Submission by Childminding Ireland on the Child Care Act 1991 (Early Years Services) Childminding Regulations 2024 (Regulations)

1. Introduction:

Childminding Ireland is the national association of childminders. We are a not-for-profit organisation run specifically to provide guidance and support to childminders in all aspects of their activities. In addition to supporting childminders for over 40 years, Childminding Ireland has been to the fore in advocating for the equitable inclusion of childminding in childcare policy. Childminding Ireland represents Ireland’s childminders and is governed by a Board of Directors that is comprised of childminders and people with experience of childminding. Over 600 childminders, that are members of Childminding Ireland, are fully insured, trained in first aid, child safeguarding and are Garda vetted. In addition, Childminding Ireland are in contact with another 2,914 childminders and 6,908 parents using childminding services.

At the heart of any consideration of policy around childminding must be a basic acceptance that childminding is different from other forms of childcare. Unlike centre based childcare or corporatised childcare settings, childminding is distinct in providing the best quality childcare in a home from home setting for the benefit of over 53,000 children, their families, and their communities. Home based care mirrors the atmosphere and flexibility of family life and allows children to grow and develop in a homely setting.

The childminders consulted were passionate about safeguarding children, their safety and wellbeing and would welcome a system that supports these priorities. Childminders also appreciate the importance for families of having access to subsidies for their childcare costs, however any new system and subsidies must be workable in the context of childminding.

2. Feedback to the consultation process

In completing this submission to the consultation process, we engaged extensively with childminders so that their perspectives, hopes and concerns could be accurately and authentically represented in our submission.

There is huge unease, concern, and complete opposition to the draft Regulations among childminders. The common theme in the response from childminders is that they felt that the new Regulations are seeking to capture childminders within a regulatory context that is more suited and designed to centre-based or corporatised childcare.

We believe that the Child Care Act 1991, Part VII A, Supervision of Early Years’ Service, is an inappropriate legislative platform on which to base a regulatory structure for childminding, as it was written for centre-based childcare.

3. Lack of proportionality

Childminding Ireland also believes that the regulatory structure proposed is not proportionate and that the consultation process will not enable the State to assess the proportionality of the measure. Consequently, Childminding Ireland believes that the new Regulations will run counter to Directive 2018/958 and will effectively disproportionately restrict access to the provision of childminding.

In particular Childminding Ireland would argue that the Public Consultation Process cannot be considered as a contributor to the ‘State’s assessment of the proportionality of the proposed regulation of childminding’ for the following reasons:

Although presented as a Public Consultation there was no national promotion about the draft Regulations. While Childminding Ireland engage with our members and childminding contacts, there are likely to be a significant number of childminders entirely unaware of the proposed changes to their businesses, and their views are not being captured. Equally parents using the services of these childminders are not being meaningfully consulted.
The Public Consultation Survey focused on only 4 of the 26 draft Regulations. A narrative box for additional comments is not a sufficient replacement. In addition, many childminders have reported finding the questions asked as incredibly leading with very limited options for making a response other than to accept the proposition which is proposed.
Feedback from childminders suggested that the Public Consultation Focus Groups, mirrored the questions raised in the survey, and as a result at most of the Focus Groups there was little discussion on the wider issues within the draft Regulations.
Another theme that emerged from childminders feedback is that the draft Regulations have ‘many gaps’ such as the lack of detail in relation to the proposed Schedules and what they might contain, and that the draft Regulations appeared ‘rushed and incomplete’.
The consultation was seen as being asked to comment on measures that did not include numerous salient pieces of information. Childminders were invited to only consult on 4 Regulations without critical information being included for review, for example Quality Development Programme and Suitability requirements. It is clear that the draft Regulations in their current form are not proportionate, are not appropriate, and are not suitable for a childminding setting.
The proposed system of regulation is not appropriate to support and enhance the many benefits that childminding currently affords to thousands of children and their families.
This is the feedback from extensive engagement with childminders on the draft Regulations. Childminders voiced their shock and disbelief at the content of the draft Regulations, they feel they are a copy and paste of existing centre-based Regulations and do not reflect or recognise their home from home settings. For details on the specific issues raised by childminders in the Online Get-Together meetings held by us please see attached Appendix 1.

