speak to a range of staff, including those who do not attend safeguarding meetings, because what teaching assistants and site staff say tells you a great deal about culture. Where you agree, we speak to pupils.

Then we triangulate. A strong policy, a confident DSL, and staff who cannot say what they would do if a child disclosed something adds up to a finding, not a reassurance.

We work sensitively. Safeguarding audits touch on real children and real distress, and we handle records and conversations with the care that deserves. If we identify something requiring immediate action, we tell you at the time rather than saving it for the report.

Trusts face a particular difficulty. The board carries the Section 157 duty across every school, but the practice sits in each of them, and it is rarely consistent.

We audit across trusts using the same framework in every school, which produces something a single-school audit cannot: a comparison. Trust boards see where practice is strong enough to spread, where it is weaker than the reporting suggested, and where a shared approach would raise the floor.

We also review the trust’s own arrangements, including central safeguarding leadership, the scheme of delegation as it applies to safeguarding, how local governing bodies exercise oversight, and how assurance reaches the board.

Local authorities carry their own Section 175 duty alongside duties under Section 11 of the Children Act 2004, and they also need assurance about the settings they oversee and commission.

We support authorities with audits of their own arrangements, independent verification of school and college returns, thematic audits across a group of settings, audits of commissioned alternative provision, and support where a setting has been identified as a concern. We can also provide an independent view where an authority needs one that is visibly separate from its own school improvement function.

These settings carry higher risk and, very often, smaller teams to manage it.

In alternative provision, we look closely at exploitation and contextual risk, information sharing with commissioning schools and local authorities, attendance and children missing education, and the registration position of the provision itself. For commissioners, we can audit provision before or during a placement arrangement.

In independent special schools, the Section 157 duty sits alongside the independent school standards, and a safeguarding finding rarely stays contained. We audit against both, and we understand what unmet standards, action plans, and progress monitoring mean for a proprietor.

In special schools, we pay particular attention to pupils who communicate differently, intimate care, use of reasonable force, and the specific difficulty that pupils who cannot easily report harm are more vulnerable to it.

We work only in education, and safeguarding is core to what we do rather than an add-on to a general consultancy offer.

Our safeguarding consultants have been designated safeguarding leads, headteachers, and senior leaders in mainstream, special, independent, and alternative provision settings. Several have inspected schools. Several have worked on the local authority side, on the receiving end of referrals rather than the making of them. That combination matters, because a good audit needs someone who has held the responsibility, someone who knows what an inspector looks for, and someone who understands why a referral was not accepted.

We have supported settings through the difficult moments too: allegations against staff, historic disclosures, a case that went wrong, an inspection that found safeguarding not met. We are not naive about what these situations feel like from the inside, and we do not treat them as an opportunity to be impressive at a client’s expense.

Yes. Academies and free schools are independent schools in law, so their proprietors fall under Section 157 rather than Section 175. The practical expectations, set out through the independent school standards and Keeping Children Safe in Education, are closely aligned with those on maintained schools.

The duty to have arrangements is statutory. There is no single prescribed audit format, though many local authorities require an annual Section 175/157 return from their schools. An independent audit is not itself mandatory, but it is the most reliable way to evidence that the duty is being met.

Annual self-assessment is standard practice, and we would suggest an independent audit every two to three years, or sooner after a change of DSL or headteacher, a serious incident, a change of setting status, or a significant change in statutory guidance. The KCSIE 2026 changes make this year a sensible point for many settings.

A single school audit is typically one day on site with document review before and the report following. Larger settings, trusts, and authorities take longer. We scope it so that the demand on your DSL, who is usually the person carrying the work, stays proportionate.

Your policies, training records, single central record, a sample of safeguarding records, governing board minutes, and your most recent self-assessment or return. We send a clear list in advance and we do not ask for anything we will not use.

Yes, with appropriate agreements in place. Case records are where the quality of practice actually shows, and reviewing a sample is the only reliable way to test whether concerns are followed through rather than simply logged. We handle them with care and report on patterns rather than individuals.

We tell you at the time. If a child may be at risk, that conversation happens on the day, not in a report three weeks later. We will support you to take the right action, including where that means a referral, a report to the local authority designated officer, or a notification to a regulator.

Yes, and commissioners increasingly ask for this. We can audit a provision before placements begin or as part of ongoing assurance, covering safeguarding arrangements, staffing checks, registration status, and the information sharing that sits between the commissioner and the provider.

Yes. We audit authorities’ own arrangements, verify returns from their settings, carry out thematic audits across groups of schools, and provide an independent view where an authority wants one that is visibly separate from its own improvement function.

The report belongs to you. We gather staff and pupil views in confidence so that people speak openly, and we report on themes rather than exposing individuals, unless a safeguarding matter requires otherwise.