Regulator’s Ultimatum: Church of England Given 18 Months to Fix Safeguarding Failures
The Unmistakable Warning
The Charity Commission has issued a stark and unequivocal warning to the Archbishops’ Council of the Church of England, demanding it “rapidly accelerate” the pace of its long-promised safeguarding reforms. This public intervention represents far more than a rebuke of a single institution; it is a critical test of governance, accountability, and the ability of one of the UK’s most significant national bodies to reform itself under regulatory pressure. The ultimatum brings into sharp focus the conflict between the Commission’s demand for urgent, meaningful change and a history of slow progress that has eroded trust among survivors and the public. The urgency of this demand is palpable, and for this reason, charity leaders, trustees, and governance experts across the country are watching this case with intense interest, viewing it as a landmark moment in charity regulation and institutional responsibility.
The Regulator’s Ultimatum
The core of the regulator’s action is a formal Regulatory Action Plan that sets a new, non-negotiable timeline. The Charity Commission, as the independent regulator of charities in England and Wales, has mandated that the Archbishops’ Council, a registered charity, must implement independent safeguarding structures within the next 18 months. This deadline is a full year ahead of the Church’s 2028 timeline, a clear signal of the regulator’s profound dissatisfaction with the current pace. The Commission’s findings stated there is “insufficient urgency and pace” in the Church’s approach, which it described as “fragmented and overly complex”. While the new structures are being established, the Council must also put in place “robust interim measures” to ensure people are kept safe.
The Commission’s Core Findings
The Commission’s intervention was rooted in two critical failings. Foremost among them was a dangerous policy gap where the Church does not treat allegations of abuse from an adult not assessed to be “vulnerable” as a safeguarding allegation. This stands in direct opposition to the Commission’s clear and unambiguous guidance, which states that trustees “must take reasonable steps to protect from harm all people who come into contact with their charity”. Compounding this was the regulator’s conclusion that progress on implementing recommendations from past reviews has been unacceptably slow, highlighting the four-year gap since Professor Alexis Jay’s landmark ‘Future of Church Safeguarding’ report as a prime example of this inertia. While the Commission explicitly stated it found no evidence of mismanagement or misconduct by the trustees, the central issue remains the failure to implement reforms with the necessary speed.
A Reckoning Years in the Making
This regulatory action is not a sudden development but the culmination of years of damning reports and sustained public outcry. The Commission’s engagement began in late 2024, prompted by a series of high-profile independent reviews that exposed deep-seated failures, including IICSA, Sarah Wilkinson, and Professor Alexis Jay’s reports, which had already called for fundamental changes such as mandatory reporting and robust redress schemes. However, the catalyst for the current intervention was the explosive Makin Review, an inquiry into the Church’s handling of decades of “prolific, brutal and horrific” abuse committed by the barrister John Smyth. The Commission noted that the public debate following the review—and the subsequent, unprecedented resignation of the Archbishop of Canterbury, Justin Welby—served to “exacerbate regulatory concerns” that progress was not happening at a sufficient pace.
A Spectrum of Reaction
The intense pressure for reform is palpable, with the regulator’s demands set against a backdrop of survivor frustration, official commitments, and deep internal division. Charity Commission Chief Executive, David Holdsworth, articulated the regulator’s impatience, stating it is “time for the Archbishops’ Council and the Church of England to move from review to reform, and from debate to delivery” in “bigger, bolder steps, informed by the experience of victims and survivors.” This call for urgency is echoed forcefully by survivor advocates like Lucy Duckworth of the Act on IICSA campaign group, who warned that ongoing delays are “costing lives” and that the Church has, “to all intents and purposes… completely ignored” the recommendations of the Jay Review.
In response, the Archbishops’ Council stated it “welcomed the commission’s findings” and is “committed to acting on these recommendations as swiftly as possible.” A spokesperson highlighted progress made over the past decade, including “the introduction of independent safeguarding audits, comprehensive safeguarding training for all who work in the church, whether paid or voluntary,” and the development of a Redress Scheme, although it is not yet receiving applications. Yet this commitment is undermined by internal conflict. The Second Church Estates Commissioner expressed “deep disappointment” after the General Synod—the Church’s parliament—opted for a less robust version of independent oversight (“Model 3”) instead of the “wholly independent” structure (“Model 4”) preferred by victims. This decision, they warned, “puts back the progress we need” and demonstrates that the Church has not yet proven “itself capable of marking its own homework in any capacity.”
Implications for the Wider Charity Sector
This high-profile case serves as a powerful cautionary tale for the entire UK charity sector. It is a stark reminder of the fundamental responsibilities of trustees to protect all individuals who come into contact with their organisation, not just those formally defined as ‘vulnerable’. The reputational damage inflicted by a failure to act with urgency is immense, and the Commission’s intervention underscores the critical importance of embedding survivor-led processes into any meaningful governance reform. The regulator’s use of a formal, time-bound Action Plan could well serve as a blueprint for future action against other large, complex charities that are perceived to be failing to address systemic issues. This case clearly signals that while the journey to reform is recognised as complex, indefinite delays will no longer be tolerated.
The Road Ahead
The central challenge is now laid bare: the Charity Commission’s demand for rapid, meaningful change is pitted against the Church of England’s deep-rooted institutional inertia. The coming 18 months will be a crucial test of accountability and the true extent of the Church’s commitment to independent oversight. The entire charity sector will be watching to see whether the Archbishops’ Council can finally take the “bigger, bolder steps” required to move from review to reform. If not, the Commission has made it clear that it will “reserve all regulatory options for the future if sufficient progress is not made at pace,” which could potentially include more severe regulatory measures or even the revocation of the Church’s charitable status, signalling that this may be the last warning the Church receives.
