We welcome the government’s proposal to establish a new Child Protection Authority (CPA) and support its ambition to create a child‑centred, expert‑led system capable of addressing the fragmentation, inconsistency, and lack of accountability identified by the Independent Inquiry into Child Sexual Abuse.
Our response focuses specifically on babies – from pre‑birth through the first 1001 days – who are profoundly affected by domestic abuse during pregnancy and early years. This developmental period is uniquely sensitive, and harm caused at this stage can shape a child’s lifelong outcomes. Babies cannot speak for themselves, yet they are deeply impacted by domestic abuse; therefore, the CPA must explicitly recognise and advocate for them throughout its design and implementation.
Babies Must Be Explicitly Recognised in the CPA’s Scope
Although the consultation states that “children” includes those “from pre‑birth to the transition into adulthood”, babies and unborn children are not consistently named in the operational detail. This omission risks leaving them invisible in practice. Unborn babies and newborns should be explicitly included in the CPA’s list of vulnerable groups on page 23 of the consultation document. Babies also require an advocate during the consultation phase (outlined on pages 48 and 49) because they cannot use their own voices but are as equally impacted as other children, if not more so. Children under the age of one are the most likely age group to be killed by another person.
To ensure that babies are not overlooked, the CPA should consistently reference unborn babies and infants across all definitions, risk categories, workforce standards, and data requirements. Their developmental vulnerability and documented high risk of harm demand that they are not simply assumed to be covered under the broader category of “children,” but are named and prioritised as victims in their own right.
Domestic Abuse During Pregnancy and Early Years Must Be a Core Focus for Frontline Staff
Domestic abuse is a major risk factor for harm during pregnancy and the early years of a child’s life, yet it is often under‑recognised in safeguarding systems. Evidence suggests that at least 30% of domestic abuse begins or escalates during pregnancy. The new Lead Child Protection Practitioner role must include training on the specific risks associated with domestic abuse during pregnancy and the early years, as well as guidance on how to engage effectively with maternity services. Pregnancy is also a critical window for intervention: parents may be more motivated to change, and therapeutic work at this stage can disrupt generational cycles of abuse. Therapeutic work with expectant and new parents, such as the For Baby’s Sake programme, can prevent re‑offending and break cycles of abuse.
The CPA should therefore ensure that domestic abuse is recorded as its own category of harm, with attention to patterns and cumulative impact. Universal routine enquiry – “asking the question” about experiences of domestic abuse and feelings of safety and wellbeing should be embedded across maternity, neonatal, health visiting, and early years services, and crucially, this should apply to both parents.
Specialist training on: domestic abuse during pregnancy; its impact on both the parents and the baby; trauma‑informed practice; and evidence-based interventions with those experiencing abuse, and those using abusive behaviours, must be a core part of workforce development. There must also be clear pathways for those concerned about their own behaviour and the impact it’s having on their family, to access support.
The perinatal period is critical to child development and breaking cycles of abuse; the CPA must ensure that funding and training reflect this. We are recommending this in line with the Domestic Abuse Commissioner’s tenth recommendation: “The CPA should use its position and role to influence regulators and professional bodies to […] provide practice directions for practitioners about how to respond to domestic abuse, and advise the government on the need to fund the co-production and delivery of robust training.”
Babies’ Developmental Vulnerability Requires a Distinct Approach
The consultation acknowledges the “cumulative impact of adverse events” on children facing severe and enduring harm, but babies require specific recognition because their developmental trajectory is uniquely sensitive to environmental stress. Those involved in creating the CPA must ask a vital question: What would a baby ask for if they could speak? Babies experience domestic abuse through stress in utero, disrupted attachment, and exposure to parental anger, grief, fear and trauma. Early harm has disproportionate long‑term consequences, and babies cannot verbalise distress or seek help.
For these reasons, the CPA should adopt a “1001 Days Lens” across all decision‑making, data analysis, and workforce standards. Along with the Domestic Abuse Commissioner, we welcome the “CPA viewing all of its aims and delivery through the lens of racial and socio-economic disparities, and that the leadership will reflect the diversity of the communities that it serves”. In line with this, we advise that there should be senior leaders with specific maternity and early years’ experience, to provide a voice for babies.
