By Styliana Pasiardi, Policy & Campaigns Manager & Timothy Haynes Principal Positive Behaviour Support Practitioner
In April 2025, the Together Trust’s campaigns team supported our Positive Behaviour Support (PBS) team to respond to the Department for Education’s consultation on the Revised Use of Reasonable Force and Other Restrictive Interventions Guidance. The government published its response in December 2025.
The new guidance, introduces a new legal duty for schools to record and report any incident involving restrictive interventions to parents or carers. This new guidance will come into effect on 1 April 2026. Until then, nothing changes – the current guidance remains in place and continues to apply.
This blog explores how closely the government’s updated plans align with the changes we called for, and highlights where key gaps remain.
Strengthened areas and how they have improved
Several areas have been bolstered to improve pupil safety and staff accountability:
- Seclusion Regulation: The 2026 guidance introduces a formal definition and strict rules for seclusion, which was not detailed in 2013. It specifies that seclusion ‘‘should only be used as a safety measure’’ and never as a ‘‘disciplinary response’’.
- Data Interrogation: The 2026 version mandates that governing bodies ‘‘regularly review and interrogate data’’ to identify patterns, disproportionate use against pupils with protected characteristics, and areas for staff development. Governing bodies are encouraged to use recorded data to ‘‘identify areas of learning and development for school staff’’, supporting specific departments or teachers to improve their practice.
- Post-Incident Support: There is a new emphasis on debriefing. Schools should now ‘‘hold a follow-up conversation(s) to facilitate reflection, learning and to support pupil and staff wellbeing’’ to repair relationships after an incident.
- Focus on Prevention: The newer guidance prioritises minimising the need for intervention through ‘‘early support, prevention and de-escalation strategies’’.
This includes training in ‘‘effective communication strategies’’, such as using an appropriate tone of voice and empathy to aid de-escalation.
“I welcome these additions to the updated guidance, which strongly reflect and reinforce the practice already embedded within our setting. The clear definition and tightened regulation around seclusion, particularly the emphasis that it is a safety measure and never a disciplinary response, aligns fully with our values and existing procedures.
The strengthened focus on data interrogation is also a positive and necessary step. Regularly reviewing and analysing data to identify patterns, address disproportionality, and inform targeted staff development mirrors our ongoing commitment to reflective, evidence-informed practice.
I am especially encouraged by the increased emphasis on post-incident support and debriefing. Structured follow-up conversations that promote reflection, learning, and wellbeing are essential for repairing relationships and supporting both pupils and staff, and this has long been a cornerstone of our approach.
Finally, the guidance’s prioritisation of prevention through early support, de-escalation, and effective communication strategies is particularly welcome. This proactive focus reinforces our belief that the most effective intervention is one that reduces the likelihood of incidents occurring in the first place. Overall, these additions provide clarity and consistency while affirming practices we already value and uphold.“
– Timothy Haynes, Principal PBS Practitioner
Our asks and what’s still missing
Seclusion
What we asked
- Near‑ban except in exceptional, life‑threatening circumstances (e.g., weapon use), plus clear room standards, supervision, time limits, recording, reflective practice, and a distinction between emergency and planned use.
What’s missing
- No move to ban seclusion, no emergency vs planned distinction, limited acknowledgment of emotional/psychological harm, and vague room/time/staffing expectations.
Definitions of restrictive interventions
What we asked
- Broader definitions to include psychological, cultural, environmental restraint, blanket rules, and surveillance; embed safeguards: necessity, least-restrictive, proportional.
What changed
- Definition expanded to include physical and non‑physical actions; clearer examples may come in phase two.
What’s missing
- The most concerning non‑physical restrictions remain unnamed, and core safeguards are not embedded in definitions – risking restrictive environments going unnoticed.
Who can use reasonable force & training standards
What we asked
- Mandatory, nationally accredited training (e.g., BILD/Restraint Reduction Network certified programmes), with clear content/quality standards – covering proactive strategies, de‑escalation, post‑incident support.
