From bullying to online safety: What Dubai's new school safeguarding framework covers

Dubai: Private schools and other educational institutions in Dubai will have to follow new safeguarding requirements aimed at protecting learners, identifying potential risks earlier and ensuring concerns are properly reported and addressed.

The Knowledge and Human Development Authority (KHDA) has introduced the Policy Framework for Safeguarding and Learner Protection in Dubai’s Private Educational Institutions, setting out mandatory requirements for how institutions prevent, identify and respond to safeguarding concerns.

The framework also establishes clearer responsibilities for school leaders, staff and governing bodies, with a phased implementation period of up to 12 months.

Here is what the new framework means, how it will work and what happens if institutions fail to comply.

What is the new safeguarding framework?

The framework establishes a common set of safeguarding standards across Dubai's private education sector. It focuses on four areas:

• Prevention: Creating safer learning environments and reducing potential risks.

• Early identification: Recognising warning signs and safeguarding concerns.

• Reporting and response: Ensuring concerns are reported, escalated and addressed appropriately.

• Accountability: Monitoring safeguarding practices and holding institutions responsible for compliance.

Safeguarding will no longer be treated solely as the responsibility of a designated staff member. It must be integrated into an institution's policies, leadership, recruitment, training and everyday practices.

Which institutions and learners are covered?

The framework applies to all KHDA-licensed and permitted private educational institutions, including - early childhood centres and nurseries, private schools, higher education institutions and training and vocational institutes It covers both in-person and virtual learning environments.

The framework applies to learners aged 21 and under. For those aged 18 to 21, institutions must identify concerns, provide support and follow internal reporting procedures.What types of safeguarding concerns does it cover?

The framework addresses a wide range of risks affecting learners' safety and wellbeing, including:

• Abuse, neglect and other risks of harm

• Bullying and cyberbullying

• Online grooming, unsafe contact and harmful digital content

• Misuse of technology and artificial intelligence

• Manipulated content and digital coercion

• Risks arising during transport, sports, educational visits and extracurricular activities

• Wellbeing or counselling concerns that indicate a risk of harm

Institutions must also establish appropriate digital safety controls and provide learners with age-appropriate online safety education.

Who will be responsible for safeguarding?

Although safeguarding is everyone's responsibility, the framework introduces specific roles to strengthen accountability.

1. Safeguarding Governor - Every institution must appoint a Safeguarding Governor at board or governing body level. This person will provide independent oversight, monitor safeguarding arrangements and challenge shortcomings. The Safeguarding Governor cannot be the institution's owner, principal, senior executive or operational safeguarding lead.

2. Head of the institution - The principal or institutional head will hold executive accountability and be directly answerable to KHDA for compliance.

3. Designated Safeguarding Lead - Institutions must appoint a Child Protection Coordinator or Designated Safeguarding Lead (CPC/DSL), supported by at least two deputies. They will help coordinate safeguarding concerns and responses. Institutions must also establish safeguarding teams with specialist support. Importantly, assigning these duties to individual staff members does not remove the institution's overall responsibility.

How will reporting and action improve?

One of the framework's key requirements is ensuring safeguarding concerns are reported promptly, even when there is no confirmed evidence of harm.

Staff do not need proof before reporting a concern. If they have reasonable suspicion or information that raises concern, they must report it without delay. Staff must not investigate allegations themselves, wait for certainty or assume someone else has already reported the issue.

When a learner discloses abuse or neglect, staff must listen calmly, take the concern seriously, assess immediate safety risks and follow the appropriate reporting procedures. They must not promise secrecy, ask leading questions or independently investigate the incident.

Institutions must also:

• Provide accessible reporting channels for staff and learners.

• Refer immediate risks to the appropriate authorities without delay.

• Record safeguarding concerns promptly.

• Document decisions and actions taken.

• Monitor cases until closure.

• Review safeguarding data every term and conduct a comprehensive annual review.

Students must also have appropriate opportunities to raise concerns and express their views about matters affecting their safety.

What other changes must institutions make?

Institutions must maintain written policies covering safeguarding, anti-bullying, attendance, behaviour, digital safety, inclusion, safer recruitment, emergency planning and other required areas. 

They must also introduce appropriate pre-employment checks and safeguarding training.

Additional role-specific training is required for staff working in settings such as transport, sports, boarding, digital environments and one-to-one provision. 

Staff, parents and learners must be consulted when key safeguarding policies are developed or reviewed.

When will the new requirements take effect?

The framework has a two-stage implementation process, calculated from its publication date.

Immediately: Requirements that protect learners straight away, or are already required under UAE law or existing KHDA regulations, apply from the effective date.

Within 12 months: Institutions must implement requirements involving new governance structures, systems, documents and other arrangements.

Some deadlines are shorter:

• Within nine months: Appoint a Safeguarding Governor.

• Within three months of appointment: The Safeguarding Governor must complete governance training.

• Within 12 months: Complete the remaining requirements covered by the grace period, subject to earlier training deadlines.

KHDA will review institutions' progress during the transition period.

How will KHDA monitor compliance?

KHDA monitors and enforces compliance with the Policy Framework through the following mechanisms:

• Quality assurance activities: KHDA assesses how well institutions meet safeguarding requirements through its quality assurance activities and regular evaluations.

• Review of progress: During the 12-month grace period, KHDA's quality assurance activities review institutions' progress towards meeting the grace-period requirements.

• Evaluation impact: Non-compliance directly affects the evaluation of institutional leadership, governance, and overall provision during KHDA quality assurance reviews.

What happens if an institution fails to comply?

Failure to follow mandatory safeguarding requirements can lead to regulatory and professional consequences.

These may include:

• Formal compliance notices and administrative penalties.

• Restrictions on permit renewals or other regulatory sanctions.

• Negative findings in KHDA evaluations of leadership, governance and educational provision.

• Disciplinary action against staff, including dismissal, for serious safeguarding misconduct.

• Reporting serious misconduct to law enforcement and possible inclusion on KHDA's Deregistration List.

Failing to report or deliberately ignoring safeguarding concerns can constitute severe professional misconduct. 

The policy framework is based on the principles of Wadeema Law (Federal Law No. 3 of 2016) and builds on existing legislation, policies and frameworks in Dubai and across the UAE aimed at protecting children and safeguarding their rights. It also supports the objectives of the Dubai Social Agenda 33 and the Education 33 Strategy by strengthening the environments in which learners spend their formative years.