Grooming Gangs Inquiry: What Do the Draft Terms of Reference Mean, and How Can I Get Involved?

Posted onJanuary 30, 2026
Phoebe Epstein

In December, the government published the draft Terms of Reference (TORs) for the long-awaited Grooming Gangs Inquiry. As set out in our earlier article, these offer the clearest indication yet of the Inquiry’s intended scope.

The publication of draft TORs, however, is only the starting point. It marks the beginning of a formal public consultation process that will directly influence what the Inquiry will – and will not – examine. For survivors of group-based child sexual exploitation and abuse (CSEA), organisations, charities and professionals working with those affected, the consultation offers a critical opportunity to influence the direction and boundaries of the investigation.

In this article, we consider what the draft TORs tell us about the Inquiry’s plans, what key questions remain unanswered, and how interested parties can effectively engage with the process.

What The Draft TORs Tell Us

At its core, the Inquiry’s aims to:

Investigate failures and obstruction by statutory services in their response to group-based CSEA.
Identify systemic and individual failings in practice, and hold those responsible to account.
Drive meaningful change in safeguarding systems at local and national levels, ensuring that victims and survivors are placed at the centre of reform.

All Public Inquiries operate in slightly different ways. The Chair and their appointed Inquiry Team have broad discretion over how they run their investigation. The TORs, therefore, play a vital role in setting the framework and tone. Once finalised, amendments to the TORs are rare. Issues or questions falling outside the agreed scope risk being ruled inadmissible or irrelevant, and subsequently refused.

The draft TORs for the Grooming Inquiry are currently framed in relatively broad terms. This breadth indicates an appreciation of the many complex and intersecting issues at stake, but it also leaves significant questions unanswered about the Inquiry’s precise scope, priorities and practical operation. The consultation process will be critical in resolving these ambiguities, and determine the investigation’s boundaries. It is a mechanism through which those with an interest in the Inquiry – such as survivors, community organisations, advocacy groups or professionals – can influence how these questions are resolved and shape the final direction of the Inquiry.

A Victim-Centred Approach in Practice

The draft TORs acknowledge that victims and survivors must be at the forefront of the Inquiry’s approach, with engagement that is inclusive, representative and trauma-informed. There is an explicit commitment to engaging victims and survivors across England and Wales.

This recognition is welcome. However, the commitment is largely aspirational at this stage. There is not yet an explanation of how victim-centred engagement will be delivered in practice, nor how evidence from victims will meaningfully inform the Inquiry’s findings and recommendations.

This lack of clarity is particularly significant in light of recent reports that several survivors resigned from the panel overseeing the establishment of the Inquiry, amid concerns around the government’s handling of the process. Victim and survivor engagement is commonly a contentious issue in public inquiries. Baroness Longfield will no doubt be keen to avoid repeating the criticisms raised in the Grenfell Tower Inquiry and the Covid Inquiry, where some of those affected felt their voices were not heard sufficiently.

Confidence in the Inquiry will depend on transparent, clearly defined and robust mechanisms for victim and survivor involvement.

Key questions that remain unanswered include:

Will survivors be appointed as Assessors or advisors to the Inquiry?
How will victim and survivor testimony be gathered, evaluated and reflected in the Inquiry’s conclusions?
Will there be a place for those who wish to share their stories and experiences in live evidence during public hearings to do so? If so, how will that process be managed, how much time will be dedicated to that witness testimony and how will individuals be supported to do so in a safe way?
What safeguards will be put in place to ensure that engagement is genuinely trauma-informed?
How will the Inquiry ensure that it engages with victims whose experiences may be less visible or less publicly recognised – such as children and young people currently/recently affected by grooming, or those who have faced barriers to accessing support and reporting abuse?

These types of issues should be carefully considered in the Inquiry’s planning.

Systemic issues and institutional accountability

The Inquiry will operate as a series of local investigations, overseen by a national panel responsible for synthesising findings and making recommendations. It will also work alongside the existing national police operation examining group-based CSEA.

