Changes to Keeping Children Safe in Education 2025 and steps for schools to take

The Department for Education (DfE) has published its revised version of Keeping Children Safe in Education (KCSIE) 2025.

The changes to KCSIE this year are not significant. A summary list of all the changes can be found at Annex F of KCSIE 2025 but in this briefing we focus on the main changes likely to have an impact on your safeguarding policies and procedures.

The small number of updates is interesting given the DfE conducted an extensive “call for evidence” prior to issuing this latest version of KCSIE. This “call” sought views from safeguarding practitioners and educational professionals on the statutory guidance in quite general terms. It is unclear whether the DfE is still reflecting on the responses it received (and more substantive changes could therefore be in the pipeline) or whether this latest iteration of KCSIE incorporates their learnings from that exercise.

The main changes this year are summarised below.  

1. Technology

The DfE has responded to the changing (and increasingly challenging) online environment that children are experiencing and is looking to schools to remain up to date and responsive to these risks.

• Under “Online Safety”, the definition of “content” has been updated. This now specifically includes that “misinformation, disinformation (including fake news) and conspiracy theories” should be viewed as safeguarding harms. Previously, only “fake news” was included as a standalone item. These additions widen the potential harms schools should be alert to.
  
  

  Schools should update their policies to reflect this new wording (including their Safeguarding Policy and any associated online safety policies) and reflect on how staff are educated on these issues and students equipped to spot and protect themselves from them.

• There is now explicit reference to the DfE’s Generative AI: product safety expectations under additional guidance for appropriate filtering and monitoring. The product safety expectations outline the capabilities and features that Generative AI products and systems should meet to be considered safe for users in schools. This is not a new requirement. It is a link to guidance that was issued back in January 2025. This adds to a suite of existing guidance that may be relevant for schools to consider (in discussion with IT staff and service providers) when reviewing the filtering and monitoring software to meet the longstanding KCSIE requirements.
• In summary, the DfE expects that Generative AI products must:
  
  
  • effectively and reliably prevent access to harmful and inappropriate content by users;
  • maintain robust activity logs, either by the Generative AI product itself or additional technology;
  • be secured against malicious use or expose to harm;
  • prioritise transparency and child safety in its design and be operated with accountability; and
  • respect data protection and intellectual property laws.

As we outlined in our briefing when the filtering and monitoring obligations were first introduced, the DSL should take lead responsibility and work in consultation with the school’s IT team on this issue, and assess whether any Generative AI technology deployed by the school meets these standards. Governors should have awareness of the filtering and monitoring software and provisions in place and scrutinise their suitability.

• There is now a link to the DfE’s "plan technology for your school" service to assess whether they match the requirements and to receive personalised recommendations on how to meet them. With the pace of technology constantly evolving, particularly in the Generative AI sphere, this will be a useful tool to ensure the school’s position remains compliant with KCSIE.
  

  The DSL and IT team should familiarise themselves with this information and reflect on (and monitor) whether the school’s provision remains fit for purpose. 

For more on Artificial Intelligence in schools please see Farrer & Co’s briefing here.

2. Additional resources on harmful sexual behaviour

• Reference is made in Annex B to the Centre of Expertise on Child Sexual Abuse’s new resources to assist education professionals to identify and respond to sexual abuse and the Children’s Society and the Home Office’s guidance on Preventing Child Sexual Exploitation.
• Further changes can be found in Part Five of KCSIE concerning child-on-child sexual violence and sexual harassment. A link is provided to The Lucy Faithfull Foundation’s “Shore Space”, a confidential chat service to assist young people who are concerned about their own or someone else’s sexual thoughts or behaviour.
  
  

  The DSL/safeguarding team should consider explicitly referencing these resources in the Safeguarding Policy and/or flagging them to students as a source of confidential early support.

Further guidance, support and resources on responding to harmful sexual behaviour can be found in Farrer & Co’s Addressing child-on-child abuse: a resource for schools and colleges.

3. Further changes on the horizon?

The DfE has flagged that revised guidance on Relationships, Sex and Health Education and Gender Questioning Children will be published over the summer.

Once published, they will “signpost” to the guidance within KCSIE within the relevant sections (at pages 36 and 56 respectively). It is not yet clear whether (beyond referencing the guidance) any further substantive changes will be made, but this does feel likely.

Undoubtedly, the DfE will be reflecting on whether updates are required to these guidance documents following the Supreme Court judgment “For Women Scotland v Scottish Ministers” and the subsequent interim guidance from the Equality and Human Rights Commission (EHRC). The judgment ruled that for the purposes of the Equality Act 2010 the definitions of “woman” and “man” refer to biological sex (for more on the judgment and it implications, please see our previous blog here).

We have supported ISBA with their template Gender Questioning/Transgender Policy for member schools, which we have updated in light of the judgment and interim EHRC guidance.

Schools should reflect on whether their policies and practices align with the Equality and Human Rights Commission guidance and seek advice, as appropriate.

4. Other minor changes

There are a number of other relatively minor changes – listed below:  

• At paragraph 144, schools should now consider “taking appropriate action” to meet the Cyber Security Standards, which were designed to help them improve their resilience against cyber-attacks.
• At paragraphs 169-170, there is additional requirements regarding pupils placed in Alternative Provisions to reflect existing guidance.
  
  In summary, schools maintain responsibility for safeguarding those pupils. Schools should obtain written information from the provider that safeguarding checks on staff have been carried out and confirmation that the provider will inform the school of any arrangements that might put the child at risk. The school should regularly review the alternative provision arrangements, at least every half term and in response to a safeguarding concern.
• At paragraph 177, “working together to improve school attendance” is now specified as statutory guidance.
• At paragraph 199, it is noted the role of Virtual School Heads was extended last September to include responsibility to promote the educational achievement of all children in kinship care.
• At paragraph 205, the removal of “spectrum” and “disorder” (in reference to autism) to align with the SEND Code of Practice.
• In Part 3, references to the Teaching Regulation Agency’s Employer Access Service have been replaced by the DfE’s “Check a teacher’s record”.
• At paragraph 422, the Information Commissioner’s Employment Practices Code is now properly named and linked to.

DSLs should commence their review to ensure safeguarding policies and procedures remain in compliance with KCSIE 2025 (particularly surrounding the changes relating to online safety and the use of Generative AI) and keep a watching brief on any future changes to the September version. 

Many thanks to Alex Evans, current trainee in the team for his help preparing this article.

This publication is a general summary of the law. It should not replace legal advice tailored to your specific circumstances.

© Farrer & Co LLP, July 2025