AYJs response to the Oversight and funding of Youth Justice Services
AYJ welcomes the opportunity to provide high-level feedback on the proposed reforms to youth justice oversight and funding. We have responded to a small number of questions that directly relate to AYJ’s core policy principles: ensuring custody is used only as a genuine last resort; keeping children safe by prioritising diversion from the youth justice system; and advancing racial justice across all aspects of youth justice system.
Part A: Youth justice service performance and oversight
Question 1: Should National Standards remain structured around system phases (Option 1), or be re-structured into thematic areas with cross-cutting principles (Option 2)?
Any restructuring of the National Standards must put children’s rights and needs at the forefront rather than the current process driven standards. They must reflect children’s lived experiences, recognising that their journeys through the youth justice system are rarely linear and are shaped by complexity, instability and wider structural factors. The framework must embed Child First principles and children’s rights consistently across all areas of practice, ensuring that participation, trauma-informed approaches, anti-racism and safeguarding apply at every point of a child’s journey.
It is also essential that any new structure strengthens effective multi-agency accountability, given that many outcomes depend on partners beyond the youth justice service. Evidence consistently shows that partnership functioning is often the decisive factor in children’s progress. Clear and explicit expectations for education, health, social care, policing and other partners must therefore be embedded throughout the standards to ensure effective support for children and partners to enable them to meet their statutory duties as set out in Working Together to Safeguard Children. In addition, the National Standards should align with inspection standards.
It is notable that the consultation provides no detail on how the Ministry of Justice intends to carry out its new oversight responsibilities, nor how these arrangements will align with inspectorates to reduce duplication for services. Greater clarity on oversight mechanisms and on plans to streamline expectations across MoJ, YJB and the inspectorates would have been helpful to contextualise the proposals on National Standards and to assess their likely impact on youth justice services.
Question 2: If National Standards remain as phases of youth justice (Option 1), do you agree with our proposals to develop new standards on Victims, Early Intervention and Prevention, and to update OOCRs to reflect contemporary good practice? What other changes or additions would you expect to see to National Standard phases to ensure they reflect the realities of current practice?
As noted, any restructuring needs to reflect children’s needs, rights and lived experiences. The standards must also reflect the purpose of the youth justice system to prevent children and young people from offending or re-offending while prioritising their welfare and rehabilitation. If standards remain phase based new standards on early intervention and prevention would align with this purpose.
It is also right that the standards recognise that there is not a binary distinction between victims and ‘children who offend’ given that many children in, or at risk of contact with, the youth justice system have experienced significant harm, trauma and victimisation. However introducing a new victims focused standard risks diverting resource and focus from the core purpose of the youth justice system. AYJ is therefore cautious about introducing a new victims-focused standard within the framework. The Code of Practice for Victims of Crime already sets out the statutory requirements and expectations for victim-related practice. and YJS already have responsibility to respond to victims of crime where a child has committed the offence.
If National Standards remain phase based, they must also be updated to strengthen expectations around effective multi-agency partnership working, Child First practice, trauma-informed approaches, anti-racism, participation, and transitions so the phased model reflects the realities of children’s lives and the complexity of their journeys through the system. In relation to transitions there need to be a clear focus and definition relation to transitions from custody to community, youth justice services to probation and youth custody to adult estate.
Question 3: If National Standards are restructured around thematic areas (Option 2), to what extent do you agree with the proposed example thematic areas and cross-cutting principles? What additions or changes would you suggest to reflect the realities of current practice?
If the National Standards are restructured, AYJ recommends explicit thematic areas on disproportionality and anti-racism, participation and co-production, and transitions and continuity of care, as these are consistently identified in inspection findings and as areas requiring improvement.
We also suggest strengthening expectations around early intervention, SEND and neurodiversity including children with speech and language difficulties who make up a significant proportion of the youth justice system, the specific needs of girls and care experienced children, whose needs are not sufficiently captured in the example themes. Clear accountability for partner agencies should be embedded throughout, supported by practical guidance and streamlined reporting requirements.
The National Standards must also align with the forthcoming updated national protocol on reducing the unnecessary criminalisation of children in care and care leavers, ensuring that they reinforce the expectations and safeguards set out in the protocol and promote consistent practice across local areas.
Question 4: Should disproportionality be included as an individual standard/thematic area or integrated throughout the National Standards? You may wish to give reasons in the text box.
