by Styliana Pasiardi, Charity Policy and Campaigns Manager
About the consultation
In July 2026, Ofsted launched a consultation on proposed changes to two inspection frameworks:
- Inspecting local authority children’s services (ILACS) and
- The social care common inspection framework (SCCIF) for providers.
The proposals include:
- Removing the ‘overall experiences and progress’ judgement for the SCCIF
- Introducing a 5-grade scale and report cards for both frameworks.
- Adding a new evaluation area: children’s enduring relationships.
- Making the use of unregistered children homes an evaluation area limiting criterion in ILACS.
- Including additional contextual information in published reports.
The consultation closed on 28 September 2026.
No immediate changes
The proposed changes to the ILACS and SCCIF frameworks have not yet been introduced.
Ofsted plans to:
- Begin introducing SCCIF changes between spring 2027 and spring 2028
- Publish its consultation response and revised frameworks in early 2027
Our response in a nutshell
Together Trust broadly supports Ofsted’s proposed changes, particularly the stronger focus on stability, enduring relationships and reducing reliance on unregistered provision.
However, the goal should not be to manage unregistered placements. The goal should be to ensure every child can access a safe, high-quality, regulated placement that meets their needs.
Inspections should assess how effectively leaders:
- Develop long-term solutions that reduce reliance on unregistered placements
- Understand local need
- Plan for sufficient services and placements
- Secure appropriate provision
- Keep children safe
Increasing use of unregistered provision
Local authorities have an important role in planning and overseeing children’s care. However, the growing use of unregistered provision reflects wider pressures across the system.
These pressures include:
- A shortage of regulated placements
- Workforce challenges
- Long-term underinvestment in services
As a result, local authorities are often making decisions based on what is available, rather than what best meets a child’s needs.
Addressing these challenges will require capital investment, action to strengthen the workforce, and a long-term strategy to ensure there are enough suitable placements.
Avoiding unintended consequences
As Ofsted reviews and develops its inspection frameworks, it is important that providers are not discouraged from supporting children with the most complex needs.
Many children who experience unregistered provision have faced significant instability. They may need time to settle, build trusting relationships and adjust to a regulated setting.
Inspection should recognise these realities and avoid creating disincentives for providers who support children requiring intensive support, a period of adjustment or who present with challenging behaviours.
Inspection should recognise these realities. It should not create incentives for providers to avoid children who need intensive support, a period of adjustment or who may display challenging behaviour.
Instead, judgements should focus on whether:
- Children’s needs are being met
- Children experience stability
- Positing and lasting relationships are being supported
Inspection must also recognise effective partnership working between providers and local authorities to secure suitable regulated placements for children.
Our recommendations to Ofsted
We recommend that Ofsted:
- Track and report on unmet need, not just the use of unregistered provision. This should include delays in securing placements, distance from home and gaps between assessed need and available provision.
- Require greater accountability where unregistered placements are used. Records should show why the placement was made, how the child is being safeguarded, what steps are being taken to secure regulated provision, how long the placement is expected to last and how it will be monitored.
- Strengthen oversight of unregistered provision and wider sufficiency pressures through improved national data collection, reporting and information-sharing.
- Continue reviewing registration processes to ensure they are proportionate and efficient, enabling high-quality provision to be registered without unnecessary delay while maintaining robust quality and safeguarding standards.
- Publish data on registration timelines, priority applications and identified sufficiency gaps to support transparency and inform local and national sufficiency planning.
- Recognise and highlight positive practice where providers successfully support children to move from unregistered into regulated care.
- Provide clear guidance on how transitions from unregistered to regulated care should be evaluated.
- Monitor whether inspection outcomes inadvertently discourage providers from accepting children with the most complex needs.
Unregistered placements should never become normalised. The success of these reforms should be measured NOT by how effectively systems manage unregistered provision, but by whether they reduce and ultimately eliminate reliance on it through sufficient, high-quality regulated care that meets children’s needs, promotes stability and supports enduring relationships
Styliana Pasiardi, Policy and Campaigns Manager
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