# What safeguarding checks should a school make when it uses alternative provision?

Source page: https://pupilprotect.co.uk/glossary/ap  
Last updated: 2026-10-20  
Publisher: Pupil Protect (Glacier Labs Ltd)

> When a school places a pupil in alternative provision, it stays responsible for that pupil's safeguarding. KCSIE 2026 says the school should get written confirmation that the provider has made the same safeguarding checks the school would make on its own staff, and that it will be told of changes such as new staff. The school should always know where the child is, and review the placement at least half-termly, ending it if safeguarding concerns aren't resolved.

## The rule

Keeping children safe in education (KCSIE) 2026 says that when a school places a pupil with an alternative provision (AP) provider, it **continues to be responsible for the safeguarding of that pupil**. It should therefore be satisfied that the placement meets the pupil's needs (paragraph 210, repeated at paragraph 405).

The pupils in AP often have complex needs and are at greater risk of harm (paragraph 211). KCSIE also says that time in AP, suspension and exclusion are linked to a higher risk of serious violence (paragraph 52).

The DfE's statutory guidance **Arranging alternative provision** (February 2025) says the same thing: oversight always rests with whoever commissioned the placement, and schools should tell the local authority when they commission one.

## Before the placement

- **Check the provider is safe and suitable for this child.** Do your own due diligence, even if the provider is on a local approved list (KCSIE paragraph 212).
- **Get written confirmation of staff checks.** The provider should confirm in writing that it has carried out the checks you would make on your own staff, such as an enhanced DBS check with a barred list check where the role needs it (paragraphs 211 and 405).
- **Get written confirmation that the provider will tell you of changes** that could put the child at risk, such as new staff, so that you can check them too.
- **Check the provider's safeguarding arrangements.** The voluntary national standards for non-school AP expect a safeguarding policy, a procedure for concerns, staff who know it, a named safeguarding lead with documented training, a single central record and restricted site access (Annex A, standards 1.1 to 1.6).
- **Check whether the provider should be registered.** A provider offering full-time education to five or more pupils of compulsory school age, or to one pupil with an EHC plan or who is looked after, must register as an independent school. Don't place a child if your placement would mean an unregistered provider needs to register.
- **Check the route.** Make sure the journey between home and the provider is safe and manageable, and that there are no safeguarding concerns about the location.
- **Share information before day one.** Send the provider what it needs to keep the child safe, including SEN, medical needs and safeguarding information, in line with data protection law.
- **Agree a written plan with the provider,** the child and parents. It should set out objectives, how long the placement is expected to last, how the provider reports concerns and attendance, and how and when the child will come back.

## While the child is there

- **Always know where the child is during school hours.** Keep the address of the provider and any subcontracted or satellite sites (KCSIE paragraph 213).
- **Record attendance correctly.** Use **code D** where the pupil is dual registered at a PRU, AP academy or other school. For a non-school provider arranged by the school, use **code B**, and record the nature of the activity. The school must be satisfied the pupil is safeguarded there (Working together to improve school attendance, paragraphs 317 to 320 and 350 to 351).
- **Have the provider tell you about absence the same day.** Follow up unexpected and unexplained absence promptly, just as you would in school.
- **Keep the child on your roll** and keep them feeling part of your school.
- **Make sure the provider knows how to reach your DSL.** Concerns found at the provider are your concerns too. Record them on the child's safeguarding record.

## Reviewing the placement

- **Review at least half-termly.** The review should confirm that the child is attending regularly, the placement is still safe and it still meets their needs (KCSIE paragraph 213).
- **Review immediately if a safeguarding concern arises,** and end the placement if necessary until the concern is resolved.
- **Include the child's view** of the placement, and keep a full record of every placement, its outcome and where the child went next.
- **If the placement is part time,** the rest of the week is at school, and there should be a plan to return to full-time education. See [part-time timetables](https://pupilprotect.co.uk/glossary/part-time-timetable).

## Off-site direction

Off-site direction is when the school directs a pupil to attend AP or another school for a time to improve their behaviour. It must not be a punishment for past misconduct (suspension and permanent exclusion guidance, paragraph 36).

Since **26 July 2026**, academies and PRUs have to follow the same legal process as maintained schools (SI 2026/558). The **Arranging alternative provision** guidance, written in February 2025, still describes the old position for academies.