AYJ believes disproportionality must be addressed as both a standalone thematic area and a cross-cutting principle, and it must cover all forms of disproportionality — including racial, ethnic, gender, disability, care-experience, and socio-economic disparities. A dedicated standard is essential to ensure sustained focus, accountability and measurable progress, while embedding disproportionality throughout all thematic areas ensures anti-racist and inclusive practice is reflected in assessment, planning, engagement, partnership work and decision-making. Treating disproportionality solely as a cross-cutting principle risks dilution; a combined approach is necessary to reflect the scale, urgency and breadth of disproportionality across the youth justice system.
Question 5: To what extent do you agree with the introduction of a Quality Performance Framework to define high-quality practice and support continuous improvement? Please explain your answer, including if there are any key risks or challenges you foresee and how these could be mitigated.
The AYJ would support a Quality Performance Framework that defines high-quality practice and does not just focus on compliance. The QPF must be Child First, rights-based and theme-led (safety/relational security, therapeutic education, equity, participation, resettlement and workforce). It should combine quantitative and qualitative measures, require disaggregated reporting, and be independently validated.
In addition, any new Framework would need to align with the HMIP inspection standards and should support YJSs in developing good practice in line with these. The risk is of duplicate and unaligned frameworks, creating additional work without improving performance.
Question 6: What areas or aspects of youth justice practice should the framework cover to be most useful to your local area?
Not responding
Question 7: To what extent do you agree that performance information should be organised and used across three tiers:
Youth justice service
Management boards and partners
System health
Please explain your answer, including any risks, benefits or implementation challenges
AYJ would support a tiered system that organising performance information across tiers that include Management Boards and Partners and System Health.
Question 8: We currently collect 14 national KPIs and a range of other performance information. As we develop future oversight arrangements:
Which measures are most useful for understanding the performance of an individual youth justice service?
Which measures are most useful for understanding the effectiveness of local partnership arrangements?
Which measures are most useful for understanding the health of the youth justice system overall?
Are there any measures that should be moved, removed or added?
Effective oversight requires a compact set of child-centred, disaggregated KPIs, high-quality shared datasets and active Boards that use both quantitative and qualitative evidence to drive improvement. Measures must prioritise children’s safety, rights, education and resettlement, and expose disparities so partners can be held to account.
On racial disproportionality we strongly recommend developing a measure that links directly to local YJS plans to address disproportionality and enables both YJSs and their statutory partners to be held to account for progress. A clear, outcome-focused measure would support consistent national expectations, strengthen local accountability, and ensure that tackling racial disparities is treated as a core priority across the youth justice system.
Question 9: To what extent do you agree that the voices of children, victims and families should form part of local and national performance oversight arrangements? Please explain your answer, including how these perspectives could be captured in a meaningful and proportionate way.
AYJ strongly agrees that the voices of children and families should form part of both local and national performance oversight. Their experiences are essential to understanding the quality, accessibility and impact of youth justice services, and align with Child First principles and UNCRC Article 12. To be meaningful, these perspectives must be captured through safe, proportionate and rights-based mechanisms such as structured feedback, co-produced local panels, independent facilitation, and thematic national insight work. Participation must include racialised children, care-experienced children, those with SEND, and groups most affected by disproportionality.
Feedback should inform improvement rather than compliance and must sit alongside clear expectations for partner agencies to act on feedback and to report back to participants on how their input has been used. Where feedback cannot be acted on, this should be explained to the participants.
Question 10: To what extent do the proposed arrangements reflect the oversight and accountability requirements of youth justice in Wales, and what additional considerations are needed?
AYJ agrees that the proposed arrangements broadly recognise the distinct governance and policy landscape in Wales, but further clarity is needed. Oversight must reflect devolved responsibilities for children’s services, education, health and safeguarding, and ensure alignment with Welsh policy frameworks such as the Youth Justice Blueprint1 and the Well-being of Future Generations Act.2 Accountability arrangements should be co-designed with Welsh Government and YJB, with clear expectations for partnership contributions and data sharing. Additional consideration is needed to avoid duplication between MoJ/YJB requirements and Welsh national reporting structures.
Question 11: What factors should be considered when designing local self-assessment arrangements to ensure they are meaningful, proportionate and support improvement in practice? Please include any risks, challenges or unintended consequences that should be avoided.
Not answering
Question 12: To what extent do you agree with the proposed approach to youth justice plans and annual updates? Please explain if there are any risks or unintended consequences you foresee with this approach.
