Why Non-Certified Training Puts Your Organisation at Risk

Using physical intervention training that is not certified against the RRN Training Standards is not simply a quality concern. It is a regulatory risk, a governance failure, and a potential source of harm to the people your organisation supports. Since April 2021, CQC expects all health and social care services to use training certified against the RRN Training Standards. Organisations that have not transitioned to certified provision are operating outside those expectations, often without fully understanding the exposure this creates.

The regulatory risk: CQC and Regulation 18

In November 2020, CQC, Skills for Care, and Health Education England issued a joint letter to health and social care providers. The letter stated clearly that from April 2021, CQC expects all health and social care services to use training that is certified against the RRN Training Standards. It also stated that non-compliance is likely to be a breach of Regulation 18, the CQC regulation that covers staffing.

Regulation 18 requires registered persons to ensure that sufficient numbers of suitably qualified, competent, and experienced staff are deployed and that those staff receive appropriate support, training, and supervision. Where CQC finds that physical intervention training is not certified, this may be recorded as a finding against Regulation 18 on the basis that the training does not meet the expected standard of competency.

This is not a hypothetical risk. CQC inspectors are increasingly asking for evidence of certified training during inspections of services that may involve restrictive practices. If your organisation cannot demonstrate that your training is certified, this is a gap that inspectors are equipped to identify.

The NHS contract risk

For organisations delivering services under NHS contracts, the risk is more direct. Certified training against the RRN Training Standards became a contractual requirement of the NHS Standard Contract for services supporting people with learning disabilities, autism, or mental health conditions in April 2020. This predates CQC's expectation by a year.

NHS-commissioned services that have not transitioned to certified provision may be in breach of their contractual obligations. This has implications not only for the current contract but for any future commissioning decisions and contract renewals.

If your organisation delivers NHS-funded care and has not confirmed that your physical intervention training is certified, checking this should be an immediate priority. Our guide on how to check if your training provider is BILD Act certified explains how to verify certification status at bildact.org.uk.

The governance risk: what happens after a serious incident

The most serious consequence of non-certified training is not a regulatory finding on an inspection report. It is what happens when something goes wrong. Physical intervention, even when carried out by well-meaning and experienced staff, carries inherent risk. When a serious incident occurs involving physical intervention, one of the first questions that will be asked in any internal or external investigation is: was the training the staff received certified against the RRN Training Standards?

If the answer is no, the organisation faces a governance problem on top of the incident itself. Non-certified training cannot demonstrate that staff were equipped to the expected standard. This affects not only CQC but potentially the police, the coroner's court, or civil litigation. The absence of certified training becomes a factor in any investigation or proceedings, because it represents a failure to meet the standard that the regulatory framework identifies as expected practice.

For managers in adult social care, this is not an abstract concern. The consequences of a serious incident involving non-certified staff training are potentially significant for individuals and for the organisation.

The quality risk: what non-certified training cannot guarantee

Beyond the regulatory and governance dimensions, there is a straightforward quality argument. The RRN Training Standards define what comprehensive, evidence-based physical intervention training looks like. Training certified against those standards has been independently verified to cover all required content areas with sufficient depth and quality. Non-certified training has not.

Non-certified training may be well-intentioned and delivered by competent trainers. But without independent audit, there is no external verification that it covers human rights frameworks, trauma-informed approaches, post-incident support, de-escalation, and proportionate use of physical techniques at the level the standards require. The organisation is relying entirely on the provider's own assessment of its quality.

The short-course limitation

Many non-certified programmes are also short. Six-hour or twelve-hour physical intervention courses are common in the market. As outlined in the RRN Training Standards, programmes of this duration cannot cover all required elements to the depth required for certification. Staff who have attended only short non-certified courses may have basic physical technique skills but lack the broader contextual knowledge, de-escalation capability, and trauma-informed understanding that certified training requires.

The organisational culture risk

Training shapes culture. Organisations that invest in certified, genuinely trauma-informed training send a message to staff about the values the organisation holds. Training that is primarily technique-focused, not contextualised within a restraint-reduction philosophy, can inadvertently normalise the use of physical intervention rather than treating it as a last resort.

Organisations that have implemented BILD Act certified training consistently report that the shift to certified provision changes how staff think about physical intervention, not just how they perform physical techniques. Organisations using our programmes have documented up to an 80% reduction in incidents, reflecting the impact of a genuinely restraint-reduction-oriented approach embedded across the whole organisation, not just in training days.

This culture shift is difficult to achieve with non-certified training that has not been assessed for its alignment with the values and philosophy of the RRN Training Standards.

