BACP Ethical Framework 2026: What Has Changed and What It Means for You

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From midday today, 3 November 2026, the BACP's new Ethical Framework for the Counselling Professions is mandatory for every BACP member. It replaces the 2018 framework that most of us have trained and practised under, and it is the first full rewrite of the framework since then.

If you are feeling a little weary at the thought of reading another set of changes, you are not alone. This has been a year of them. The UK's data protection law was updated, the regulator changed its name, AI arrived in tools you already use, and now the framework at the heart of your professional life has been rewritten. All of that lands on people who already give a great deal of themselves to their clients every day.

So this guide is written to make it lighter. It walks through the whole framework in plain English: what it is, who it applies to, what has genuinely changed since 2018, what each part asks of you, and what you can sensibly do this week. We give the clause number for every requirement, so you can check anything against the original. And we are honest about where the framework leaves room for judgement, because it often does.

Quick answer. The BACP Ethical Framework 2026 became mandatory for all BACP members at midday on 3 November 2026, replacing the 2018 framework. It has three sections that work together: working ethically within relationships, 12 ethical principles, and core responsibilities. The biggest changes are that you must be able to explain the reasoning behind your ethical decisions, assess the risk of any AI or digital tool before using it, have a clear privacy notice, and have a clinical will with a named executor. Two new principles, compassion and anti-oppression, sit alongside the familiar ones.

Therasee is not affiliated with the BACP. This guide is our plain-English reading of the framework, not legal advice or official guidance. Always read the Ethical Framework 2026 itself, and talk anything uncertain through with your supervisor or the BACP's Ethics team.

Key dates at a glance

The review took four years and drew on member surveys, focus groups including people with lived experience, consultation with courses and services, and the BACP's own data on the ethical questions members and the public had raised since 2018. The BACP published 24 reports along the way, all available on its page about how the 2026 framework was developed.

Who the framework applies to

The framework applies to every BACP member, at every membership level, as the basis of all their professional work. That includes:

• counsellors, psychotherapists and coaches working directly with clients
• supervisors and trainers
• organisational members, and courses and services that are BACP accredited or offer BACP approved qualifications
• members who use counselling skills in another role
• student members in training

It also covers more than your work with clients. The 2026 framework applies to your relationships with colleagues, other professionals, the BACP and the public, and asks members to uphold the good reputation of the profession in all of them.

It matters in a practical sense too. The BACP's Professional Conduct panels use the framework as their reference point when considering a complaint against a member, and the framework itself says that a member's registration may be at risk if they fail to meet its commitments.

The framework and the law are two different things

Before going further, it helps to separate two things that are easy to blur, especially this year.

The Ethical Framework is your professional body's code. It is written by the BACP, it applies to BACP members, and it is upheld through the BACP's professional conduct process.

Data protection law is the law. UK GDPR and the Data Protection Act 2018 apply to anyone who holds information about clients, whatever their profession and whichever body they belong to. They are enforced by the Information Commission (still known as the ICO).

The two overlap more than ever. The 2026 framework asks you to understand and comply with data protection law (clause 3.1b), and several of its new requirements, such as a privacy notice and assessing digital tools, mirror legal duties. But meeting one does not on its own mean you meet the other. If you would like the legal side in the same plain English, our UK GDPR guide for therapists covers it in full.

How the 2026 framework is structured

The 2018 framework had three parts: our commitment to clients, ethics (values, principles and personal moral qualities), and 94 numbered points of good practice. The 2026 framework is shorter and organised differently, into three sections:

• Section A: Working ethically within relationships. How to make ethical decisions collaboratively, and how to explain your reasoning.
• Section B: Ethical principles. Twelve principles that underpin everything else.
• Section C: Core responsibilities. The practical standards of good practice, grouped under four headings.

The BACP is clear that the three sections must be used together, not picked from. It also describes the framework as interpretative rather than a set of rules: it gives you room to respond to different clients and settings, as long as you can justify the decisions you make. That one idea, being able to explain your reasoning, runs through the whole document.

What has changed since 2018

Much of the framework will feel familiar. The heart of it, putting clients first, confidentiality, honesty, good boundaries and supervision, has not moved. What has changed is how clearly some of it is spelled out, and a handful of genuinely new areas. We checked each row below against the text of both frameworks.

Two of these are worth pausing on, because they are often misreported. First, the clinical will is not entirely new. The 2018 framework already asked you to appoint someone to contact clients if you died or became too ill to do so. What 2026 does is name it as a clinical will with an executor, and widen it to any time you cannot contact clients yourself. Second, the prohibition on trying to change or suppress a person's sexual orientation or gender identity was already in the 2018 framework. It continues in 2026 (2.4d), now under the responsibility to protect people from harm.

