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© Copyright, Victims Commissioner 2026.

A new Victims’ Code: consultation response

Published:
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This submission sets out the Victims’ Commissioner’s response to the Ministry of Justice consultation on a revised Victims’ Code. The submission draws on engagement with victims, bereaved families, specialist support services, and criminal justice professionals to assess whether the revised Code will meaningfully improve victims’ experiences.

The Victims’ Code focuses on victims’ rights and sets out the minimum standard that organisations must provide to victims of crime.

The 2026 Ministry of Justice consultation sought views on proposed updates to The Code of Practice for Victims of Crime in England and Wales (Victims’ Code).

The consultation ran from 5 February 2026 to 30 April 2026.

Further information:

Executive Summary

Purpose and Context

This submission sets out the Victims’ Commissioner’s response to the Ministry of Justice consultation on a revised Victims’ Code. The Code is central to victims’ experiences of the criminal justice system (CJS), yet evidence consistently shows that victims’ rights are poorly understood, inconsistently delivered, and weakly enforced.

The submission draws on engagement with victims, bereaved families, specialist support services, and criminal justice professionals to assess whether the revised Code will meaningfully improve victims’ experiences.

While the Commissioner welcomes the ambition to strengthen the Code, the submission concludes that without systemic reform, robust accountability, and genuine cultural change, the revised Code risks remaining aspirational rather than transformative.

The victims’ code gave me a false sense of hope. I thought that if the code wasn’t upheld, I could complain and find a meaningful solution.  However, currently there are no repercussions for agencies failing to uphold the code. This needs to be rectified for it to hold any real meaning or the code is redundant.
Victim of coercive control

Key Findings

1. The Victims’ Code is poorly implemented and inconsistently applied

  • Victims frequently experience superficial or “tick‑box” compliance rather than meaningful delivery of their rights.
  • Awareness of the Code remains very low among victims, limiting their ability to understand, exercise or challenge unmet rights.
  • Fragmentation across criminal justice agencies undermines consistency, communication, and accountability.

2. Lack of enforcement and accountability is the Code’s greatest weakness   

  • Systems and processes for monitoring and oversight of the Code’s implementation remain weak, with compliance mechanisms lacking reliable data, independent scrutiny, victim feedback and adequate capture of victims’ lived experience.
  • Victims are often forced to self‑advocate or navigate complex complaints systems when rights are breached.
  • The 2004 Domestic Violence, Crime and Victims Act gave the Victims’ Commissioner a clear statutory role to keep the code under review. The new Victims and Courts Bill extends this by giving the Victims’ Commissioners Powers to scrutinise compliance with the Code.  Yet without a system of national data collection, this is unenforceable.  

3. System fragmentation drives poor victim experience

  • There is no single system or agency responsible for navigating and supporting victims through the criminal justice process.
  • Multiple agencies operate in silos, with separate IT systems and unclear ownership of victim communication.
  • Victims are repeatedly required to retell their story and re‑explain their needs.
  • Information gaps between police, CPS, courts and probation frequently leave victims uninformed and unsupported.
  • Too often, victims feel abandoned, having to navigate a complex system alone.

4. Marginalised victims experience compounded disadvantage

  • Trust in the criminal justice system is significantly lower among victims with protected characteristics.
  • Disabled victims, D/deaf victims, migrant victims, victims from minoritised backgrounds, and victims of VAWG face additional barriers to access, understanding and participation.
  • The Code does not consistently translate equality duties into practical, enforceable action.
  • Significant gaps across the system in supporting child victims including lack of child advocacy services and specialist training for CJ agencies.

5. Failures in victims needs assessments:

  • Needs assessments are inconsistent, police‑led, overly procedural, and too often fail to result in tailored support to victims.
  • Many victims do not recall having had their needs assessed.
  • Assessments are rarely shared between agencies or reviewed over time.

6. Poor communication and information sharing:

  • Poor communication is one of the strongest drivers of victim distress and disengagement.
  • Victims value clarity, explanation and human contact more than frequent automated updates.
  • Digital innovation risks depersonalising the system if poorly designed.
  • Victim services provide vital support to victims but statutory services often fail to collaborate with them.

7. Lack of Victims Voice and participation

  • Victims tell us they want to feel heard in the justice process. But many feel they have no say.
  • For many victims, procedural justice is valued just as much, if not more, than a criminal justice outcome.
  • Opportunities for participation are often poorly explained, procedurally driven and not trauma-informed.
  • Victim Impact Statements (VIS) are highly valued but undermined by their evidential status.
  • Lack of information and support to enable victims to be informed about sentencing, parole, and release processes.

Key Recommendations

Implementation and oversight of the Code

1. Make the Victims’ Code enforceable and accountable

  • Introduce robust, transparent monitoring and oversight of Code compliance across all criminal justice agencies.
  • Move beyond tick‑box compliance to measuring quality and impact, including routine collection of victim feedback.
  • Finalise and implement the Code compliance monitoring framework under the Victims and Prisoners Act without further delay.
  • Strengthen complaints and redress mechanisms, with clear lines of accountability for breaches and meaningful consequences for non‑compliance.
  • Properly resource the Victims’ Commissioner to provide independent scrutiny and victim‑led monitoring of Code delivery.
  • Develop a Code specifically for statutory services, making clear their responsibilities and standardising good practice.

