The Archbishops' Council of the Church of England must rapidly accelerate the delivery of safeguarding improvements and close gaps in its approach to handling complaints, the charity regulator has warned.
The Charity Commission has set an expectation that the Archbishops' Council should implement independent safeguarding structures as endorsed by the Church's General Synod in February 2025 within 18 months from now - a year sooner than current plans indicate - and in the meantime, put robust interim measures in place to keep people safe.
The expectation is part of a Regulatory Action Plan issued to the Archbishops' Council, a registered charity whose objects are to co-ordinate, promote, aid and further the work and mission of the Church of England. It follows the Commission engaging with the charity over whether its trustees are taking sufficient steps to address the safeguarding concerns and implement recommended changes raised in a number of safeguarding reviews.
Background
The Commission's engagement with the Archbishops' Council began towards the end of 2024, following the publication of an 'Independent Learning Lessons Review' into the case of John Smyth (the "Makin Review"). This followed other independent reviews in recent years, including the report by Sarah Wilkinson into the Church's Independent Safeguarding Board, and the 'Future of Church Safeguarding' report by Professor Alexis Jay.
Public debate about the Church's approach to safeguarding following publication of the Makin Review - and the Archbishop of Canterbury's resignation over the issue - exacerbated regulatory concerns that progress towards safeguarding improvements identified in the various independent reports was not happening with sufficient pace.
The regulatory compliance case was informed by information provided by bishops and Diocesan Boards of Finance, as well as the Archbishops' Council, at the Commission's request.
While the Commission does not investigate individual allegations of abuse, it does have a responsibility to assess concerns about the extent to which trustees are taking necessary action and ensuring their charity has appropriate safeguarding policies and procedures in place. The Church of England's National Safeguarding Team is a department of the Archbishops' Council and develops proposals for safeguarding guidance, processes and procedures for consideration by the General Synod which the trustees of other Church charities are required to follow.
Findings
In summary, the Commission has found that:
- there is insufficient urgency and pace in implementing responses to past safeguarding reviews, and the current approach to doing so is fragmented and overly complex. For example, the Council's current timescale of 2028 to pass the necessary legislation to implement independent safeguarding is too slow, representing a four year gap since the publication of the Jay Review
- currently the Church does not treat allegations of abuse from an adult not assessed to be "vulnerable" as a safeguarding allegation. The Commission's guidance is clear that trustees must take reasonable steps to protect from harm all people who come into contact with their charity
Conclusions
The Commission found no evidence of mismanagement or misconduct by the trustees of the Archbishops' Council, and recognises that the charity has made progress and delivered some improvements to the Church's safeguarding in recent years. However, the Commission has made it clear that it expects the Archbishops' Council to take all steps within its powers to implement outstanding safeguarding reforms at a much faster pace.
Where legislative changes will not address safeguarding risks quickly, the charity's trustees should facilitate interim arrangements sufficient to address identified safeguarding risks until the legislative changes are in place. These should reflect the Commission's guidance to trustees as well as Church policy and procedure.
Next steps
The Commission has issued a Regulatory Action Plan setting out steps the trustees need to take to address the Commission's concerns. These include closing the gap on how allegations made by a non-vulnerable adult should be handled in different circumstances, and quicker delivery of the new structures for independent safeguarding which the General Synod "endorsed as the way forward in the short term" in February 2025.
The Commission notes the recent appointment of Dame Christine Ryan as executive chair of the Church's Safeguarding Structures Programme Board to lead work on the structural changes agreed by the Synod.
The Commission now expects the Archbishops' Council to identify any safeguarding risks that may require interim non-legislative measures to keep people safe and to put suitable measures in place. Reflecting this approach, the Archbishops' Council has told the Commission it plans to establish an interim independent scrutiny body for Church safeguarding ahead of legislation.
The Commission understands the risks associated with acting in undue haste, and notes that the Archbishops' Council's trustees need to consider how to plan for future engagement with victims and survivors in a meaningful, sensitive and structured way so that it supports the timely delivery of change needed to keep people safe in the future.
The regulator is monitoring the Archbishops' Council's progress against the Regulatory Action Plan. Should it receive evidence that raises new regulatory concerns, it will assess this in line with its usual process.
Charity Commission Chief Executive, David Holdsworth, said:
It's time for the Archbishops' Council and the Church of England to move from review to reform, and from debate to delivery.
Everyone recognises that improving safeguarding is an ongoing journey, but in the Archbishops' Council's case the progress on that journey must be made in bigger, bolder steps, informed by the experience of victims and survivors.
The Commission will monitor the charity's progress against our Regulatory Action Plan, and reserve all regulatory options for the future if sufficient progress is not made at pace.