What to do if your training is not currently certified

If you have identified that your current physical intervention training is not certified against the RRN Training Standards, the recommended steps are straightforward.

Step 1: Document the gap and your response

Record that you have identified the training gap and are taking steps to address it. Documenting your awareness and your response demonstrates proactive compliance management. This matters if you face an inspection before the transition to certified provision is complete.

Step 2: Notify the right people internally

This is a governance matter, not simply a training administration issue. Notify your registered manager, your senior leadership team, and, if relevant, your board or trustees. The decision to use non-certified training has governance implications that sit above the training function.

Step 3: Identify a certified provider

Use the bildact.org.uk certified organisations list to identify providers certified against the RRN Training Standards. Conduct due diligence on providers who appear there, looking for experience in your specific sector and an approach that is genuinely trauma-informed. Plan a transition timeline for moving to certified provision.

Step 4: Prioritise new staff and upcoming refreshers

You do not need to immediately re-train all staff who have attended non-certified training. Prioritise ensuring that all new staff, and all staff due for refresher training, receive certified provision going forward.

The reputational risk that is harder to quantify

Most commissioners think about non-certified training in terms of the immediate risks: legal exposure, regulatory criticism, staff injury, harm to people who use services. These are the right risks to take seriously. But there is a slower, less obvious risk that often gets overlooked: the reputational drag of being the organisation that did not invest in the recognised standard.

Local authority commissioners talk to each other. Health partners talk to each other. Safeguarding leads compare notes across services. If your organisation is the one whose name comes up when a serious incident is being analysed, the question of what training you used will be asked. "It was the cheapest option" is not a defensible answer in front of a coroner, a serious case review panel, or a CQC inspection team.

Conversely, organisations that have made the decision to invest in BILD ACT certified, RRN-aligned training tend to find it easier to recruit experienced staff, retain commissioners, and rebuild trust after difficult moments. The training itself is part of the story you tell about your service.

What to do if you have already invested in non-certified training

If your organisation has rolled out non-certified training in good faith and is now reconsidering, you are not alone. Many services bought what was available at the time, before the Restraint Reduction Network Training Standards became established practice. The honest answer is that you do not need to throw everything out and start again. You do need to put a plan in place to migrate to a certified, RRN-aligned approach over a defined period.

Start by mapping the gaps. Look at your current training against the RRN Training Standards and identify where it is genuinely aligned, where it is partially aligned, and where it is missing entirely. Then build a migration plan that prioritises the highest-risk service areas first, secures budget across the next financial cycle, and documents the rationale at every step. Inspectors and commissioners look more favourably on services that can show a credible plan for improvement than on services that pretend their existing training is already good enough.

Frequently asked questions

Is it illegal to use non-certified physical intervention training?

It is not illegal in the criminal law sense to use non-certified training in most settings. However, for CQC-regulated services, non-compliance with CQC's April 2021 expectation for certified training is likely to be treated as a breach of Regulation 18. For NHS-contracted services, certified training is a contractual requirement. The risks are regulatory and contractual rather than criminal, but they are significant and real.

Does Ofsted require certified training?

Ofsted does not currently require BILD Act certified training for settings regulated only by Ofsted or DfE. LGA guidance produced jointly with CQC, NHS England, and ADASS confirms this. However, this does not mean non-certified training is adequate practice. The regulatory landscape is evolving and best practice, as defined by the sector, favours certified provision regardless of inspection framework.

Can we keep using our current non-certified training while we transition?

This depends on your specific regulatory context. For CQC-regulated services, continuing with non-certified training carries ongoing risk. Document your transition plan, implement it promptly, and ensure that all new and refresher training moves to certified provision as quickly as practicable. Speak to your registered manager and senior leadership about the appropriate pace of transition given your organisation's specific circumstances.

Does the registered manager carry personal risk if training is non-certified?

The registered manager is responsible for evidencing that staffing, including training, meets required standards under CQC Regulation 18. Where a serious incident occurs and training is found to be non-certified, the registered manager's decisions about training provision will be scrutinised. This is not to say individual liability is automatic, but the registered manager's governance role in training decisions is clear and significant.

Transition to certified training

ProActive Approaches is BILD Act (RRN) certified, with 30+ years experience delivering physical intervention and behaviour support training in adult social care, children's services, and healthcare. Our training is certified against the Restraint Reduction Network Training Standards. Manchester Metropolitan University evaluated the RRN Training Standards as a national framework, not our programme directly.

If you need to transition your organisation to certified training, or want to discuss in-house delivery for your team, get in touch or view upcoming course dates.