This structure creates the potential to identify recurring patterns across different geographical areas and time periods, including systemic failures relating to risk assessment, information sharing, leadership and accountability.

However, important questions remain about the consistency of local investigations, the comparability of their findings and the extent to which responsibility for failures spanning multiple institutions and jurisdictions will be meaningfully examined. Without careful framing, there is a risk of systemic failures being mischaracterised as isolated local issues, rather than patterns evidencing entrenched national-level problems.

A robust Inquiry must therefore look beyond individual cases and “missed opportunities” to examine the wider structural and policy context in which abuse persists. This may include the impact of structural vulnerability – such as poverty, housing insecurity, immigration status or economic dependence – in entrenching cycles of exploitation. The Inquiry must also examine evidence relating to intersecting socioeconomic and demographic inequalities. There has been much commentary on how the Inquiry might address allegations of disproportionate representation of certain ethnicities amongst perpetrators. It will be critical that the role of structural racism and its impact on entry, and barriers to exiting, sexually exploitative situations, as well as how discrimination has shaped institutional responses to group-based CSEA at the local and national level, is carefully considered.

Individuals and organisations with relevant experience or evidence have a vital role to play in ensuring the Inquiry examines these intersecting institutional and structural issues, to make national-level recommendations that address root causes and close accountability gaps.

Definitions, scope and who is included

The draft TORs define a “child” as anyone under the age of 18, but explicitly allow the Inquiry to consider abuse of those over 18 where their abuse began before they turned 18. This is a significant and positive inclusion, reflecting the reality that exploitation often continues into adulthood.

Recognising this category of victims in principle is, however, only the first step. To be effective, the Inquiry will need to grapple with the full scope and complexity of survivor experiences, including careful examination of:

The interaction – and frequent disconnect – between child and adult safeguarding services and frameworks, particularly the abrupt withdrawal of support at age 18.
Accountability failures when abuse spans multiple local authority areas or policing jurisdictions.
Efforts aimed at safeguarding within communities and population groups known to be underserved and/or otherwise at heightened risk.
The heightened risks faced by children and young people with care experience, given their disproportionate representation amongst victims of sexual exploitation.

The draft TORs also acknowledge that group-based CSEA can take many different forms. A particularly important issue is the changing nature ‘grooming’ over time, including the increasing use of social media and online platforms by perpetrators to identify and target victims.

The Inquiry must confront and engage proactively with these complexities, which are directly relevant to how exploitation is identified, investigated and responded to. The consultation provides an opportunity to press for TORs that explicitly include them in the Inquiry’s scope, ensuring that victims are not excluded simply because their experiences do not align neatly with age-based, geographic or administrative boundaries. It is vital that the Inquiry team reaches and listens to the voices and perspectives of as wide a range of victims and groups working to support them as possible.

Why Early Engagement Matters

Once the final TORs are agreed and published, the Inquiry’s scope is effectively fixed. Opportunities to widen or reshape it thereafter are extremely limited.

The consultation stage is therefore a key moment at which those with a direct interest can most effectively influence Inquiry’s focus and priorities, at a stage when it is most receptive to change. Targeted consultation submissions can address gaps, ambiguities or risks in the draft TORs, helping to ensure that the final framework allows for meaningful scrutiny of the issues that matter most.

Details of the consultation are expected to be published in January, and the current aim is that the finalised terms of reference will be agreed and published by March 2026.

How Saunders Law can help

For those considering or wanting to participate in the Inquiry, early engagement in the TORs consultation is particularly important. At Saunders Law, we specialise in representing Core Participants in public inquiries. Our extensive experience includes representing victims, survivors, bereaved families and non-state advocacy groups in:

The Grenfell Tower Inquiry
The Infected Blood Inquiry
The Covid-19 Inquiry
The Undercover Policing Inquiry

If you have been affected by group-based CSEA and/or are interested in participating in the upcoming Inquiry, please call us on 020 7632 4300 or fill in our online enquiry form.