After Sex Matters wrote to complain, the chief executive of the National Society for the Prevention of Cruelty to Children (NSPCC), Chris Sherwood, has written to us saying the charity has revised its schools briefing on safeguarding considerations in changing rooms. The guidance now says that, wherever possible, staff supervising children changing should be the same sex as them. That is welcome. But the NSPCC should not have needed reminding of basic safeguarding.
In his response, dated 25th September, to our letter, Sherwood responded to each of our concerns.
The revised briefing now says that, wherever possible, staff supervising children changing should be the same sex as them.
It also says plainly that having children of both sexes in the same changing area becomes less appropriate as they get older.
It quotes Keeping children safe in education (KCSIE), the statutory safeguarding guidance for schools in England, which says that children aged 11 and over must not undress in front of the opposite sex, and refers to KCSIE’s guidance on “gender-questioning” children.
We welcome these changes, but the charity has declined two of our requests, and we think schools still deserve clearer direction on what they should and shouldn’t do.
What the NSPCC has changed
Same-sex supervision. For years the NSPCC told schools that where possible, adults supervising children getting changed “should be of the same gender as them”. “Gender” was initially a synonym for sex, but it has since become used to mean “gender identity”. Rather than correcting the word to make the meaning clear following the Supreme Court judgment of April 2025, the NSPCC removed the advice altogether, leaving schools with no guidance on who should supervise children while they change.
The NSPCC’s letter says that it dropped the advice because the September 2026 update of KCSIE does not address the sex of adults supervising changing rooms.
This is a poor excuse. The charity now accepts that it did not need to wait for government guidance, and its revised briefing says: “Wherever possible staff supervising children changing should be the same sex as them.”
Mixed changing areas. The 2024 briefing said “mixed gender changing areas” become less appropriate as children get older. The August update changed this to “mixed changing areas”, which could mean mixed by age, with members of the public or by gender identity. The revised briefing now says mixed changing areas are less appropriate as children get older, “whether that be mixed by age, or by sex”.
Gender-questioning children. The revised briefing now reflects the KCSIE guidance that, if a gender-questioning child does not want to use the changing room designated for their sex, the school should consider an alternative, such as an enclosed room for one child at a time or a different changing time. This replaces the 2024 NSPCC advice that schools should support “transgender and non-binary” children to use the changing rooms they “feel comfortable with”.
The NSPCC leaves out an important safeguarding point in the KCSIE guidance that says: “When responding to a request to support any degree of social transition, a school must not allow a child access to changing rooms designated for the opposite sex” (emphasis added).
This omission is particularly concerning because the charity’s own previous advice contradicted this safeguard, and schools following that guidance were risking the safety, comfort, privacy or dignity of children by not maintaining separate-sex privacy.
Our view is that schools should make every effort to ensure that the correct-sex changing rooms are safe and welcoming for all children, and not move children out because they identify as “trans” or “gender questioning”. Safe alternative spaces and times will not always be available, and subjecting children to lower standards of care because they identify as trans could, in our view, amount to gender-reassignment discrimination.
Staff data. We also raised the NSPCC’s practice of reporting data on its trustees, staff and volunteers as “male (including transgender men)” and “female (including transgender women)”. The NSPCC says this data is historic and that it plans to change its categories when it publishes 2026 figures. We hope the new categories will record sex accurately.
What the NSPCC has not changed
The 2024 briefing told schools to “consider how to support transgender and non-binary young people to use the changing rooms that they feel comfortable with”. That advice has gone, which we welcome.
But neither the revised briefing nor the webpage tells schools that it was wrong, and the NSPCC has declined to do so. Silently removing a sentence does not tell anyone that the policy it previously supported was wrong and should be revisited.
A section once headed “Separating children of different genders” is now titled “Guidance and legislation around toilets and changing facilities in schools”. The NSPCC says this signposts the content clearly. We still think “Separating children by sex” would say more plainly what schools should do. This is a smaller point, but clear headings help busy staff find the rule they need.
The law is not in doubt. School-premises regulations in each part of the UK require separate toilet or washroom provision for boys and girls, and maintaining clear rules and boundaries was always a basic principle of safeguarding.
The NSPCC says it would welcome greater clarity on adult supervision in both KCSIE and the Equality and Human Rights Commission’s forthcoming technical guidance for schools. We think this is passing the buck. The job of the equality regulator is to explain the Equality Act. The Equality Act doesn’t say how schools should run changing rooms. There is nothing to wait for. And the NSPCC should know that.
Same-sex supervision was good practice long before the Supreme Court ruled or KCSIE was updated. The NSPCC is the country’s best-known child-protection charity, and schools rely on its guidance. We are glad it has listened to us on the most important point. We hope it will take the next step and make clear that schools following its previous guidance should revise their policies.
What happens next
We are considering whether to appeal the NSPCC’s decision not to issue a correction to its 2024 advice.
Schools do not need to wait. If your school’s changing-room policy was based on the 2024 NSPCC briefing, now is the time to review it. Sex Matters has produced a whole-school model policy for schools in England that is in line with KCSIE and the Equality Act.
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Congratulations to Sex Matters!
And hopefully, they appeal the NSPCC's decision not to issue a correction to its 2024 recommendation.
Well done. So glad Sex Matters is out there. ❤️🇬🇧❌❌