Section A: working ethically within relationships

This is the section that sets the tone for everything else, and it is the one the BACP highlights first when it describes what has changed.

The idea is simple and very human. Ethical decisions happen inside relationships, so wherever possible and appropriate, you make them with the people they affect, not about them. And because there is often no single right answer in our work, what matters is that you can explain how you reached your decision and why.

Your rationale for ethical decisions

The framework asks you to be able to give a rationale for your ethical decisions: the reasoning behind them, and the factors that shaped them. It describes two kinds of factor.

• Internal factors sit within the relationship: for example a person's age, culture, gender, disability, sexuality, religious belief, race or ethnicity, the nature and context of the work, the contract you agreed, and principles such as honesty and transparency.
• External factors sit outside it but affect it: for example your legal duties, other people involved such as family or other services, and the requirements of any organisation you work for.

Your rationale should answer six questions, which we have put in plain English:

1. What are the ethical issues?
2. How will you involve the person affected in the decision, and if you cannot, why not?
3. Which internal factors matter, and how will they shape the decision?
4. Which external factors matter, and how will they shape it?
5. What did you decide and do, what was the outcome, and was it consistent with the framework's principles and responsibilities?
6. How did you review the process, and with whom?

This does not mean writing an essay about every session. Most of the time, your rationale lives in your thinking and in supervision. It becomes something you write down when a decision is significant, when it departs from what you would usually do, or when someone may later need to understand it. When you do record it, the framework reminds you to keep your confidentiality and data protection duties in mind, and to record it with enough detail to give a clear account of what you decided and why.

Collaboration, and when it is not possible

The framework treats collaboration as a fundamental part of ethical practice, including taking deliberate steps to reduce harmful power dynamics. It suggests a short process: consider whether you can discuss the issue with the person affected, listen to their perspective, reflect and consult your supervisor, consider your legal and contractual duties, then review and record what you decided and why.

It is also realistic about when collaboration may not be possible. It names temporary factors such as a person's capacity, distress, risk or age, permanent factors such as legal constraints or a duty to report safeguarding concerns, people who simply do not want to work collaboratively, and contracts or settings that exclude it. Where that happens, the reasons should be documented.

Section B: the 12 ethical principles

The 2018 framework described six principles alongside a set of values and personal moral qualities. The 2026 framework replaces these with twelve principles written in plain English. The BACP says most remain the same in substance, with two new additions: compassion and anti-oppression.

These principles are not a separate checklist. The framework asks you to use them alongside sections A and C whenever you make an ethical decision.

Section C: the core responsibilities, clause by clause

The core responsibilities are the practical heart of the framework. The BACP describes them as the fundamental principles of good practice without which no professional service can be considered safe, trustworthy or respectful. There are four groups.

1. Build appropriate relationships

• 1.1 Treat people with respect: work in partnership on how you will work together, communicate respectfully and accurately, never take unfair advantage, make reasonable adjustments, avoid assumptions, and treat colleagues, the BACP and clients with kindness and courtesy.
• 1.2 Give people the information they need to make choices: be honest about your services, qualifications, experience and competence, and give people a record of your working agreement.
• 1.3 Keep appropriate boundaries: avoid harmful dual relationships, respect personal boundaries, no sexual relationships with clients, supervisees, trainees or research participants, keep a clear boundary between personal and professional social media, and do not bring the profession into disrepute.
• 1.4 Work collaboratively to resolve ethical dilemmas: be able to show you involved people where appropriate, dealt with issues promptly, consulted your supervisor, and can explain your reasoning.

2. Keep ourselves, colleagues and those using our services safe

• 2.1 Safety: be competent to work with your clients, keep physical, digital and remote meeting spaces private, look after your own safety, and assess the risk of any AI tool, digital tool or online platform before using it (2.1e, covered in detail below).
• 2.2 Honesty when things go wrong: explain fully and promptly what happened and its likely effects, apologise, limit harm and meet any legal obligations.
• 2.3 Your own health and wellbeing: monitor your psychological and physical health, make sure you are resilient enough for the work, and seek support when you need it.
• 2.4 Protect people from harm: have training and safeguarding policies and procedures for adults at risk, children and young people, make sure clients can find them and know who to contact, share information when someone is at risk of immediate serious harm in line with the law, and never try to change or suppress someone's sexual orientation or gender identity.

