Regulation 20 of the Children's Homes (England) Regulations 2015 defines the legal framework for physical intervention in residential childcare. It permits staff to use physical intervention to prevent injury to a child or another person, to prevent serious damage to property, and, in secure children's homes, to prevent a child from absconding. Any intervention that falls outside these purposes is unlawful, regardless of the perceived justification.
- Regulation 20 permits physical intervention only to prevent injury, prevent serious property damage, or (in secure homes) prevent absconding.
- Physical intervention must always be the last resort after all other de-escalation strategies have been attempted or considered.
- The Children's Homes Quality Standards reinforce Regulation 20, requiring homes to minimise and monitor the use of restrictive practices.
- Ofsted inspectors assess not just whether physical intervention is recorded but whether homes have a credible restraint-reduction strategy.
- BILD Act certified training equips staff to operate lawfully and safely within the Regulation 20 framework.
What Regulation 20 actually says
Regulation 20 of the Children's Homes (England) Regulations 2015 is the primary legal authority governing physical intervention in registered children's homes in England. The regulation is precise: it lists the circumstances under which a member of staff may use physical intervention and makes clear that no other circumstances justify it.
The permitted purposes are:
- To prevent injury to the child or to another person.
- To prevent serious damage to property.
- In a secure children's home, to prevent the child from absconding.
The regulation also sets requirements for how physical intervention must be carried out. It must be the minimum force necessary. It must not be used as a punishment. It must not cause pain, except where BILD Act approved techniques are used to prevent a greater harm. And it must be followed by a review and a record.
Staff working in children's residential homes need to understand these boundaries as operational knowledge, not just as policy text. When a situation escalates, a practitioner who understands the legal parameters makes better decisions than one who is only aware that a policy exists.
What Regulation 20 prohibits
The prohibited uses of physical intervention are as significant as the permitted ones. Regulation 20 makes explicit that physical intervention must never be used as a punishment, as a means of enforcing compliance with an instruction, or as a response to distressed behaviour that does not present a risk of injury or serious property damage.
Pain compliance
Pain compliance techniques are not permitted in children's homes except in the narrowest of circumstances and only where the technique has been approved through the BILD Act (formerly the Restraint Reduction Network) certification process. Homes that have not adopted BILD Act certified training cannot lawfully use any technique that deliberately causes pain.
Prone restraint
Face-down (prone) restraint is not prohibited by the text of Regulation 20 itself, but it is strongly discouraged by statutory guidance and by the Children's Homes Quality Standards. The risks associated with positional asphyxia in prone restraint are well-documented. Homes whose trained staff are taught prone holds are almost certainly not using BILD Act certified approaches, which would be a significant concern on inspection.
Seclusion and solitary confinement
Locking a child in a room alone as a behavioural consequence is not a form of physical intervention. It is an unlawful deprivation of liberty in the majority of residential childcare settings and would constitute a serious safeguarding concern on inspection.
Our guide to physical intervention training in children's homes sets out the full training framework that keeps staff and children safe within these legal boundaries.
How Regulation 20 interacts with the Quality Standards
The Children's Homes (England) Regulations 2015 and the accompanying Quality Standards work together. Regulation 20 sets the legal permission; the Quality Standards describe what good practice looks like in implementing that permission responsibly.
The safety and welfare standard
Quality Standard 3, the safety and welfare standard, requires homes to promote the welfare of children and to use the least restrictive approach possible. This means homes must not only have a Regulation 20-compliant policy but must actively work to reduce the frequency and intensity of physical interventions over time. A home that records the same number of incidents year after year without analysis or a reduction strategy will struggle under inspection.
The leadership and management standard
Quality Standard 13 places accountability on registered managers to ensure staff are trained and that their use of physical intervention is monitored. Managers are expected to review incident data, identify patterns, and take corrective action. Where training is not current or not appropriate for the children placed, the manager is accountable.
The positive relationships standard
The positive relationships standard recognises that a relational approach to care reduces the need for physical intervention. Homes that invest in building trusting relationships with children, and that support staff to understand the impact of trauma, report fewer incidents overall. Organisations using ProActive Approaches' BILD Act certified training have documented up to an 80% reduction in physical intervention incidents across residential settings.
What Ofsted inspectors look for
Ofsted inspectors assessing a children's home under the Social Care Common Inspection Framework (SCCIF) do not simply check whether Regulation 20 has been mentioned in a policy. They examine the evidence of how physical intervention is used in practice and whether the home's approach is reducing harm over time.
Documentation and recording
Inspectors will ask to see records of physical intervention incidents. They are looking for records that are detailed, completed promptly, and show evidence of review. A record that captures only the fact that intervention occurred, without the circumstances, the techniques used, the child's response, and the post-incident review, will be viewed critically.