2. Deliver culture change, not just procedural reform

  • Do not raise expectations through an ambitious Code unless delivery is properly resourced with clear accountablility.
  • Embed trauma‑informed, victim‑centred practice throughout.
  • Success should ultimately be judged by victims’ experience, not simply by compliance statistics.

Needs Assessment & System Design

3. Reform how victims’ needs are assessed

  • End reliance on inconsistent, police‑led, one‑off needs assessments that encourage a procedural, tickbox approach.
  • Embed needs assessment as a continuous, evolving process that follows victims through their journey in the justice system.
  • Develop a standardised, bestpractice (gold standard) needs assessment, co‑designed with victims and specialist services.
  • Ensure needs assessments:
    • Are trauma‑informed and victim‑led
    • Do not act as gatekeepers to support
    • Avoid stereotyping by offence type or perceived vulnerability
  • Introduce routine review points, particularly where victims disengage, delays occur, or circumstances change.

4. Introduce an end-to-end Victim care model

  • Implement a Victim Care Hub as a single, independent point of contact to:
    • Coordinate communication
    • Track needs and rights delivery
    • Support navigation of the justice system
    • Refer victims to support services
    • Troubleshoot issues to keep victims engaged and justice progressing.
    • Use data collected by the Victim Care Hub to inform and improve justice agencies performance.
  • Introduce a Victim Unique Identifier to:
    • Reduce repetition
    • Enable information‑sharing across agencies
    • Improve continuity, safeguarding and accountability
  • Use needs assessment data to inform commissioning and funding of specialist services, particularly by‑and‑for provision.

5. Meet the needs of marginalised groups

  • Design the Code around those most likely to be excluded
    • If the Code works for the most marginalised victims, it will work for all victims
    • Intersectionality must be built in at every stage.
  • Move away from “neutral” delivery models
    • Standardised, one‑size‑fits‑all processes should be replaced with flexible, victim‑led approaches.
  • Shift responsibility back to agencies not victims
  • Systems, not victims, must adapt.

6. Improve engagement with Children and Young People

  • Move away from rigid age‑based categories and instead prioritise capacity and capability to engage.
  • Ensure direct engagement with children is the norm, not the exception
  • Provide specialist training and resourcing for statutory agencies working with children.
  • Expand investment in specialist child advocacy, including CHIDVAs and CHISVAs.

Communication & Case Information

7. Transform how information is communicated to victims

  • Prioritise quality, clarity and explanation over frequency of updates.
  • Require agencies to explain:
    • Decisions (including charging and NFA decisions)
    • Delays and adjournments
    • What processes mean in practice
  • Implement the Victim Care Hub model to facilitate this.
  • Clarify responsibilities between police, CPS and Witness Care to avoid gaps.

8. Ensure digital tools are victim‑led

  • Any digital portal must:
    • Be optional, not the default
    • Complement—not replace—human contact
    • Be accessible, secure and trauma‑informed
  • Sensitive information must always be delivered personally first.
  • Embed the Victim Unique Identifier into any digital offer.
  • Guarantee consent, data security and transparency including around AI use.

Participation, Voice & Procedural Justice

9. Reform Victim Impact Statements (VIS)

  • Acknowledge the critical value of VIS while recognising current harms caused by their evidential status.
  • Stop pressuring victims to submit VIS at early, traumatic stages.
  • Improve information to victims on VIS and how they are used. 
  • Provide victims with:
    • Realistic expectations
    • Flexibility to provide additional and / or later statements
    • Appropriate support when preparing statements
  • Explore and implement alternative formats (e.g. video) where appropriate.

10. Strengthen victim participation in sentencing and beyond

  • Consult victims on offender attendance at sentencing, with decisions being victim‑led.
  • Improve understanding of sentencing, release and appeals through:
    • CPS‑led explanations
    • Clear, accessible materials
    • Joined‑up communication post‑conviction
  • Ensure victims can access special measures at sentencing and beyond, including via live‑link.

Post‑Conviction & Protection

11. Improve the Victim Contact Scheme (VCS)

  • Strengthen automatic referral processes so eligible victims are not missed.
  • Implement the Victim Care Hub to support in the offer of the scheme.
  • Allow genuine choice over updates while prioritising safeguarding.
  • Ensure communication preferences and needs are shared across agencies.
  • Strengthen probation resource in relation to VCS so they can deliver on their VCS duties consistently.

12. Centre protective orders and safety throughout

  • Make protective orders much more visible in the Code.
  • Require agencies to consult victims when applying for, varying or discharging orders.
  • Ensure victims understand what protections are available regardless of conviction.

Code Awareness & Accessibility

13. Re‑design how victims understand and access their rights

  • Low awareness reflects design and delivery failures, not victim disengagement.
  • Make Code awareness:
    • Ongoing, not one‑off
    • Supported by explanation, not just signposting
  • Promote the Code beyond the justice system i.e. GPs, schools, community settings.
  • Ensure accessibility for D/deaf, disabled, marginalised and criminalised victims.
  • Recognise that many victims disengage early or never report—and shape awareness strategies accordingly.