Under that process:

- parents (and the local authority, if the pupil has an EHC plan) get written notice at least **two school days** before the placement starts, with the address, who to report to, the number of days, session times, and the reasons and objectives
- the governing board reviews the placement as often as the pupil's needs require
- parents can ask for a review meeting, which must be held unless there has been one in the previous 10 weeks
- after each review, the governing board must tell parents its decision in writing within six days (paragraphs 44 to 50)

## Who to involve

If the child has a social worker, tell them about the placement and invite them to reviews. If the child is looked after, involve the virtual school head and update the PEP. See [looked-after children in schools](https://pupilprotect.co.uk/glossary/lac).

## Questions

**Who is responsible for safeguarding pupils in alternative provision?**  
The school or local authority that commissioned the placement. KCSIE 2026 says that where a school places a pupil with an alternative provision provider, it continues to be responsible for the safeguarding of that pupil (paragraph 210). Voluntary national standards and local approved lists help, but schools remain ultimately responsible (paragraph 212).

**What is alternative provision in education?**  
Education arranged for pupils of compulsory school age who would not otherwise get a suitable education because of exclusion, illness or other reasons. It also covers education for pupils on a suspension and pupils directed off-site to improve their behaviour. It includes pupil referral units, AP academies, hospital schools, colleges and non-school (unregistered) providers. Elective home education is not alternative provision.

**What is off site direction in schools?**  
Off-site direction is when a school requires a pupil to attend another education setting, such as alternative provision or another school, for a time to improve their behaviour. It must not be a punishment for past misconduct. Since 26 July 2026 the same legal process applies in academies and PRUs as in maintained schools, including written notice to parents at least two school days before it starts.

**How long can alternative provision last?**  
There is no single national limit. For off-site direction, a proposed maximum period should be agreed at the planning stage, and the governing board must keep it under review. All placements should be reviewed at least half-termly, and a part-time placement needs a clear plan and timeline for returning to full-time education.

**What is dual registration in schools?**  
A pupil can be on the admission register of more than one school, for example their home school and a pupil referral unit or AP academy. The school the pupil is due at that session records attendance, and the other uses code D. A pupil at a non-school provider is not dual registered: the home school records them with code B.

## Sources

- [Keeping children safe in education 2026, paragraphs 210 to 215 and 405 (DfE, in force from 1 September 2026)](https://assets.publishing.service.gov.uk/media/6ac3c09c11ed58342ad8e4ac/Keeping_children_safe_in_education_2026.pdf), checked 2026-10-20
- [Arranging alternative provision: a guide for local authorities and schools (DfE statutory guidance, February 2025)](https://www.gov.uk/government/publications/alternative-provision), checked 2026-10-20
- [Non-school alternative provision: voluntary national standards (DfE, August 2025), Annex A](https://www.gov.uk/government/publications/non-school-alternative-provision-voluntary-national-standards), checked 2026-10-20
- [Working together to improve school attendance 2026, paragraphs 317 to 320 (code B) and 350 to 351 (code D)](https://assets.publishing.service.gov.uk/media/6a4f9ec6a6586e258d371bd0/Working_together_to_improve_school_attendance_2026.pdf), checked 2026-10-20
- [Suspension and permanent exclusion guidance (DfE, effective from 26 July 2026), paragraphs 36 to 57 on off-site direction](https://www.gov.uk/government/publications/school-suspensions-and-permanent-exclusions), checked 2026-10-20
- [The Education (Educational Provision for Improving Behaviour) (Application to Academies and Pupil Referral Units and Minor Amendments) Regulations 2026, SI 2026/558](https://www.legislation.gov.uk/uksi/2026/558/made), checked 2026-10-20

## Related

- [Safer recruitment checks](https://pupilprotect.co.uk/tools/safer-recruitment-checks): The checks a role needs, so you know what to ask a provider to confirm.
- [Part-time timetables](https://pupilprotect.co.uk/glossary/part-time-timetable)
- [Suspension and permanent exclusion guidance](https://pupilprotect.co.uk/glossary/exclusion)
- [Persistent and severe absence](https://pupilprotect.co.uk/glossary/persistent-absence)
- [Single central record](https://pupilprotect.co.uk/glossary/scr)
- [Attendance jobs](https://pupilprotect.co.uk/jobs/role/attendance)