4. Benefits of childminding

It is important to highlight what is potentially at risk if the regulation of childminding does prove to be disproportionate and/or inappropriate. The benefits to children of being minded by childminders include:

Childminding allows a child’s individuality to flourish (Ang et al., 2016; Freeman & Karlsson, 2012), thanks to the one-to-one attention and care each child receives (Garrick et al., 2010); Ahnert et al., 2006).
Children develop optimally in the secure relationship and secondary attachment bonding with their childminders (Bowlby, 2007).
Children thrive in childminding settings helped by smaller group sizes, which is an acknowledged marker of quality in childcare (Laevers et al, 2016; Clarke-Stewart et al, 2022).
Toddlers and babies in particular flourish in the low stress environment at the childminders (Dalli et al., 2011).
Childminding has been shown to lead to better outcomes for children in terms of well-being, language, and socio-emotional development (Otero, 2015; Melhuish et al., 2017; Russell et al., 2016).
Children enjoy a home from home environment (DCYA, 2017; Shannon et al., 2014) as provided by childminders.
Children benefit from the security provided by the continuity of care possible with childminders from babyhood to teenage years (Sure Start 2004; Tonyan, 2017).
Children can be taken out and about and benefit from being part of the local community and experiencing the world in a real way (Bromer, 2011; Garrity et al., 2017).
There are fewer instances of sickness amongst children minded by childminders when compared with children in large group childcare (McGinnity et al., 2013).
Childminding is also valued as an appropriate setting for children with additional needs, who can receive the extra care and attention they need with a childminder (Coplan et al., 2010).
Since childminding services are so varied, parents can choose childminders that match their own parenting style, and the needs of their family (Fauth, 2013).
The parents and the childminder can agree the details of the childcare required, including shift work patterns, such as overnight or at weekends, allowing for flexibility (Brooker, 2016).

5. No incentives for childminders

The National Childcare Scheme is of no direct benefit to childminders – it may facilitate parents with funding the cost of childminding, but only in circumstances where there are childminding services available to do so.

The constant feedback that we have received from childminders suggests that the new regulatory structures and the accompanying administrative requirements will drive many childminders out of the service. There will not be the adequate cohort of childminders available to offer childcare spaces to parents. The State will effectively have regulated the sector out of existence by presenting disproportionate, misdirected and wholly inappropriate regulatory requirements and stipulations. This will have been as a consequence of the State seeking to overlay the regulatory structure for centre-based childcare on childminding, despite the vastly different operational and childcare contexts.

These new Regulations will also introduce a major administrative burden for childminders, in addition, childminders are very aware of the issues that have arisen in small childcare services in terms of administration and the lack of financial sustainability. Many childminders that formerly worked in centre-based settings deliberately switched to childminding to spend more time with children and less time on administrative bureaucracy.

The incentive for childminders to start childminding will be gone, as will the freedom, independence, spontaneity, and flexibility that childminding offers children and parents alike.

Being at home with your own children will now impact the sustainability of your business, as you will be required to count your own children up to the time they start secondary school. We know that being able to be at home with their own children is a big incentive, one of the biggest reasons childminders decide to start childminding.

6. Parents access to childcare subsidies.

If it is the Government’s intention to increase subsided childcare places, childminders believe that these regulations will have the opposite effect, in that there will be a mass exodus of childminders resulting in greatly reduced childcare availability, disproportionately impacting women and their participation in the workforce.

In addition, the administration system of NCS is not suitable for childminders, it does not suit irregular working/part-time hours of parents, as a result remaining childminders are unlikely to offer the NCS.

There will be further pressure on an already struggling childcare sector if childminders stop offering childminding places in their homes.

Childminders in their family homes will be subject to Inspections by Tusla, Pobal inspections (if offering NCS) and possibly further down the road subject to Department of Education inspections.

7. Conflicting with National Policy

These Draft Regulations fail to meet the following stated Aims of National Action Plan: –

• That the children, families, and communities of Ireland can experience the benefits of quality childminding in a relationship-based, home-from-home, family life environment.

• That the life-learning, continuity of care and flexibility that quality childminding provides is acknowledged, supported by the development of an appropriate quality assurance system that protects and enhances this long-established and respected model of childcare

For childminding to survive it needs experienced childminders to be retained and new childminders to be recruited.