Multi‑agency child protection teams should include specialist domestic abuse practitioners trained in infant mental health and domestic abuse during pregnancy, ensuring that babies’ needs are understood and acted upon. Local areas should also be required to report on outcomes for babies separately from older children, recognising their distinct developmental profile.
Multi‑Agency Working Must Fully Integrate Maternity and Early Years Services
The consultation emphasises the importance of multi‑agency working and early intervention, noting that the system must support children “experiencing or likely to experience significant harm” across all settings. However, maternity services, health visiting, perinatal mental health teams and service providers in the voluntary sector are not consistently named as core safeguarding partners, despite their central role in identifying and responding to risk during pregnancy and infancy.
To address this, maternity and neonatal services must be formally embedded within multi‑agency child protection teams. The CPA should develop joint protocols for information‑sharing between maternity services, police, social care, and health visiting, ensuring that early signs of domestic abuse or parental vulnerability are not missed. Workforce development should include cross‑sector training on perinatal risk, baby‑specific harm indicators, and trauma‑informed practice, reflecting the risks of domestic abuse during pregnancy.
Data and Accountability Must Capture Pre‑Birth and Early Life Harm
One of the CPA’s core aims is to address “data gaps” and the lack of consistent outcome measures, which currently make the system reactive rather than strategic. Domestic abuse, especially as it impacts babies, is often invisible in data systems. There is a need to record domestic abuse as its own category and to recognise patterns of harm, not just isolated incidents. This also specifically a concern relating to Children in Need data, given the Department for Education’s commitment to explore this in response to the Domestic Abuse Commissioner’s ‘Victims in their Own Right’ report, published last year.
The CPA should therefore mandate consistent national standards for recording pre‑birth risk, domestic abuse exposure, and infant developmental outcomes. Domestic abuse should be recorded as a standalone category, with clear guidance on identifying cumulative harm. The CPA should also publish annual reports on outcomes for babies, including those in kinship care, foster care, and reunification pathways, ensuring transparency and accountability.
Prevention and Therapeutic Support Must Be Prioritised
The consultation highlights £547 million ringfenced for prevention and de‑escalation, noting that this funding will support initiatives such as the Families First Partnership Programme and foster care reforms. Like the Domestic Abuse Commissioner, we are concerned about transparency around the allocation of these funds. We would like to emphasise the importance of therapeutic work with parents, including those using abusive behaviours, and highlight that reunification is more likely when families receive holistic, whole-family, therapeutic, and trauma‑informed support.
A portion of the prevention settlement should be specifically ringfenced for domestic abuse interventions during pregnancy and early years. Parents should have access to trauma‑informed therapeutic support, including programmes designed to address abusive behaviours during pregnancy. We must also stress the importance of ensuring that practitioners themselves have access to therapeutic support, enabling them to sustain trauma‑informed practice in emotionally demanding roles. The CPA should embed this principle within its workforce development strategy.
The CPA Must Address Baby Loss, Maternal Mortality, and Intergenerational Trauma
There is a need to link domestic abuse to baby loss and maternal mortality, recognising that domestic abuse is a known contributor to both, and that the CPA functions to “reduce preventable significant harm and deaths” (page 21). The CPA should work with the Department of Health and Social Care to integrate domestic abuse risk into maternal mortality reviews.
Alongside this, there must be an entrenched understanding of the relationship between adverse childhood experiences (ACEs) and generational cycles of trauma and abuse. These issues are often treated separately from child protection, yet they are deeply interconnected.
Support for at-risk parents, such as teenage parents (who are at high risk of intimate partner violence) or young people leaving care, should be included in CPA guidance. This would recognise the safeguarding implications of their experiences and the need for sensitive, trauma‑informed responses, including for parents concerned about their own behaviours and/or mental health needs. This would be in line with the “updates to the joint DfE-DHSC statutory guidance on promoting the health and well-being of children in care and extending this to care leavers up to the age of 25” as stated on page 19; care leavers becoming parents need specific and trauma-informed support.
Conclusion
The creation of the Child Protection Authority is a vital opportunity to transform outcomes for the most vulnerable children. To achieve its ambition of a truly child‑centred, expert‑led system, the CPA must ensure that babies – especially those experiencing domestic abuse in utero and early life – are explicitly recognised, prioritised, and protected.
Babies cannot speak for themselves; the CPA must speak for them.

