Evaluating Child Safeguarding Standards

The Child Safeguarding Standards (SOM) document has been sitting in your binder since 2024. A short version for children hangs in the waiting room. The topic seems closed. Yet the Act requires you to assess the standards from time to time and to record the conclusions of that assessment. In everyday language people talk about an "evaluation"; the Act speaks of an "assessment of the standards".

This article covers only that stage: when you carry out the review, what you check in it and how to leave a trace afterwards. Who is bound by the standards and what they must contain is described in the article on Child Safeguarding Standards at a physiotherapy practice.

Key points

• Entities bound by the duty to introduce the standards must assess them at least once every two years (Article 22c(6) of the Act).
• The assessment checks two things: whether the standards match current needs and whether they comply with the provisions in force.
• The conclusions of the assessment must be documented in writing. The Act gives no template for the record.
• The provision does not say directly when to start counting the two years. The most cautious approach is to count from the day the standards were introduced.
• The document itself must contain the rules for reviewing and updating the standards (Article 22c(1)(4)).

Do the standards have to be reviewed, and what does evaluation mean

The basis is the Act of 13 May 2016 on Counteracting Threats of Sexual Crime and Protecting Minors. The duty to introduce standards applies, among others, to the managing body of a medical facility attended or stayed in by minors, or where minors may stay, and to the organiser of medical activity for minors (Article 22b). Whether your practice is covered by the duty is decided on the basis of that provision. This article assumes that you have already introduced the standards.

For such entities, Article 22c(6) provides that they must assess the standards at least once every two years, in order to ensure they are adjusted to current needs and comply with the provisions in force. The conclusions of the assessment must be documented in writing.

This is not a duty carried over from schools to practices. The provision is common to all entities in Article 22b, and among them the Act expressly names medical facilities. Incidentally, the word "evaluation" does not appear in the Act. Look in the documents for the terms "assessment of the standards" and "review and update of the standards".

How often and who is responsible

How often. The minimum is once every two years. Nothing prevents you from reviewing more often, for example after every major change at the practice.

Counting from when. The Act does not give a start date. The Act of 28 July 2023 (Article 10) gave entities 6 months from its entry into force to introduce the standards. It entered into force on 15 February 2024, so the deadline for introducing them expired on 15 August 2024 (this is our own calculation from Article 10 and the date of entry into force). If you introduced the standards on time, the most cautious assumption is that the first assessment falls due no later than around August 2026. For many practices that means now. If you introduced them later, count two years from your own date.

Who is responsible. The Act does not name the person responsible for the assessment itself. It does say, however, that the standards must set out the persons responsible for receiving reports of events threatening a minor (Article 22c(1)(7)) and the scope of competence of the person responsible for preparing staff to apply the standards (point 5). In a small practice the owner is responsible for everything. In a team, designate in the document one person who runs the review, and put it in the standards. This is our recommendation, not a requirement of the Act.

SOM review checklist

The table below organises the review according to what the Act requires the standards to contain. The "Basis" column shows the provision from which each element follows.

What you check	Check question	Basis
Safe relations between staff and minors	Do the rules (including prohibited behaviours) match how you work now, for example therapy without a parent in the room?	Art. 22c(1)(1)
Intervention when abuse is suspected	Is the procedure up to date, and does everyone on the team know what to do?	point 2
Notifications	Is it clear who notifies about a suspected offence and who notifies the family court? Are the details of those people up to date?	point 3
Rules of review and update	Does the description in the document match what you actually do?	point 4
Preparing staff	Have new people been introduced to the standards, and is that documented?	point 5
Making the standards available	Do parents and children know where to find them?	point 6
Receiving reports	Are the responsible persons still at the practice?	point 7
Documenting incidents	Does the way of recording and storing them still work?	point 8
Internet and devices	Do the rules cover all devices with network access available at the practice?	Art. 22c(2)(2)-(3)
Children with disabilities	Do the standards take their situation into account?	para. 4
Understandable for children	Is the short version written in language suited to minors?	paras. 5 and 7
Website and premises	Are the standards on your website, if you run one, and displayed on the premises in both the full and the short version?	para. 7

Beyond the table, ask yourself three questions about changes since the last review:

1. Staff changes. Has someone left, has someone joined, has the division of roles changed?
2. New services. Are you starting to treat younger children, offering home visits, group classes or therapy without a parent present?
3. Incidents and comments. Was there a signal, a doubt, a conversation with a parent that needs to be turned into a change in the document?

If new people work at your practice, remember to check them properly before they start work. We describe the procedure in the article on checking an employee in the offender register.

How to document the review

The Act requires only that the conclusions be in writing (Article 22c(6), second sentence). It imposes no form. We suggest a one-page record with these fields:

• date of the assessment and the person who carried it out,
• number or date of the version of the standards in force,
• what was checked (for example, by reference to the checklist table),
• conclusions: what is up to date, what needs changing,
• changes introduced, or a justification that no changes are needed,
• date of the next assessment and a signature.