It is our firm belief that these Draft Regulations would lead to a mass exodus from childminding and childminding will no longer be an attractive proposition for new childminders, post regulation. From our recent survey of childminders that attended the online get togethers, 94% said, they did not believe that the Draft Regulations were appropriate, proportionate, or specific to a childminding setting. (5% answered don’t know, 1% answered Yes).

These Draft Regulations fail to meet the following recommendations of the Joint Oireachtas Committee on Children, Equality, Disability, Integration and Youth in their Report on challenges facing the Early Childhood Care and Education Sector March 2024:

“Recommendations……

8. The learnings coming from recent developments in centre-based provision, particularly around the need for flexibility and measures that account for the bespoke needs of unique models of provision, should be acted on and taken forward into the developments for childminders.

10. The Regulations that are developed for childminders should be proportionate, appropriate, and specific to the setting of childminding. The childminding sector should continue to be involved in their development.”

No learnings have been taken from recent developments in centre-based care. These Draft Regulations do not recognise or support the unique provision of childminding. As previously stated, neither we nor childminders who have shared their views with us (please see Appendix 2), believe that these Draft Regulations are proportionate, appropriate nor specific to the setting of childminding.

Childminding voices have not been listened to in the development of these Regulations. Childminding Ireland surveyed 3 of the 4 childminders that sat on the Regulations and Supports Advisory Group, all responded and stated that they did not support the recommendation put forward from their group.

In addition, these draft Regulations are actually more onerous that the current Early Years Service Regulations 2016 (Pre-school Regulations) applicable to Tusla registered childminders. Some examples:

Count their own children.
Only allowing 2 children under 2yrs
The overall ratio limit imposed.

8. Conclusion

Childminding Ireland believes that the draft Regulations are not fit for purpose in providing a supportive structure for childminding in Ireland. We feel that they have been crudely advanced on a centre based childcare regulatory model and fail to take adequate account of the specific setting and priorities concerning childminding in a person’s own home.

The public policy imperative for supporting and developing childminding must be based on an evidence-based approach rather than a doctrinaire commitment to secure regulatory equivalence between centre-based and corporatised childcare and childminding.

There has been no detail provided on the evidence upon which the proposed regulatory structure has been based and this is evident in the misdirected and misinformed nature of the Regulations.

Instead of providing a proportionate and targeted basis for facilitating the growth and development of childminding, the measures will drive childminders from childcare and create a wholly different problem than the unspecified challenges that they are seeking to address.

Consequently, Childminding Ireland recommends:

That Draft Childminding Regulations are substantially amended, revised or otherwise they should be withdrawn.
That the childminding exemption within the Child Care Act is not removed until such time as there is an appropriate childminding structure created.

Childminding Ireland as always is committed to working with the Department to find solutions to the challenges.

Appendix 1

Feedback gathered from childminders on the individual draft Regulations.

Childminding Ireland held 8 online Get-togethers attended by a regional spread of childminders. The below feedback represents themes that emerged over the course of the 8 Get-Togethers.

Draft Regulation	Examples of the Feedback received
Part I
Preliminary and General
Regulation 1 -Title and commencement	Objections characterised as ‘Childminding is being shoe-horned into existing centre-based legislation’
Regulation 2 – Interpretation	Childminders object to being legally referred to as a Registered Provider – this is centre-based terminology – they are childminders and should be recognised as such. There is no distinction between childminding and centre-based childcare.Childminders strongly reject the term ‘Premises’ when referring to their homes. They childmind in their home and would expect their home to be legally recognised. Childminders fear the unintended consequences such legal descriptions could have on them, for example be subject to Commercial Rates, Planning permission requirements, Fire Safety requirements, Capital Gains Tax. etc. The description of premises in the draft Regulations could lead to childminding taking place in a range of locations different to the family home.
Regulation 3 – Prescribed early years’ service	Childminders are not Early Years Services and should not be described as such under regulation. Childminders are strongly opposed to losing their unique identity, and caution about the problems that have arisen in other small settings.
Regulation 4 – Fees	Missing information, no amount given in the draft regulation.