Not answering
Question 13: The proposed annual update would cover:
confirmation of a locally approved youth justice plan
strategic priorities
a performance summary
key risks
staffing and resources
Are there any areas that should be added, removed or amended? Please explain your answer.
Not answering
Question 14: To what extent do you agree with the proposal to remove the requirement for youth justice services to submit Serious Incident Notifications within 24 hours and instead report learning from serious incidents at regular intervals? Please explain your answer, including any benefits, risks or unintended consequences you foresee.
Not answering
Question 15: As we develop a more proportionate approach to reporting and compliance, are there any other requirements that you think could be streamlined, simplified or removed? Please provide details.
AYJ recommends streamlining data returns that duplicate information already captured through YJB, MoJ or HMIP systems, and simplifying narrative reporting that does not directly support improvement. Requirements should be aligned across agencies to reduce duplication, and outdated or low-value reporting should be removed. Any new reporting must be proportionate, child-first, and clearly linked to improvement rather than compliance. We also support co-production of reporting templates with YJS practitioners.
We agree with the principle that the focus of the arrangements should be on ‘improvement over compliance’
Part B: Stable and sustainable funding
Question 16: Do you agree that we should reform the funding formula, recognising that it is likely to result in a significant redistribution of funding across services in England and Wales?
The funding formula should be reformed, provided the process is driven by and aligned with feedback from Youth Justice Services and its partners. It is also important that the funding formula recognises informal prevention and diversion activity undertaken by YJS alongside more formal service delivery. Any changes must be transparent, phased, and supported by clear, published modelling showing the impact on individual services so local partners can plan and mitigate risks. Reforms should include transitional protections, an implementation timetable, and a commitment to review and adjust the approach in response to sector feedback and emerging evidence
Question 17: Do you agree that the principles outlined above are the right ones to guide the design of a new funding formula?
Not answering
Question 18: Do you agree that allocating MOJ funding to youth justice services across England and Wales based on relative levels of need is the most appropriate approach? Please explain your response.
Not answering
Question 19: Stakeholders have highlighted the limitations of using first time entrant data as a proxy for demand and need. Aside from diversion data currently collected by the YJB, what alternative or supplementary datasets could be considered to provide a comprehensive measure of need in your local area? When providing alternative or supplementary datasets please ensure that any proposed data meets the following criteria
available across England and Wales
can be disaggregated to local levels
published data
recent / up-to-date
likely to be updated regularly in the future
not directly influenced by youth justice services to avoid perverse incentives.
AYJ agrees that first-time entrant (FTE) data is too limited to act as a meaningful proxy for demand or need. FTEs are shaped by policing practice, local diversion pathways and wider system behaviour, and therefore do not reliably reflect underlying levels of vulnerability, complexity or harm. A more comprehensive measure of need should draw on published datasets that capture deprivation, vulnerability, disproportionality, trauma, exclusion and exposure to violence, and which are available across England and Wales, disaggregated locally, regularly updated, and not directly influenced by youth justice services.
To support a more accurate and equitable assessment of local need, the MoJ could consider incorporating the following datasets:
Socioeconomic need: Index of Multiple Deprivation (IMD) and Welsh Index of Multiple Deprivation (WIMD), which are robust indicators strongly correlated with youth justice involvement.
Education vulnerability: School exclusions, suspensions and persistent absence, which reliably reflect disengagement and unmet need.
Children’s social care indicators: Children in Need, Child Protection Plan and Looked-After Children statistics, which capture trauma, instability and complexity.
Health and neurodiversity: Mental health prevalence, local health inequality profiles, SEND prevalence and EHCP rates.
Contextual harm: Police-recorded serious violence and hospital admissions for assault with a sharp object, which are regularly published and available at local levels.
Transitions and care experience: Care leaver outcomes, which highlight vulnerabilities linked to instability and service access.
Together, these datasets would provide a more comprehensive, evidence-based picture of local need than FTEs alone and support a funding model that reflects the complexity and diversity of children’s experiences across England and Wales.
Question 20: To what extent do you support providing all youth justice services with a standard allocation towards core business costs before the remaining funding is distributed through the funding formula? You may wish to give reasons in the text box.
We agree with this as there is a significant infrastructure cost for even the smallest service. We suggest this question should read “providing all local authorities (not ‘all youth justice services’) with a standard, ring-fenced allocation for the delivery of their youth justice
service’s core business costs etc”. This avoids the current disincentives for cross-authority working. All YJSs should receive a minimum level of funding before the funding formula kicks in. This must recognise that all services need the same basic infrastructure such as buildings and IT. Lastly, we strongly recommend retaining the ring-fence on all grants to youth justice services.
