We have been asked repeatedly over the last few weeks to review school policies against the new 2026 Department for Education guidance on restrictive interventions, reasonable force, restraint and seclusion.
The pattern is now clear.
Most schools are not starting from nothing. They already have behaviour policies, positive handling statements, incident forms, CPOMS categories, parent letters, risk assessments and behaviour support plans. The problem is that many of these systems were built around the older “reasonable force” guidance, where recording and reporting expectations were often treated as good practice, local policy, or safeguarding common sense.
The 2026 position is sharper.
Parts of the framework now carry statutory recording and reporting duties, particularly around significant use of force, seclusion and restraint. Schools need to be able to demonstrate that they are not only using restrictive interventions lawfully, but also recording them properly, informing parents promptly, reviewing patterns and using the data to reduce future incidents.
That is a meaningful shift.
It changes the question from: “Do we have a positive handling policy?” to something more operational:
Can your school show, from the record, that each restrictive intervention was necessary, proportionate, welfare-informed, communicated properly and reviewed for learning?
That is the test we have been applying in our client policy reviews.
1. Definitions matter more than they used to
The first issue we keep finding is definitional drift.
The 2026 guidance uses “restrictive intervention” as a wider umbrella term: actions that prevent, restrict or subdue movement. Inside that sit more specific concepts such as reasonable force, restraint and seclusion. Reasonable force is not just a synonym for “physical intervention”; it is the legal test applied to whether force was necessary and proportionate.
That distinction matters because a school policy that only talks about “positive handling” may miss important non-contact restrictive practices.
For example, seclusion may involve no direct physical holding at all. A pupil may be prevented from leaving a space by physical obstruction, locked or controlled access, or even by the belief that they will be punished if they leave. Likewise, “restraint without direct physical contact” may include restricting movement through other means, such as removing or withholding an aid that a pupil normally uses to move independently.
In our reviews, we have been advising clients to make the definitions explicit and practical. Staff do not need a law lecture during a crisis, but they do need shared language.
A useful working clarification is this:
“Non-force” is often better understood by staff as “non-physical restraint” — not “not important”, and certainly not “not reportable”.
2. No-contact policies are still the wrong answer
Some schools understandably react to new guidance by wanting to reduce risk through avoidance: “Should we just have a no-contact policy?”
The answer remains no.
The 2026 guidance recognises that appropriate physical contact is part of safe school life. First aid, guiding, comforting, preventing a pupil running into danger, or supporting a dysregulated child may all involve physical contact. A blanket no-contact policy can leave staff confused, hesitant and unsafe — and can leave pupils less protected.
The better approach is not “no contact”.
It is lawful, proportionate, role-specific contact, supported by training and policy.
That means staff need to know the difference between ordinary appropriate contact, restrictive intervention, restraint, seclusion and significant use of force. They also need to know what must be recorded, what must be reported, and when safeguarding exceptions apply.
3. The central decision test: necessity, proportionality and welfare
The most useful practical test for staff remains simple:
- Necessity — Was intervention needed to prevent a greater harm?
- Proportionality — Was the least restrictive option used for the shortest time?
- Welfare — Were the pupil’s age, stage, SEND, trauma history, medical needs, communication needs and dignity considered?
This is where policy and training must meet.
It is not enough for a policy to say “force must be reasonable”. Staff need to practise applying that judgement under pressure. A lunchtime supervisor, SEN teaching assistant, cover teacher and member of SLT may all face different risk scenarios. Their training should reflect the actual flashpoints in the school, not a generic list of holds or techniques.
This is one of the strongest points in the guidance for us: training should be adequate, safe, lawful, preventative, based on the school’s individual context and aligned with the principles of the guidance.
That is a very useful standard for school leaders selecting training providers.
4. Recording is no longer a “we’ll do it when we can” task
A major theme in our advice to clients has been same-day recording.
For every significant use of force, schools should record the key facts promptly, preferably the same day: who was involved, when and where it happened, what led up to it, why force was necessary, what type and degree of force was used, how long it lasted, whether anyone was injured, and what post-incident support followed.
This record is not only there in case someone complains.