Part II
Registration and Register
Regulation 5 – Registration of childminding service	(1), (2) and (4) refer to Schedules that contain no information.What is the difference between (1) and (2)?(3) a minimum of 3 months’ notice required before starting to childmind is unrealistic.(4) error in sequence (a) (b) (a)(4) (d) directed to Schedule 5 – contains no information.(5) and (6) missing?(7) repetition of (4)(a)?(4) (ii) refers to ‘all persons over the age of 16’ and (7) ii refers to ‘all adults’?(7) (c) directed to Schedule 5 for information on declaration on suitability – no information available.(8) (e) How is the suitability of the person applying decided?
Regulation 6 – Register	Childminders raised a number of issues including: Why are childminders asked to give the age profile of the children they mind – childminders mind children at whatever age and stage the children are at – pre-school and after school care.Childminders object to their personal information being available online – may be suitable for a business premises but should not be applied to a family home.
Regulation 7 – Certification of Registration	(5) The original certificate of registration is issued by Tusla, so Tusla can confirm this on their own system as necessary.
Regulation 8 – Application to vary terms of registration	(1) Proposed changes to the register at least 60 days’ notice before the proposed change takes place. Considered to be impractical given the flexible nature of the role. (2) Proposed changes to the Emergency cover at least 60 days’ notice before the proposed change takes place. This is not practical. (4) Application form directed to Schedule 4 – no information provided.

Part III
The Childminder
Regulation 9 – Training	and (2) no information provided. ( c) child safeguarding? Childminders are being asked to sign up to a Quality Development Programme that has yet to be developed, no specifics of this training are available nor who is creating the training.
Regulation 10 – Assessment of suitability	(1) Directed to Schedule 5 no information available. (2) ( c) On what basis would an interview be held? Who would be present in the interview? Childminders are strongly opposed to being interviewed. (d) More clarity is required on the information that Tusla would be collecting on individuals. A system of appeals is needed.

Part IV
The Childminding Service
Regulation 11 – Health, safety, welfare, and development of the child/ren	(2) remove ‘learning and development’ . Well-being of children is a broad description. Numerous childminders do not want to deliver a curriculum nor to have to write observations, they are working single handedly and the majority view has been against this. Childminders want to continue to offer children the freedom they need while their being minded.
Regulation 12 – Maximum numbers of children	(1) (a) This regulation will make childminding unsustainable for those with their own pre-school children or children at primary school. Often childminders begin childminding when they have young families, this could negatively impact the recruitment of new childminders. (b) Why have the Regulations changed from 2 children under the age of 15 months? Will premium rates be offered in State subsidies for minding children 2 years or younger? (2) Is there an appeals process for this Agency decision?
Regulation 13 – The home setting	(1) ( c) cleaned, maintained, and repaired as required – further details required. (d) Built as family homes, the sanitary facilities will be designed primarily for family use – not a centre-based purpose-built building.
Regulation 14 – Supervision	Benefits of childminding include the family environment and members of the childminder’s family often support the childminder through school runs, activities etc. It’s about relationship building as well.
Regulation 15 – Emergency cover	(1) Impossible to meet compliance – unrealistic that a volunteer cover person will remain close to the childminders home at all times.
Regulation 16 – The Childminding service Handbook	Directed to Schedule 3 – no information available.Individual policies and procedures should be limited to a page in length at most. Are the policies listed in the Explanatory Guidance finalised? Many do not believe that there is a need for this handbook?
Regulation 17 – Food and drink	Again, the worry if childminders are described as Early Years providers operating from a premises, the onerous requirements expected of centre-based provision, could be applied to childminding homes. Many parents send food in with their children – are childminders to be expected to audit the food that parents have chosen for their children?
Regulation 18 – Insurance	Why are ‘Fire and theft’ included?What would be the legal implications in relation to insurance be, for example if you are minding 2 children and 1 of your own children? This could this invalidate household insurance that covers only childminding for 2 children?

Part V
Information and records
Regulation 19 – Record of the child	(2) (b) Limited information should be available to the Emergency Person. ( c) Who is an authorised person?
Regulation 20 – Record in relation to the childminding service	Many childminders objected to having to register their own children in and out even if not providing NCS. (3) (b) Who is the authorised person? Age -profile is not appropriate for a childminding setting.
Regulation 21 – Information for parents	Not necessary to distribute to parents that you are not in contract with.

