Analysis of the National Audit on Group-Based Child Sexual Exploitation and Abuse

Baroness Casey's National Audit on Group-Based Child Sexual Exploitation and Abuse (the Audit) was commissioned by the Government in February 2025 and reported in June 2025. The Government has accepted all 12 recommendations of the Audit (Government's response).

The Audit was commissioned following widespread public outrage and pressure on the Government to act in relation to child sexual abuse and exploitation (CSAE) by ‘grooming gangs’. Specifically the Audit was to “evaluate our understanding of the scale, nature and drivers of group-based” CSAE at a national and local level. 

It is clear that Baroness Casey and her team understand the scale of the crisis, the ongoing and significant obstacles to both tackling grooming gangs offending today and redressing past injustices. The overarching question the Audit leaves us with is what prospect is there for change?

The Audit expressly recognises:

“Reviews, recommendations and strategies on child sexual exploitation raise the same issues repeatedly: system failures in information sharing, the need for more training, understanding of risk factors of victims, and the importance of collecting better data and information on perpetrators, including on ethnicity."

What conclusions did the Audit draw?

The Audit points out that a whole litany of recommendations have been made previously and that to a significant extent the challenges that persist in relation to tackling CSAE do so because those recommendations were not implemented either effectively or at all.

Data

The most significant obstacle the Audit faced was a lack of data in relation to CSAE, particularly data in relation to group-based CSAE in non-family settings, and even more particularly data in relation to group-based child sexual exploitation (as distinct from abuse).  The data that the Audit was able to obtain was often not reliable and of poor quality. The issues with data largely arose from the following:

(1) Inconsistent definitions and application of those definitions by the range of public bodies involved in identifying, preventing and prosecuting CSAE;

(2) Failure to consistently collect data in relation to the ethnicities of victims and perpetrators, as well as misleading presentation of the data that was collected;

(3) The absence of a regular and up-to-date prevalence study of CSAE; and

(4) The continued under-reporting of CSAE.

The Independent Inquiry into Child Sexual Abuse (IICSA) made a number of recommendations in relation to data, which the Audit concludes have not been implemented either effectively or at all.

The Audit states that “It is a failure of public policy over many years that there remains such limited, reliable data in this area”. 

Adultification and criminalisation of victims and survivors

The Audit concludes that significant challenges arise from pervasive attitudes that girls who are victims of group-based CSAE are in some way responsible or complicit in the offending.  This is particularly the case for girls who are older, albeit still legally children.  As the Audit quite rightly points out, the pattern of group-based CSAE is often designed to create an “illusion of consent”, for example by the abuser behaving as a boyfriend might, by buying their victims gifts and showing them affection, particularly at the outset of the relationship, in order to help facilitate the offending later down the line.  

This grooming can be so effective that victims and survivors themselves do not recognise themselves as victims, sometimes for many years after the offences took place. This can lead to victims and survivors refusing to cooperate with investigations and prosecutions, as well as continuing to interact with their abusers. Nevertheless, it is the legal and moral obligation of all public bodies to step in and protect children who are at risk of or are being subjected to CSAE, even where the girls themselves do not see that they are victims.  

Whilst the law may have moved on, with the term ‘child prostitution' being dropped and replaced with the term ‘child sexual exploitation’ in 2015, the societal attitude, as well as the attitudes of some of those involved in protecting children and investigating, prosecuting and sentencing offenders, lags behind.  

IICSA reported that between 1989 and 1995, almost 4,000 police cautions were given to children aged between 10 and 18 for offences relating to prostitution.

The consequences of this attitude is particularly demonstrated by the approach to decision-making around whether to charge and, if so, for which offence, where an adult has raped a 13-15 year old child. Whilst still unlawful, there is a grey area which means cases where a defendant argues the victim had consented to sex can be dropped or downgraded to lesser charges.  As the Audit states, “they cannot consent to their own abuse - they remain children”  and we welcome the recommendation that the law be changed so adults receive a mandatory charge of rape in these circumstances.

What comes next?

To a large extent this Audit repeats the recommendations of previous reviews and inquiries. Indeed, the Audit's recommendations are predicated on the basis that the Government should also implement all recommendations previously made by IICSA and notes that the recommendations made are not intended to be exhaustive.  The recommendations go to the issues identified above, as well as others (see the Government's response).

Convictions of children

The Audit recommends that criminal convictions of victims of CSAE are reviewed and where the Government finds victims were criminalised instead of protected, those convictions be quashed.  Whilst the Government has accepted this recommendation, and committed to introducing a a disregard scheme, we note that the Government has distinguished between convictions for child prostitution offences and other convictions where victims of CSAE were criminalised, which the Governments says will be a matter for the Courts.  Victims and survivors of CSAE have spoken about the significant and lasting impact of such convictions, for example on the Channel 4 documentary Groomed: A National Scandal. It seems that those criminalised as children will face a further fight to clear their names and their records.

A national inquiry

One recommendation which has attracted a lot of attention is around the recommendation for a national inquiry.  There have been calls, particularly this year, for a new public inquiry into CSAE, notwithstanding IICSA. What the Audit recommends is a national inquiry co-ordinating a series of targeted local investigations, to be overseen by an Independent Commission with full statutory powers. As prominent CSAE campaigner Maggie Oliver (of The Maggie Oliver Foundation) has said, the devil is in the detail.

The Audit proposes that the national inquiry would be step two, with step one being a national police operation overseen by the National Crime Agency, which would require every local police force in England and Wales to review records to identify both cases of CSAE which were reported but not acted upon and unreported cases identified by reviewing police and children's services records to identify children who were at risk of or harmed by CSAE.  This review of records is to go back ten years.  

After this review, the Independent Commission should review cases of “failures or obstruction by statutory services” resulting in local investigations being initiated.  The Audit suggests that step one can effectively be bypassed where the Independent Commission and Home Office agree that sufficient evidence already exists.  In either scenario, what the purpose or outcome of these local investigations is to be is unclear.  What is clear is that the enduring problem with any type of public inquiry, be that statutory or non-statutory, is the lack of monitoring and enforcement around the implementation of recommendations made, particularly given the significant cost to the public purse.  This issue was considered by the House of Lords select committee in the report “Public Inquiries: Enhancing Public Trust”, published in September 2024.  The Government published its response to the report in February 2025, accepting a large number of the recommendations.  However, no specificity was provided around how accountability for and monitoring of the implementation of recommendations would be improved.  Against all of this backdrop, it is uncertain what will be achieved by the new national inquiry and Independent Commission.

For those continuing to seek accountability for systemic, institutional failures to prevent and protect children from sexual abuse and exploitation, a further national inquiry may not feel like justice.