When you change the content of the standards, give the new version a number or date and keep the previous one. For changes that concern children, update the short version too. Preparing it is discussed in the article on the children's version of the standards. If a change concerns rules of behaviour at the practice, introduce the team to it and record that, as described in the article on staff training in the standards.

Many practices combine this review with a review of parental consents for children's therapy, because it concerns the same patients. More about consents in the article on paediatric physiotherapy and parental consent.

Changes in the law and your document

We checked the consolidated text of the Act published on 30 January 2026 (Journal of Laws 2026 item 110) and the 2026 acts amending it that we found: item 187 (Act on the profession of psychologist) and item 421 (amendments to the National Criminal Register, including two provisions of the SOM Act concerning the register). In neither did we find changes to Article 22b or 22c. The requirements for the standards, including the two-year assessment, therefore read as we describe them.

What else is worth watching:

• Guidelines for the standards. The Team for the Protection of Minors at the Minister of Justice prepares guidelines for drawing up the standards and updates them every 2 years (Article 22s(4)(4)). We did not check the content of the current guidelines. It is worth reading them during the review, because they may change expectations of the document.
• National plans. The Council of Ministers was to adopt the first National Plans for Counteracting Violence Against Minors and Offences Against Sexual Freedom by 31 December 2026 (Article 8 of the Act of 28 July 2023). We did not check whether they have been adopted.
• Inspection. Compliance with the duty to introduce the standards may be inspected by, among others, local government bodies (Article 22x) and the President of the National Health Fund (NFZ) within their competence (Article 22z). For failing to introduce the standards, Article 23b provides a fine of up to PLN 250 or a reprimand, and for a repeat finding a fine of not less than PLN 1,000. We did not find in the Act a separate sanction for failing to assess the standards, but the absence of written conclusions is a breach of Article 22c(6). We did not check how inspectors treat this element in practice. Other inspections of a practice, for example a KIF inspection, are discussed separately.

Once you have collected several comments in one place, see also the list of typical gaps in a practice's paperwork in the article on compliance mistakes in a physiotherapy practice.

Frequently asked questions

How often must the Child Safeguarding Standards be assessed?

At least once every two years (Article 22c(6)). The Act does not forbid more frequent reviews, and a change at the practice, for example a new person on the team or a new service for children, is a good reason to do one earlier.

From when are the two years counted?

The provision does not settle this. The most cautious approach is to count from the day the standards were introduced. Entities had to introduce them within 6 months of the entry into force of the Act of 28 July 2023, that is, by our calculation, by 15 August 2024. If you introduced them on time, the first assessment falls due no later than around August 2026.

Must the assessment of the standards be in writing?

The conclusions of the assessment must be documented in writing (Article 22c(6)). The form of the document is not prescribed. A record with the date, the person assessing, the conclusions and the decision on changes is enough.

Do I have to change the document after the review?

No, if the conclusion is that the standards are up to date and comply with the provisions. Record that conclusion with the date. A change is needed when the assessment shows a mismatch with the practice's operations or with the provisions.

What about the children's version of the standards and the website?

The Act requires the standards to be made available on the website and displayed in a visible place on the premises, in the full version and in a short version intended for minors (Article 22c(7)). With every change to the document, update both versions and the place where you make them available.

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Legal status as of: 2 November 2026

Legal basis: Act of 13 May 2016 on Counteracting Threats of Sexual Crime and Protecting Minors (consolidated text Journal of Laws 2026 item 110), Articles 22b, 22c(1), (2) and (4)-(7), 22s(4)(4), 22x, 22z and 23b; Act of 28 July 2023 amending the Family and Guardianship Code and certain other acts (Journal of Laws 2023 item 1606), Articles 8, 10 and 12; checked for changes to Articles 22b-22c: Journal of Laws 2026 items 187 and 421. We did not check: the content of the guidelines of the Team for the Protection of Minors or materials of the Ombudsman for Children, whether the national plans under Article 8 of the amending Act have been adopted, or the inspection practice of the NFZ and local government bodies concerning the assessment of the standards. The range of entities in Article 22b (whether your practice is covered by the duty) requires your own assessment, preferably with a lawyer.

Last reviewed: 2 November 2026

You write and assess the Child Safeguarding Standards yourself, because FizjoReady packages do not include a template for them. Patient documentation, including the treatment consent, is organised by the TARCZA package. See the TARCZA package or compare all packages.

Related articles:
- Child Safeguarding Standards at a physiotherapy practice
- Child Safeguarding Standards for children
- Staff training in the SOM standards
- Offender register: how to check an employee
- Most common compliance mistakes in a physiotherapy practice