Part VI
Notifications and complaints
Regulation 22 – Notification of incidents	(C) If not providing State subsidies why is this necessary?
Regulation 23 – Complaints	More suitable for a centre-based setting.

Part VII
Inspection and enforcement
Regulation 24 – Furnishing information to the Agency	More detail is needed on the information required.
Regulation 25 – Inspection	This should read The Agency shall recognise that childminding takes place in a home-from-home setting and in a family environment,Childminders object to the term “home-based nature” Childminders require advance notice of inspections as they are single handed and will need the support of the emergency backup person to mind the children while they work with the inspector.Will the inspectors have specific experience of childminding?Childminders requested mentoring rather than inspection visits.
Regulation 26 – Enforcement and execution	There is no detail as to what penalties or fines will be issued for non-compliance.

Appendix 2

Examples of written comments received from childminders.

The draft regulations are very vague and not giving you all the information we need to be fully informed. They are very much not based for childminding. We work in our homes not a childcare facility. We need the regulations to take this into consideration.

The regulations make me feel like the government want us all to be an early year setting and this is unrealistic. Parents choose to go the route of a childminder because they want their children cared for in a HOME. Not an early year setting.

Better I will return to the playschool.

Childminding should be supported and developed. I have experienced Childminding over the last 23 years initially as a parent and in the last 7 years as a minder and what is proposed will destroy childminding. Taking away choices from parents and family is totally wrong. I don’t see how any of this is a help to parents. I thought this would be a good thing and give recognition and support to childminders but it’s going to drive them out. This is totally heartbreaking because of all the lost opportunities that could be available developed and enhanced to create a better world for parents and families.

Proposes regulations are just off the wall.

If the proposed regulations come into force without a doubt I will be quitting childminding.

The draft regulations are not fit for purpose. Childminding should not be treated or subject to the same regulations as crèches. Childminders provide care from babies up to secondary school. It should not be structured but as close to home as possible. Many of the proposed regulations are not compatible with childminding in the home.

Legal mandate for an emergency contact to give up their daily lives and voluntary commit to be available at all times to substitute for a childminder is completely unworkable. Essentially the draft regulations are asking that two separate people are available to give full time care to particular children – one without compensation for their time.

My home is a home and not a crèche. Parents come to my home and inspect it before they leave their children there. Surely, it’s more important that they are happy with the environment that their children are being cared for in so why do childminders need to be further inspected? Parents choose a childminder as they want their child cared for in a home setting. If they wanted an early years setting, they would choose a crèche or play school. As a childminder I have years of experience and qualifications and yet the minister will require childminders to undergo more training. Will this training cost the CM as well as registration fees/ Insurance etc it will not be financially viable to operate as a CM. At first CM were given the impression these new regulations would benefit CM and recognise what CM do and it’s actually the opposite as it feels like we are being put under a microscope and our roles as CM are being undermined.

I think a lot of childminders will close their childminding businesses if these regulations come in as they are.

I am a registered childminder and would not register under the present draft childcare regulations. These regulations have no proper structure and can be easily mismanaged and misinterpreted. They are not carried out in consultation and participation with childminders but by officials whose main objective is to use the draft regulations as a tick box exercise. What childminder would feel confident with these loose so call regulations. Childminders work long hours and are dedicated to the children in their care. We childminders deserve to be respected and given proper recognition; we are not a tick box exercise. Please please please respect us and our profession because at present no childminder would approve these so-called childminding draft regulations, they do not represent me. I am absolutely furious as a childminder in Ireland today.

Regulations are only suited for crèche not a home setting. They are too vague and not taking in that it’s also my home.

Childminding in essence is caring for children at HOME. It is an extension of family in a HOME setting. Parents choose childminding over day care for these reasons. The new regulation as is about putting more pressure into carers and transforming a home into a day care centre with all the admin and pressure that is already so heavy on creches. As a one-person business this is ridiculous.

The new Childminding Regulations should be drafted from scratch, specifically for childminders- not a “copy & paste” of preschool regulations for centre-based care.

I need to see home not setting etc.

