Safe Sport: A legal perspective on the UK’s new blueprint for safeguarding in sport

The publication of the Safe Sport project report marks the most ambitious attempt yet to reshape safeguarding across the UK sporting landscape. Co-chaired by Sarah Powell (British Gymnastics) and Andy Salmon (Swim England), the report draws on a survivor-led consultation with 146 organisations and more than 200 individual voices to diagnose a “fragmented, inconsistent and creaking” system and to chart a route towards an integrated, person-centred model.

At its heart is a call for the establishment of something that will drive cultural change in sport for the better – to make it safer for all participants, whatever their role. To do that, the report recommends a solution that feeds from a single framework, united in its values and ambition, to offer consistent standards, independence and ultimately greater focus on preventative as opposed to reactive schemes. To do this, it is suggested the new framework be supported by a code of practice and a new lead independent body to drive this forward.

The sentiment is commendable and the ambition admirable. However, it will not be without its challenges and the report at least impliedly gives a nod to that at times, without detracting from the determination it conveys.

Whilst the aim of the system is to free sport from the often expensive, arbitrary and lengthy constraints of unnecessary legal process, there can be no getting away from the risks that the development and implementation of this plan could create for stakeholders. My experience in advising NGBs, clubs and participants in sport over the years tells me that this project has great potential if it achieves the buy-in needed, but there are risks that will need careful management. Clubs, governing bodies and those affected by harm in sport must now pay careful attention to the legal implications over the coming months and early years.

Why the report matters

Sport already operates under a dense web of statutory and common-law duties: child protection law, data protection, equality, charity regulation, employment law, contract law, negligence principles and, for some, the UK Sports Governance Code. Yet despite this, the report finds that:

• victims perceive existing processes as inadequate, opaque and retraumatising;
• safeguarding practice is reactive and litigation-heavy, diverting millions of pounds away from prevention; and
• the absence of a single authoritative framework allows “regulator-shopping” and inconsistency, making it easier for abusers to migrate unchecked between clubs or sports.

Against that backdrop, the report’s vision of a comprehensive, integrated Safe Sport System, anchored by an independent lead body and an independent complaints & resolution service, could amount to a wholesale re-drawing of the risk map for sport. In my view, for the sector to buy in, the solution needs to be sound and its interface with governing bodies needs to offer fairness and transparency, whilst allowing those governing bodies to ultimately retain responsibility for their sport.

Key governance challenges that might arise from the plans

Independence and accountability

Under the proposed framework, National Governing Bodies (NGBs) may need to relinquish elements of their current ability to self-investigate safeguarding complaints. This would likely require amendments to constitutional documents, disciplinary rules, and funding agreements. Substantial thought must be given to the terms of appointment for any new lead body. NGBs will need assurance that this new structure, and the governance mechanisms supporting it, will offer security and clarity both for them and for their participants.

Data sharing and privacy

The proposal for a central data hub, intended to identify safeguarding trends and share learnings across sport, raises important legal considerations under UK GDPR. These include establishing a lawful basis for data processing, determining appropriate retention periods, and ensuring compliance where any cross-border data transfers take place. These challenges are particularly sensitive when handling survivor testimony and must be managed with care.

Thresholds for complex cases

The report suggests that “significant, sensitive and complex” safeguarding cases should be escalated to an independent complaints service. To ensure this works fairly and legally, clear criteria will need to be developed to distinguish which matters are dealt with internally versus externally. Transparent triage protocols will be essential, both to instil confidence in the system and to protect against judicial review or arbitration challenges.

Funding and cost recovery

While the report anticipates a reallocation of existing resources, NGBs and clubs must prepare for the possibility of new financial contributions, such as levies or user fees to support the independent body. Legal advisers should review how these costs will be accounted for, especially in terms of proportionality and flexibility. The framework will need to accommodate organisations of varying sizes and financial capacity, without undermining its aims.

Survivor participation

The report emphasises a survivor-led approach to safeguarding. This will require procedural fairness for all parties while embracing trauma-informed and potentially restorative justice models. These are complex and developing areas that intersect with human rights law, disciplinary best practices and public policy, and will demand thoughtful, legally sound implementation.

From vision to implementation

The report sketches a three-phase timetable:

1. Foundations & stakeholder alignment (to 2028) – scoping, pilots and creation of a Safe Sport Oversight Group (appointment targeted July 2025).
2. System integration & expansion (2028-2030) – all funded NGBs to adopt the Safe Sport Code of Practice and sign service-level agreements.
3. Full implementation & sustainability (2030 onwards).

Experience from other regulatory transitions (e.g. UK Athletics’ shift to the Athletics Integrity Unit model) suggests the heavy lifting occurs in phase 1. In my experience, pilot participants and early adopters will need to consider:

• Constitutional updates – aligning disciplinary regulations with the new framework and ensuring they dovetail with arbitral appeal routes.
• Contract reviews – revising athlete agreements, coaching contracts and sponsorship deals to reference the Code of Practice.
• Policy harmonisation – merging safeguarding, whistleblowing, and welfare policies into the common taxonomy proposed by the report.
• Training & culture – board-level education to satisfy the report’s design principle of “ownership and accountability”.

What this means for NGBs, clubs and survivors

For NGBs & clubs

Early engagement is critical. The Oversight Group will be consulting on the definition of significant, sensitive and complex complaints by October 2025; those definitions will shape which cases you must cede to the independent body. Failing to prepare could expose organisations to dual proceedings (internal and external) and compounded reputational risk.

For athletes, coaches and volunteers

A single, trauma-informed complaints route, independent of the sport, promises quicker resolution, greater consistency and, importantly, voice and choice in process design. But early years of any new regime often reveal teething issues. Ensuring your legal representation understands both sports disciplinary procedure and trauma-informed practice will be essential.

How we can help

Our Sports & Charities practice has supported governing bodies, clubs and individuals through every major safeguarding and governance reform of the past decade, including:

• Advising NGBs on constitutional change, funding-agreement negotiations and independent-complaints schemes.
• Designing and implementing child-protection and adults-at-risk policies that meet Charity Commission, Disclosure & Barring Service and UK GDPR standards.
• Acting for survivors in complex historical abuse claims, balancing trauma sensitivity with robust pursuit of civil redress.
• Delivering board-level training on duties under the Companies Act 2006, Charity Act 2011 and Sports Governance Code.

Whether you are an NGB plotting strategic alignment with the Safe Sport framework, a grassroots club seeking pragmatic policy templates, or an individual needing advice on your rights under the emerging system, our multidisciplinary team is ready to help.

Final thoughts

The Safe Sport report does not offer a quick fix, but it does offer a once-in-a-generation opportunity to embed safeguarding at the heart of UK sport’s governance architecture. For the proposal to succeed, leaders must be “bold and brave” in ceding a measure of autonomy to a truly independent body, reallocating resources from adversarial litigation to prevention and culture-change and foregrounding the voices of those harmed by sport’s past failings.

We welcome this step towards a safer, more inclusive sporting environment. Over the coming months we will publish deeper dives into specific legal aspects, data protection, funding structures, and survivor-led dispute resolution. In the meantime, if you would like to discuss how these changes could affect your organisation or your personal position, please get in touch.