An organisation can have comprehensive safeguarding policies, detailed procedures and mandatory training programmes in place and still fail to protect people effectively. That is one of the important questions raised by the Care Quality Commission's latest State of Care 2025/26 report, published on 23 October.
The report examines a health and social care system facing increasing demand, complex needs and persistent inequalities but beyond these pressures, its findings raise important questions about organisational leadership, safeguarding culture and accountability.
Are organisations genuinely safeguarding people, or simply demonstrating that safeguarding processes exist?
What Does the Report Tell Us?
CQC reports that, among the 3,783 care homes it assessed, 27% were rated requires improvement and 3% inadequate overall.
Leadership remains a particular concern. Around 34% of assessed care homes were rated requires improvement or inadequate under the well-led key question.
The report also identifies concerns surrounding Deprivation of Liberty Safeguards (DoLS), including delays in applications, inconsistent documentation and insufficient communication about changes in people's circumstances.
In some inspected services, restrictive practices were not adequately connected to individual support plans or risk assessments.
These findings matter because safeguarding failures rarely arise from one isolated weakness.
They can develop where poor leadership, inadequate oversight, workforce pressures and ineffective decision-making combine.
Safeguarding Culture Cannot Be Measured by Policies Alone
Policies and procedures are essential, but they cannot tell us everything about how an organisation safeguards people.
A policy may describe how staff should escalate concerns, but does that mean staff feel confident to challenge a senior colleague?
An organisation may provide safeguarding training, but can staff recognise less obvious indicators of abuse, neglect or exploitation?
A governance report may confirm that incidents have been reviewed, but has the organisation established whether interventions actually improved people's experiences?
These are questions of culture, not simply compliance.
The true measure of safeguarding culture is what people experience and what professionals do when concerns arise.
Organisations need environments where concerns are welcomed, professional curiosity is encouraged and leaders are prepared to challenge uncomfortable findings.
Mental Capacity, Restrictions and Individual Rights
The CQC findings concerning DoLS are particularly significant. The Mental Capacity Act 2005 provides an essential framework for protecting the rights of people who may lack capacity to make particular decisions. However, compliance requires more than submitting applications and maintaining documentation.
Professionals must understand decision-specific capacity assessments, best interests, the least restrictive principle and the legal safeguards governing deprivation of liberty. Where restrictions are introduced, organisations should be able to explain why they are necessary, proportionate and appropriate to the individual's circumstances. Restrictions should not become routine simply because they are operationally convenient.
The report reinforces the importance of reviewing restrictive practices, maintaining accurate records and ensuring appropriate legal authorisation.
Leadership and Accountability: Who Is Asking the Difficult Questions?
Effective safeguarding governance requires leaders to look beyond headline compliance measures.
For example:
Are recurring safeguarding concerns being identified and analysed?
Are staff confident in raising concerns and challenging decisions?
Are incidents reviewed for wider organisational learning?
Are people's wishes, experiences and outcomes informing safeguarding decisions?
Are safeguarding actions completed and their effectiveness evaluated?
Senior leaders and boards should receive meaningful safeguarding assurance, not simply activity reports.
Knowing how many concerns have been recorded is useful. Understanding what happened to the people involved, what changed and whether risks were reduced is far more important.
What Should Organisations Do Now?
The CQC report provides a timely opportunity for care providers and other organisations supporting adults to review their safeguarding arrangements.
At RLB Safeguarding, we would encourage organisations to focus on five priorities.
1. Evaluate safeguarding culture. Explore how staff, managers and people receiving services experience safeguarding in practice.
2. Strengthen governance. Ensure safeguarding reporting includes trends, outcomes, unresolved risks and evidence of improvement.
3. Review restrictive practices. Examine Mental Capacity Act compliance, DoLS arrangements and the proportionality of restrictions.
4. Support professional judgement. Provide meaningful training, reflective supervision and opportunities for professional challenge.
5. Test the effectiveness of interventions. Establish whether safeguarding actions have improved safety, wellbeing and individual outcomes.
Beyond Compliance
The CQC findings should encourage organisations to consider whether their safeguarding arrangements are genuinely effective.
An organisation's safeguarding culture is reflected in everyday decisions, leadership behaviours and the experiences of the people it supports and we truly commend the work that professionals commit to in the adult care industry. Professionals require the best support and resources.
Safeguarding assurance should not simply establish whether organisations have done what their policies require. It should help determine whether people are better protected as a result.
That is the difference between demonstrating compliance and embedding meaningful safeguarding practice.
How RLB Safeguarding Can Help
RLB Safeguarding supports organisations through independent safeguarding audits, consultancy, training and reflective safeguarding supervision.
Our approach considers not only the existence of policies and procedures, but how safeguarding is understood, implemented and experienced throughout an organisation.
Source: CQC State of Care 2025/26