3. Understand and act on our legal and professional responsibilities

• 3.1 Confidentiality and privacy: keep information confidential, comply with data protection law in your country (in the UK, the Data Protection Act 2018 and UK GDPR), have a clear and accessible privacy notice, and make sure clients know about and agree to any foreseeable limits to confidentiality, including the digital systems you use.
• 3.2 Appropriate records: records that are factual, adequate and relevant, stored securely, and that include all communications and information you hold about a client.
• 3.3 Serious crime and safeguarding: know your legal obligations where you practise and where your clients live, particularly around child abuse, safeguarding, suicide risk and serious crime, and report when you need to.
• 3.4 Financial responsibility: meet your tax obligations, and be clear with clients about fees, how and when to pay, and how and when fees are reviewed.

4. Deliver services to high professional standards

• 4.1 Competence: have the right qualifications, training and experience, discuss your competence in supervision, know the law that applies to your services, keep your skills up to date, and follow the BACP Register's terms and disclosure policy.
• 4.2 Insurance: hold professional indemnity and liability cover for all your UK work, online, remote or in person, and for any cross-border work.
• 4.3 Supervision: check your supervisor is qualified and competent under the BACP supervision competence framework, have regular supervision suited to your experience and caseload, keep it independent of line and case management, and agree who holds key responsibilities for clients.
• 4.4 Fairness: be clear about what you are competent to offer, never discriminate unlawfully, meet equality obligations, and make reasonable adjustments.
• 4.5 Breaks and endings: tell clients about any limits on sessions, give notice of planned breaks and endings, manage unplanned ones to minimise harm, and have a clinical will and executor in place (4.5e).

Technology and AI: the biggest new area

If one part of the framework has drawn the most attention, it is clause 2.1e. For the first time, the BACP's framework addresses AI and digital technology directly. Before using any AI tool, digital tool or online platform, you must assess the risk and be able to show that you:

1. are competent to use it
2. understand how it handles and stores data, the risks to confidentiality, and that you have reduced those risks as far as possible
3. are honest and open with clients about using it, including its benefits and risks
4. have clients' informed consent before putting any of their personal data into AI or digital tools
5. have not handed your decision-making to AI, and stay responsible for checking anything it produces

Why this matters more than it might seem

It is tempting to read this as a clause about ChatGPT. It is much broader than that. "Digital tool or online platform" covers the everyday tools of modern practice: video platforms, practice management software, online forms, messaging, cloud storage and email.

The BACP's own research shows why. In its 2024 survey of members on technology in therapy, which drew 4,976 responses, 84.8% of members said they saw at least some clients online, most often on Zoom (67.7%) or Microsoft Teams (33.4%). At the same time, 84.6% said they did not knowingly use AI in their practice. That word "knowingly" matters. Many everyday tools now include AI features, such as automatic transcripts, meeting summaries and writing suggestions, and they are not always obvious. Part of meeting 2.1e is finding out what your tools actually do.

Members' concerns were clear in the same survey: 66.4% were worried about the accuracy of AI recommendations, 65.9% about not understanding how AI works, 64.2% about data privacy, and 62.6% about bias. The 2026 framework is, in a sense, the profession's answer to those worries: not a ban on technology, but a requirement to understand it before you rely on it.

Consent before personal data goes into AI or digital tools

Point 4 is the one we are asked about most. Read literally, it asks for informed consent before a client's personal data goes into "AI or digital tools", which could include a great deal of ordinary practice software. The framework does not define the boundary, and the BACP has said more supporting resources are on the way.

Until then, a sensible approach is to be open in your privacy notice and working agreement about every system that holds client information, explain it in plain words at the start of your work together, and record the client's agreement. The framework already asks for this kind of transparency in 3.1d. For anything involving AI specifically, ask for clear, separate consent, and never paste identifiable client information into a consumer AI tool. Talk the detail through with your supervisor, and keep your reasoning, because that is exactly what section A asks for.

A simple way to evidence it

For each tool that touches client information, keep a short written note: what you use it for, who provides it, where the data is stored, whether you have a data processing agreement, whether it uses AI and how, how you have told clients, and the date you last reviewed it. One page per tool is plenty. It covers 2.1e, it supports your rationale under section A, and it also covers your legal duty to choose providers who protect client data properly. Our GDPR guide explains the legal side of this.

Privacy notices and records

Two quieter changes may take the most practical work for some practitioners.

Your privacy notice (3.1c and 3.1d). The framework now asks every member for a clear and accessible privacy notice, explaining how personal data is collected, used, stored and protected, and what rights people have. It should also tell clients about any foreseeable limits to confidentiality, including legal duties to disclose and the digital systems you use that may monitor or collect data. If you already have a privacy notice, read it again with fresh eyes against this list. If you do not, this is the single most useful thing to write this month.