It is the school’s evidence of decision-making.
If the record does not explain necessity and proportionality, the school may later struggle to show why the intervention was lawful. If the record does not capture de-escalation attempts, the school may struggle to show that force was a last resort. If the record does not mention welfare factors, SEND needs or reasonable adjustments, the school may struggle to show that the pupil’s individual circumstances were properly considered.
The practical advice here is straightforward: do not rely on long free-text narratives alone.
Schools should build structured incident forms — whether in CPOMS, another safeguarding platform, or an internal system — that prompt staff to record the required fields every time.
5. Parents must usually be told promptly — including some “non-force” incidents
This has been one of the most common client questions.
Do “non-force” incidents need to be shared with parents, or only recorded internally?
Our advice has been clear: where the incident is seclusion or non-force restraint within the scope of the regulations, it must not simply sit in an internal log. Parents should be informed promptly, ideally the same day, subject to limited safeguarding exceptions.
This applies even where the intervention was already anticipated in a behaviour support plan.
That point matters in special schools and complex needs settings, where staff may be responding repeatedly to foreseeable distress or risk. A behaviour support plan may explain what staff are expected to do, but it does not remove the duty to record and report each relevant incident.
There are difficult operational questions here. For high-frequency, similar incidents, a full blank-form write-up every time may become unrealistic. In those cases, we have been exploring carefully designed “tally-style” recording systems: pre-agreed, pupil-specific documentation where repeated interventions of the same type and character are logged efficiently without losing the statutory record.
The principle is not to reduce accountability.
The principle is to make accountability workable.
6. Seclusion needs particular attention
Seclusion is not “time out”. It is not a sanction. It is a restrictive intervention used as a safety measure, where a pupil is contained away from others and prevented from leaving.
The 2026 guidance requires schools to treat seclusion seriously: it must be supervised, safe, necessary, ended as soon as risk reduces, recorded and reported.
In policy reviews, we are advising schools to remove vague language such as “withdrawal room”, “quiet room” or “reflection room” where the practice may in reality amount to seclusion. If a pupil cannot freely leave, or believes they cannot freely leave, school leaders need to look closely at whether the seclusion rules apply.
This is not semantics.
It is safeguarding, liberty and accountability.
7. Governance is not a passive role
The final point may be the most important.
The guidance expects governing bodies and proprietors to ensure recording and reporting procedures are followed and to interrogate the data. That includes identifying training needs, repeated patterns, triggers, pupil support measures and possible disproportionality affecting pupils with SEND or other vulnerabilities.
So governors should not only ask, “Do we have a policy?”
They should ask:
- How many restrictive interventions occurred this term?
- Were parents informed promptly?
- Were incidents concentrated around particular pupils, places, times or transitions?
- Were behaviour support plans reviewed afterwards?
- Are pupils with SEND over-represented?
- What training need does the data reveal?
- What has changed because of what we learned?
This is where the guidance becomes more than compliance. Used properly, the data should help schools reduce the need for restrictive interventions over time.
What should school leaders do now?
From our reviews so far, the immediate priorities are:
- Update policy definitions and legal references.
- Clarify the difference between appropriate contact, force, restraint and seclusion.
- Build structured recording fields into your incident system.
- Make same-day parent reporting workable.
- Review behaviour support plans after incidents.
- Train staff in necessity, proportionality, welfare and de-escalation — not just physical techniques.
- Give governors a termly data report they can actually interrogate.[5][8]
A final practitioner point.
Schools are already carrying heavy workloads. SLT, SENCOs, pastoral staff and classroom teams are not short of guidance documents. What they need is a usable operating system: clear policy, trained staff, practical forms, sensible reporting workflows and a governance rhythm that spots risk before it becomes a serious incident.
I hope the above helps. If your school is reviewing its restrictive intervention, reasonable force, restraint or seclusion policy this year, the question is not whether the policy “mentions” the 2026 guidance.
The question is whether your system would still make sense at 2:15pm on a wet Wednesday, when a pupil is distressed, staff are under pressure, parents will need to be informed, and the record will later need to explain exactly why the adults did what they did.