Question 21: If a new funding formula is introduced, which approach to managing the transition would you prefer?
Option A: Faster implementation, for example over 3 years – services would reach their target allocations sooner and national funding would be distributed in line with local need – but the sharper pace of change could create instability for some services, particularly where funding levels would need to adjust more quickly to align with the formula.
Option B: Gradual implementation, for example over 6 years – changes would be phased over a longer timeframe, providing greater stability for services, but delaying the move to a fully needs-based distribution. Please explain your answer, including any practical examples of how different rates of change would affect your service's ability to plan, manage resources and deliver services effectively.
We support the view of the Association of Youth Justice Managers who prefer option A.
Question 22: Which of the following future grant arrangements would best support effective delivery of youth justice services in your local area?
Option A: Maintain the current arrangement (separate agreements for the core grant and Turnaround funding).
Option B: Merge core grant and Turnaround funding to form one grant agreement but maintain a ringfence for the delivery of early intervention activity (currently delivered through the Turnaround programme).
Option C: Merge Turnaround funding into the core grant, with no ringfencing for early intervention and give local authorities the flexibility to manage this locally. Please explain your answer, including any potential benefits or risks. If you select Option C, please comment on the potential impact on prevention and early intervention activity if funding was no longer ringfenced.
Funding should minimise administrative demands on YCS while still ensuring prioritisation of early intervention and diversion. AYJ strongly believes this must include funding and working in partnership with ‘by and for’ organisations that work with racially minoritised children. Evidence from Bridging Gaps and Changing Tracks shows that these organisations play a critical role in building trust, addressing structural barriers and preventing escalation into the youth justice system, yet they remain significantly under-resourced. However, achieving this through other accountability and oversight mechanisms—rather than restrictive funding conditions—could be a better way to reduce administrative burdens.
AYJ believes that whatever future grant arrangement is adopted, a defined portion of funding must be ringfenced for diversion and for by-and-for organisations supporting racialised children. Evidence from Bridging Gaps and Changing Tracks shows that these organisations play a critical role in building trust, addressing structural barriers and preventing escalation into the youth justice system, yet they remain significantly under-resourced.
Ringfencing a portion of Turnaround funding—or an equivalent element within any revised grant—would protect early intervention and ensure that culturally competent, community-led provision is not deprioritised in areas facing acute pressures. This approach would secure diversion pathways, strengthen racial justice, and align investment with the evidence on what works for racialised children.
Question 23: Current grant arrangements for the core grant and Turnaround funding are in place until March 2029. However, if Option B (merge core grant and Turnaround funding to form one grant agreement) were implemented, when should this change take effect? Please explain your answer, including any potential benefits or risks.
Option A: as soon as possible (making adjustments to the current grant arrangements)
Option B: after the current spending review period (no earlier than April 2029)
Not answering
Question 24: To what extent do you agree that greater public visibility of partner contributions (including how they vary between areas) would strengthen accountability, support management boards to hold partners to account, and drive partners to meet expected levels of engagement and funding contributions? You may wish to give reasons in the text box.
AYJ strongly agrees that greater public visibility of partner contributions would strengthen accountability. Transparent reporting would help management boards identify gaps, challenge inconsistent engagement, and ensure partners meet their statutory responsibilities. Visibility is particularly important for education, health, social care and policing, where variation in local contributions significantly affects outcomes for children.
Public transparency would also support equity across areas, highlight good practice, and reinforce the principle that youth justice outcomes depend on whole-system responsibility, not solely on YJSs.
Question 25: What additional measures would most help strengthen partner contributions in your area?
AYJ recommends:
Clear national expectations for partner contributions, including minimum levels of engagement and resource.
Public reporting of partner inputs, including staffing, funding and participation in governance.
Stronger escalation routes where partners fail to meet responsibilities
Joint inspection focus on partnership that meet children’s needs and rights, particularly education, health and safeguarding and findings from current thematic inspections inform additional measures.
Co-produced local partnership agreements setting out shared priorities, responsibilities and resource commitments.
Dedicated funding incentives for multi-agency early intervention and prevention.
These measures would help ensure partners contribute consistently and equitably, reducing pressure on YJSs and improving outcomes for children.