I feel the draft proposals are geared for creche based & not home base with the use of words like premises instead of home, like wording of early learner provider, Childminding is not teaching role, it is that of a caring role which the child grows in many ways, I would welcome training if suited to Childminding & have realistic goals, I personally don’t want to be taking time from the care of the child to carry out unnecessary paperwork, I would welcome inspection of my home in the confidence that I supply a safe & caring home to the children but would not welcome unrealistic settings that would turn my home into a creche.

If the childminding draft regulations go into effect, I will hang my childminding hat after 15 years of childminding, building my business and a good, trusted name for my services, as its connection, communication with children, parents, and families, who I would provide it for. For all does past years. Sadly, on my side it will be the end of my service and leaving already struggling parents without childcare they are all allowed to choose for their little ones.

The Draft regulations are already trying to generalise childminding and putting it into the same Category as ELC, Centre based Services. Childminding is different and the dept have been saying that regulations will be proportionate and appropriate for childminding and childminders homes, but they are not and as the regulations are being developed, it is assumed that all childminders are uneducated and require training on a job that they may have been doing for years. The government really has a distorted view of what childminding is and how it takes place in a family home. Until they really understand that the regulations will fail, and the sector will collapse, adding to the already stretched and stressed parents.

I work as a Childminder, believing it is my profession, and I’m proud of what I have had the opportunity to do. It’s always being my intention to register on Tusla, however it is not correct for the Government to “regularize/change” the Childminding Regulations, simply to plug a hole caused by government failings/ineptitude/inefficiency. The problem won’t be solved making things difficult, when the proper Government do not have appropriate public policy, to attend the demand in Early Education. I aim to continue this work for many years, but I do not wish to be a scapegoat when the government itself does not take care of this demand properly. I prefer to fight for the recognition of Childminders as an essential profession in Ireland, as opposed to being a stopgap where we are only valued when there’s no spot in a creche. I believe it is important to say that I’m not against regulation of Childminders, but that actual proposal of “Childminding Regulations”, aren’t going to fix the problem and make it harder for Childminders like myself.

Every Childminding setting is unique, whilst it’s a home away from home for the children we mind, they become a part of our home, these regulations in no way, shape or form recognise that bond, that flexibility the home away from home uniqueness, the Govt need to think again about the regulations, the draft is just not up to scratch for Childminding. It will not do the profession of Childminding any good unless they begin at the beginning with Childminders only driving the way forward.

I fear registering with Tusla will become very expensive. Add on the additional and on-going training and modifications to our homes then the childminders net income will be diminished. When you reflect on the long hours currently worked and then consider the amount of paperwork required, childminders income will greatly be reduced in value.

We need specific regulations for childminding.

In my opinion TUSLA are not the right body to govern childminders, their NCS is anything but efficient and childminders will be left without their wages if my own experience in the public sector is to go by.   TUSLA keep changing the parameters for NCS and core funding and I don’t think that childminders would be able to cope with all the red tape.

I am currently registered with Tusla, I am mithered with paperwork. I do find my particular Tusla inspector is very mindful that it is my FAMILY HOME and allows for this (despite what the regulations (preschool regulations) state. She has informed me that if she applied the preschool, regulations to the letter she would be having me do lots of alterations and changes to my home. But she can see that I do keep my home safe. that the children have plenty of lovely equipment all (age appropriate) available to them, plenty of freedom and space and that there is a lovely “home from home ” atmosphere. But if I was starting out anew, I would not sign up to the “new to Childminders” regulations as they are just the ‘same ol’, ‘same ol’ preschool regulations being foisted on family home and do nothing but cause stress for the family trying to live in that home. So I would walk away from childminding…which would be a blow to families here in semi-rural area ….this will happen all over Ireland and those “knowledgeable” personnel who cobbled this farcical copy of regulations together and tried passing them off as “new childminding” ( technically correct- but just playing with words!!)regulations – will have a hell of a lot to answer for when childcare system in Ireland collapses…Good Luck to them. They have paid no heed to any advice childminders gave during so called “consultation” processes over the past 3 years and have bullishly continued on path they set for themselves years ago. Absolute disgrace and I sincerely hope they lose their jobs for the bad decisions they have made…as many childminders will lose theirs and them parents of children will also have to give up work due to childminders no longer being available.   I will be sitting on the sidelines -with my popcorn – watching as the blame game show commences…. I reckon that will be very interesting.

