No.
Two duties came into force on the same day — recording a significant use of force under the Education and Inspections Act, and recording seclusion or restraint under the 2025 regulations — and schools have understandably read that as two forms for one incident. The regulations say the opposite in terms. Where an incident falls under both, it is recorded under the use-of-force procedure only, and the seclusion and restraint procedure need not deal with it at all.
updated 1 Jan 2025last checked 22 Aug 2026
What the source actually says
The overlap rule, in the regulations themselves:
“6. A procedure under regulation 4 (1) need not provide for any action to be taken in relation to a seclusion or restraint incident that also constitutes a use of force incident within the meaning of section 93A of the Education and Inspections Act 2006 ( 7 ) and therefore falls to be recorded under the procedure that is in place at the school in accordance with that section .”
— The Schools (Recording and Reporting of Seclusion and Restraint) (No. 2) (England) Regulations 2025, reg. 6 legislation.gov.uk
The explanatory note puts the same rule in one sentence:
“Regulation 6 of these Regulations provides that, if an incident would qualify to be recorded and reported under both section 93A of the 2006 Act and these Regulations, it need only be handled under section 93A.”
— The Schools (Recording and Reporting of Seclusion and Restraint) (No. 2) (England) Regulations 2025, Explanatory Note — which is not part of the Regulations legislation.gov.uk
The same exemption is written into the independent school standards, so it is not a maintained-school quirk:
“(3) The procedure under sub-paragraph (1)(b) need not provide for any action to be taken in relation to a seclusion or restraint incident that also constitutes a use of force incident within the meaning of section 93A of the Education and Inspections Act 2006 and therefore falls to be recorded under the procedure referred to in sub-paragraph (1)(a).”
— The Schools (Recording and Reporting of Seclusion and Restraint) (No. 2) (England) Regulations 2025, reg. 7, inserting para. 16A(3) into the Education (Independent School Standards) Regulations 2014 legislation.gov.uk
Both duties bite from the same date, which is why they arrived together:
“(2) These Regulations come into force as follows— (a) this regulation and regulation 9 come into force on 9th January 2026; (b) the rest of these Regulations come into force on 1st April 2026.”
— The Schools (Recording and Reporting of Seclusion and Restraint) (No. 2) (England) Regulations 2025, reg. 1(2) legislation.gov.uk
Note the instrument number. An earlier version was defective and has been revoked:
“9. The Schools (Recording and Reporting of Seclusion and Restraint) (England) Regulations 2025( 10 ) are revoked.”
— The Schools (Recording and Reporting of Seclusion and Restraint) (No. 2) (England) Regulations 2025, reg. 9 legislation.gov.uk
The exemption only runs one way and only where both apply. An incident that is a seclusion or restraint but not a significant use of force is still recorded under the 2025 regulations.
Your school may still require it
Your school can lawfully ask for both forms anyway — a single procedure that logs everything in one place is a defensible design choice, and so is a belt-and-braces one. What the law does not do is make the second record compulsory, so “the regulations require it” is not the reason for it.
See also Do I have to write up every time I use force on a pupil?, Do I have to record stopping a pupil if I never touched them? and Is putting a pupil in a room on their own 'seclusion'?.