Training evidence
Inspectors will ask which training programme staff have completed, when they last refreshed their training, and whether the techniques taught are appropriate for the children placed in the home. Ofsted does not mandate BILD Act certification, but homes using non-certified approaches carry greater risk of challenge if an incident occurs. Certified programmes have been through independent scrutiny of their techniques and governance processes.
Restraint reduction
A restraint-reduction strategy is a credible plan, based on incident analysis, for reducing the frequency or severity of physical interventions. Homes that present Ofsted with data showing a downward trend in incidents, linked to specific changes in practice or environment, demonstrate the kind of reflective management that the Quality Standards require. Physical intervention training from a BILD Act certified provider should include the tools to build this analysis.
Children's involvement
Inspectors may speak to children about their experience of physical intervention. They are interested in whether children understand why intervention was used, whether they were given an opportunity to discuss the incident afterwards, and whether they feel safe in the home. A home where children cannot articulate their rights in relation to physical intervention is a home where Regulation 20 has not been embedded in practice.
Building a Regulation 20-compliant practice framework
Compliance with Regulation 20 is not achieved through a policy document alone. It requires a practice framework that encompasses training, supervision, incident recording, post-incident review, and a culture of continuous improvement.
The key components of a compliant framework are:
- BILD Act certified training for all staff who may be required to use physical intervention, refreshed at least annually.
- A clear de-escalation pathway that sets out the steps staff must take before physical intervention is considered.
- Prompt and detailed incident recording completed within the same shift where possible, including body maps and the child's account.
- Post-incident review with both the child and the staff involved, within 24 hours wherever possible.
- Aggregate incident analysis reviewed by the registered manager monthly, with actions tracked.
- External oversight through the responsible individual and, where appropriate, an independent reviewer.
ProActive Approaches has 30 years of experience supporting children's homes to build practice frameworks of this kind. Our upcoming training courses embed Regulation 20 compliance into every element of physical intervention training, from the legal context to the post-incident review process.
Linking Regulation 20 to your training plan
Regulation 20 sits inside a wider system of expectations about how children's homes record, review, and reduce restrictive practice. Your training plan should connect to that system, not sit alongside it. When inspectors look at training records, they are also looking at incident logs, debrief notes, behaviour support plans, and reduction targets. If those documents do not tell a coherent story together, the training itself is harder to defend.
Make sure the policies you train staff against are the same ones they read on shift. It sounds obvious, but a surprising number of homes have an external training programme, an internal policy, and a separate set of operational habits that drift apart over time. The strongest services anchor everything to one consistent framework and use Regulation 20 documentation as the audit trail that proves they did.
Frequently asked questions
What does Regulation 20 permit in a children's home?
Regulation 20 of the Children's Homes (England) Regulations 2015 permits physical intervention to prevent injury to a child or another person, to prevent serious damage to property, and, in secure children's homes, to prevent a child from absconding. Intervention must use minimum necessary force and must be followed by a review and a record. It cannot be used as punishment or to enforce compliance with an instruction.
Does Ofsted require children's homes to use BILD Act certified training?
Ofsted does not require homes to use BILD Act certified physical intervention training as a specific condition of registration or inspection. However, using a certified programme provides independent assurance that the techniques taught are safe and appropriate. Homes using non-certified approaches carry greater risk of regulatory challenge if an incident results in injury or complaint, because they cannot evidence independent scrutiny of their practice.
Can physical intervention be used to manage distressed behaviour in a children's home?
Physical intervention cannot be used simply because a child is displaying distressed behaviour. Regulation 20 requires that the intervention prevents an injury or serious property damage that is imminent. Distressed behaviour that does not present that specific risk must be managed through de-escalation, environmental adjustment, and relational approaches. Using physical intervention in the absence of that risk would be unlawful under Regulation 20.
What happens if a children's home uses physical intervention outside the Regulation 20 grounds?
Using physical intervention outside the Regulation 20 grounds is unlawful and constitutes a safeguarding concern. Depending on the severity, consequences may include Ofsted enforcement action, a referral to the local authority designated officer (LADO), potential criminal liability for the staff member involved, and notification to the DBS. The registered manager and responsible individual are accountable for ensuring staff operate within the legal framework.
How often should children's home staff refresh their physical intervention training?
Most BILD Act certified training programmes require annual refresher training as a minimum. Some providers recommend six-monthly refreshers for staff working in homes with higher levels of physical intervention. The registered manager is responsible for ensuring all staff whose role may require them to use physical intervention have current, appropriate training. Lapsed training is a significant concern on Ofsted inspection.
Train your team within the Regulation 20 framework
ProActive Approaches delivers BILD Act certified physical intervention training specifically designed for residential childcare. Our programmes give staff the legal knowledge, practical skills, and reflective tools to work safely and confidently within the Regulation 20 framework.
View upcoming course dates or get in touch to discuss in-house training tailored to your home's needs.