Your records (3.2). Records must be factual, adequate and relevant, stored securely, and must include all communications and information you hold about a client. The BACP's glossary is helpful here: it defines a record as including notes, appointments, emails, text messages, social media comments, photographs and recordings, and it notes that the law draws no distinction between factual notes and process notes. In practice, that means the messages you exchange with clients belong in your records and deserve the same care as your session notes.

Clinical wills (4.5e)

From today, every BACP member must have a clinical will in place and have appointed an executor who, bound by confidentiality, can communicate with clients if you cannot contact them yourself, or if you die. The BACP's glossary describes an executor as usually a trusted colleague, a specially appointed trustee, or a supervisor.

It is not a comfortable thing to plan for, and many practitioners have put it off for exactly that reason. But it is one of the kindest things you can do for your clients: if the worst happens, they hear from someone who cares, rather than from silence. Our guide to clinical wills walks through choosing an executor and what to include, with a free template.

What to do now

You do not need to do all of this today. The framework asks for thoughtful practice, not perfection overnight. If it helps, here is a calm order to work through it:

1. Read the framework itself. It is about 4,000 words. An unhurried hour with a cup of tea is enough. The PDF is here.
2. Put your clinical will in place, if you have not already, and confirm your executor has agreed.
3. Review your privacy notice against 3.1c and 3.1d, including the limits to confidentiality and the digital systems you use.
4. List every digital tool that touches client information, and write a short note for each against the five points in 2.1e.
5. Check your working agreement gives clients a clear record of how you will work together (1.2b), your fees and how they are reviewed (3.4b), and how to find your safeguarding policies (2.4b).
6. Bring your records together, so that messages and other communications sit with your notes (3.2c).
7. Take it to supervision. Talk through anything you are unsure of, and check your supervision arrangement against 4.3.
8. Look at the BACP's new resources in its Ethics Hub, including the Ethics Essentials, and contact its Ethics service if you are unsure about a dilemma.

2026, 2027 and beyond

It would be easy to treat today as a finish line. It is really a new starting point.

The BACP describes the Ethical Framework as a living framework that can respond to changes affecting the profession, such as new legislation or research. On 3 November 2026 it replaced its old Good Practice in Action resources with three new collections in its new Ethics Hub: Ethics Essentials, Ethics in Practice and Legal Resources, with more guidance still to come. Those resources will shape how the framework is read in practice, particularly on AI and digital tools.

The world around the framework is moving too. Data protection law changed in 2026 and the regulator has been restructured. AI tools are changing month by month. Other professional bodies, including the UKCP, NCPS, BABCP and the HCPC for practitioner psychologists, are updating their own guidance at their own pace.

We do not have a crystal ball, and nobody honestly can say exactly what 2027 will bring. What we can promise is that we will keep watching. We will keep this guide up to date as the BACP publishes new resources, and log every meaningful change at the bottom of the page so you can see what has moved since you last read it.

A note from us at Therasee

We know this can feel like a lot. Most people come into this profession to help others, not to keep track of data law, AI policy and a rewritten ethical framework in the same year. Every change asks for a little more of your time and attention, and that time has to come from somewhere.

That is a big part of why we built Therasee. It is a UK practice management platform made for counsellors, psychotherapists and psychologists, and it is designed around what professional bodies and the law expect of you, so that the right way of working is also the easy one:

• Your records in one place. Notes, forms, secure messages and invoices are kept together in one secure system, stored in the UK.
• A clinical will built in. Every plan includes a clinical will, so you can name your executor and set out what they can do, inside the system that already holds your client records.
• Clear agreements. Send your working agreement, consent and intake forms for clients to read and sign online, and keep the signed copies on file.
• Technology you can explain. Therasee is registered with the ICO, includes a Data Processing Agreement on every plan, and its AI features, including speech to text, run on enterprise services that never use your data for training. That makes the note you keep for 2.1e straightforward to write.

And because frameworks and laws will keep changing, so will we. When a professional body or the law makes a significant change to what it expects, we will update Therasee to match, and explain clearly what has changed and what, if anything, you need to do. Our aim is simple: that you can feel confident your practice is on solid ground, and spend your energy where it matters, with your clients.

If you would like to see how it works, you can explore Therasee's clinical will or start for free.

Updates to this guide

We will log every meaningful change here, so you can see what has moved since you last read it.

• 3 November 2026: First published, reflecting the BACP Ethical Framework for the Counselling Professions 2026, which became mandatory for BACP members on 3 November 2026.

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Nick Evans is the co-founder of Therasee, the UK-built practice management platform for therapists, counsellors, psychotherapists, and psychologists. Therasee is registered with the ICO (ZB610705), stores all client data in the UK, and includes a Data Processing Agreement and a clinical will on every plan.