The Crime & Policing Bill had its second reading in the House of Lords in October 2025. Within this, the Government has proposed specific legislation targeting child criminal exploitation. Following the second reading, the Children’s Commissioner has criticised the much-needed legislation, pointing to loopholes that are likely to be exploited by perpetrators.
Child criminal exploitation (often referred to as ‘CCE’) is the exploitation of children for criminal gain; occurring when an adult uses a child to commit crimes for them. Often, the perpetrators of these crimes are members of gangs or organised crime organisations, and the victims are vulnerable children. Often, perpetrators groom and exploit children into committing crimes to avoid detection and/or conviction for themselves or other adult members of the gang.
Child criminal exploitation is particularly complex as the victims often do not view themselves as such and may believe they are carrying out the criminal acts of their own volition. The children involved therefore often face punishment instead of support and are themselves criminalised.
As there is no statutory definition of child criminal exploitation and no specific crime at present, it is difficult to obtain data about how widespread it is. Current estimates show that between 2023-2024, 14,500 children were identified as at risk of or involved in child criminal exploitation. However, due to the very nature of child criminal exploitation, many victims will not be known to authorities, so this figure is likely to be underestimated.
The Government’s Crime & Policing Bill was first introduced to the House of Commons on 25 February 2025. The second reading in the House of Lords took place on 16 October 2025, and the committee stage begins on 10 November.
Part 4 of this Bill provides the new legislation regarding child criminal exploitation. It will create a standalone offence of child criminal exploitation which will make it a crime for an adult (defined as anyone aged 18 or over) to use a child (who is under 18) to commit crime or to engage in conduct toward the child with the intention of causing them to commit a crime. Conviction will carry a maximum penalty of 10 years’ imprisonment, a fine, or both.
Furthermore, the Bill introduces child criminal exploitation civil preventative orders, to prevent exploitative conduct from occurring or reoccurring. These orders give the Court powers to restrict the actions of a person who is at risk of committing or recommitting child criminal exploitation where such an order is necessary to protect children. For example the Court could impose restrictions on an adult from contacting certain individuals or attending a specific address. Breach of this order is a criminal offence carrying a maximum penalty of 5 years’ imprisonment. Such orders are available at the conclusion of criminal proceedings regarding the offence of child criminal exploitation or without a criminal trial, on application by the police.
The Secretary of State also has the power to produce statutory guidance in support of the new offences and to ensure consistency in the application of the legislation. Chief police officers and the NCA will have a duty to have due regard to this guidance.
Dame Rachel De Souza, Children’s Commissioner, has welcomed specific legislation to deal with child criminal exploitation due to its growing prevalence and concerns regarding the criminalisation of victims. However in a response to the Bill on 16 October 2025, she criticised the legislation in its current form.
A particular concern is that the new offence allows a perpetrator to escape conviction if the child is over 12 and the perpetrator ‘reasonably believed’ they were an adult. This provides a defence to an offender who can claim that they believed the child was older than they were.
The Children’s Commissioner is concerned that this would result in similar issues as those that arise in child sexual exploitation cases, where perpetrators often allege that they believed the child was over 16, and in doing so can avoid prosecution for sexual offences against the children they have groomed. Furthermore, there is a risk of victim blaming – if the perpetrator uses the child’s behaviour and/or looks to suggest that they felt they were an adult and therefore avoid conviction.
Dame De Souza calls for national strategy and statutory guidance on child criminal exploitation, bringing together police, social services, education and health.
It is clear that any legislation and strengthening of laws surrounding child criminal exploitation is necessary and positive for vulnerable victims. However, there is an opportunity to close the loopholes seen in relation to child sexual exploitation convictions and it would be a shame for this new legislation to simply bring child criminal exploitation into line with child sexual exploitation and miss the opportunity to further protect vulnerable children.
The Bill is listed for committee stage starting 10 November 2025. Keoghs await developments and the final stages of this Bill with interest.
Anna Churchill - Associate
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