The present Children’s Commissioner for Wales’ response to the CWS Bill can be found here:

Leaving aside the whole issue of routine surveillance of children not being effective and even counterproductive, and of the concerns raised elsewhere about her predecessor’s insistence on “seeing” children and her use of the UNCRC in justifying this,

Leaving aside for the moment the presumption that her predecessor’s “three tests” are all roles and duties of parents, who shouldn’t be routinely placed under suspicion or surveillance…

other than to correct that it is for parents to “see” children, to advocate for them, to ensure their needs are met, to protect them,

including advocating for their right to private family life and a suitable education rather than enforced state-style provision.

 Other than to clarify that is parents and families who listen to their children’s views and experiences, that we do not co-parent with the state,

Two further points jump out,

Firstly,
Absolutely, the Children’s Commissioner for Wales is right, there should be a full Children’s Rights Impact Assessment (CRIA) of the Bill’s implications for Wales,
but this needs to be produced in a meaningful way and released well BEFORE the Senedd can possibly consider debating whether to apply the relevant clauses of the CWS Bill to Wales.
Especially bearing in mind that the English version has been considered “not fit for purpose” –

Time has to be allowed not only for a well-constructed CRIA to be developed, based on consultation and engagement with the community that would be affected,

But also time has to be allowed for Senedd Members to be able to fully appreciate and digest this, including by comparing it to first hand accounts from home educators in their area.

Secondly, we fully agree with “the importance of ensuring full and meaningful engagement and consultation with children, young people and their families in Wales”,

But disagree with this only being AFTER the vote on such a controversial and problematic Bill,
To only involve the people of Wales after the Senedd votes on these powers,

to only do so “when drawing up the regulations or statutory guidance for Wales”,

would be remarkably after the fact.

Surely full and meaningful engagement should already have taken place even before considering “piggybacking” onto this Bill at Westminster, let alone about contemplation of the decision to do so.

Surely engagement and consultation should be about whether or not to take steps,

Not merely on how to tweak steps once taken on people’s behalf without involving them.

Especially bearing in mind that even the present Cabinet Secretary for Education had to agree with the Legislation, Justice and Constitution Committee that mutual past experience had found “secondary legislation inadequate for proper scrutiny of legislation”