What changed
- Government trusts school leaders to make decisions on training based on the individual contexts and needs of their school. Training must equip staff with the skills to judge appropriateness to use restrictive interventions and help them assess whether their response is reasonably under pressure. Schools are advised to carry out risk assessments to ensure that staff who regularly work with pupils where force may be required can do so as safely as possible.
However, there are still some gaps which may make people vulnerable due to it’s lack of alignment with RRN (Restraint Reduction Network) Training Standards, for example:
- Lack of Mandatory Certification: The guidance does not specify a required accreditation or ‘‘brand’’ of training. It states school leaders should choose training that ‘‘reflects the principles’’ of the guidance, but does not mandate a specific national standard.
- Frequency of Refresher Training: While the 2013 guidance suggested headteachers ‘‘consider whether members of staff require any additional training’’, the 2026 guidance does not set a statutory timeframe (e.g., annually) for how often staff must refresh their skills.
- Specifics of ‘‘Adequate’’ Training: The guidance requires staff to be ‘‘adequately trained’’, but does not define what constitutes ‘‘adequate’’ in terms of hours, practical assessment, or theoretical content.
- Physical Technique Safety: While the guidance lists ‘‘unacceptable uses of force’’ (such as those affecting airways), it does not provide a list of ‘‘approved’’ techniques, leaving the technical safety of specific holds to the training provider and the school’s risk assessment.
- Heavy reliance on professional judgement; “necessary” force remains open to interpretation in the heat of a crisis.
Follow‑up and support after incidents
What we asked
- Embed duty of candour, and restorative/reflective organisational duties; clarify “appropriate physical contact” to avoid subjectivity.
What’s missing
- Duty of candour is absent; restorative/reflective approaches not embedded; no national standard for good post‑incident support. The 2026 guidance defines a ‘‘significant incident’’ as force that ‘‘goes beyond appropriate physical contact’’. This threshold may still vary between different school settings or individual staff members.
School policies on reasonable force/restrictive interventions
What we asked
- Policies that go beyond de‑escalation to address functions of behaviour, reduce triggers, create predictability, and build skills; multi‑disciplinary input; distinction between known vs novel behaviours; co‑production with pupils/families.
What changed
- Policies should cover whole‑school measures, individualised plans, and reasonable adjustments; examples include removing distressing stimuli, adjusting tone, offering calming space, redirecting attention; clearer terminology and acknowledgment of co‑production.
What’s missing
- Multi‑disciplinary involvement not required; co-production encouraged, not expected.
Human Rights Act & Equality Act duties
What we asked
- Shift from justifying restraint to preventing it; regulated training; trauma‑aware practice; consistent terminology (avoid euphemisms like “supportive holding”).
What changed
- Guidance reiterates restraint should be avoided where possible, decisions must consider vulnerabilities, and national training standards may be explored in phase two.
What’s missing
- Training still not mandatory, trauma‑informed practice not embedded, terminology not standardised.
Non‑force restrictive interventions
What we asked
- Tighten justifications; thresholds for property damage, and highlighted risks of phrases like ‘‘good order and discipline’’ being used as a loophole.
What’s missing
- ‘‘Good order and discipline’’ remains broad and open to over‑use. While the guidance lists ‘‘unacceptable uses of force’’ (such as those affecting airways), it does not provide a list of ‘‘approved’’ techniques, leaving the technical safety of specific holds to the training provider and the school’s risk assessment.
Closing thoughts
“The new duty to record and report incidents is welcome, and the shift in training focus towards de‑escalation and risk management is positive. However, much of the revised guidance remains non‑statutory, driving variation in practice.”
– Styliana Pasiardi, Policy and Campaigns Manager
“Ultimately, how schools interpret and respond to these ambiguities will depend on the quality of training they receive. It’s encouraging that the 2026 guidance moves beyond ‘how to restrain’ towards prevention, collaboration and de‑escalation – but consistency and standards are crucial.”
– Timothy Haynes, Principal PBS Practitioner
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