More paperwork and regulations make less childminder available in the society. We are offering home from home. Any home doesn’t need this much of control from the government. Especially this society need childminders who mind babies and toddlers as this age group isn’t creche’s financial merit also small children benefit more from home environment than institutionalised setting. Many people also mind neighbours’ and friends’ children. And many of us mind only 1 or 2 children. It’s absolutely limited income we can expect. In many cases it’s not like we can call it business be honest. It’s very silly to bring this regulation to this really small setting. We are offering home.

I am very disappointed that we have an opportunity to regulate childminding and showcase the fantastic impact childminders have in supporting families in Ireland and enabling children to flourish in the home setting their parents choose for them to allow parents to work and secure their future. But these guidelines do the opposite in trying to create mini creches. Clearly whoever drafted these doesn’t understand the benefits of childminding or the needs of childminders.   Very sad after 20 years of pretending to listen to parents and childminders.

It’s what the government want and what they can manipulate parents to think that’s what they want but it’s not in best interests of anyone…definitely not the children.

If these regulations come into effect, I will close my doors because I’m left with no choice. As these regulations are all about ticking boxes not about the kid’s, parents, or childminders.

The wording in the draft regulations is too vague to be able to accurately understand what it means for childminders going forward. As stated, it requires a huge level of trust on the part of the childminder that the government will take into account that these are our homes and that is trust that I simply do not have.

These draft regulations are not proportionate to a domestic childminding service, and I WILL LEAVE childminding if they are brought in.

I don’t think the government are thinking of childminders and the children they care for. Parents want their children to have a home from home experience that’s why they want childminders and not a Creche setting.

From the outset it was promised that they’d be appropriate & proportionate for a home setting. The draft that has been presented is just a copy & paste of the current preschool regs with a few alterations. And it’s shocking this is what they’ve come up with considering the action plan was back in 2019!! Waste of time having all those meetings & focus groups! The draft definitely does not suit the individualistic home setting we work in every day, of which the parents are seeking as an alternative to centre-based care. They want a home from home environment, but these new proposed regs will erode that environment. We don’t want to turn our HOMES into creches!!!

I am already Tusla registered but definitely against these regulations. We are such a unique service in that we all mind children differently in a way that works for the families that use our service and the department just want us to fit into one big box when we don’t fit.

We need registration specific to Childminding.

The draft regulations make the future of childminding very uncertain.

I’m happy as it stands for registering with Tusla, be Garda vetted and have first aid and have policies and procedures in place. If they do bring in a draft it has to be a standalone draft only for child minding and no other organisation it’s not a one fit all.

Would really need the support of all the parents as they will be the ones most affected.

As I’m retiring soon, I won’t be registering with Tusla but am still interested in how the childminding sector is been changed in the further.

I’ve been childminding in my own home since 2007 and have worked in crèche for 10 years previous to this. Since these proposed regulations were published it’s the first time in 27 years that I have seriously thought about leaving the childcare sector.

we are different than day care centre. We are childminders, we should not be included in the same legislation – it is not appropriate.

There should be a non-statutory registration system, and NOT REGULATIONS

Emergency contact should be EMERGENCY, cannot be sitting at home waiting for an emergency to happen – this is ridiculous. We don’t check if someone is vetted when we have an accident in the street. We just do what we can to keep people safe. I would put all my neighbours in the emergency contact so that I am sure someone is around if I need but I can’t ask them all to be vetted!! I know how regulated and how difficult the creche rules are, the poor staff is pressured to make so much admin, this is ridiculous. I won’t register if I have to run my home-based care service as a day care centre, itis inhuman.

I am a woman; I work alone and there will be children in the house. I do NOT want my address on view to the public as that not only puts myself in danger but the children too. Also, if I wanted rules and regulations – I would be working in a creche, this is not a creche it is my home. I work for myself so if I want to change my hours of work that would be up to me, not Tusla. These new rules and regulations are actually ridiculous.

I don’t agree with our address bring made public. Some childminders have partners who are Gardaí or in defence forces. We are also working solo all day & these are our homes, where our children also live. We should be the ones deciding who has our address. Regulation 8doesn’t state what needs to be notified. What if we can’t give 60 days’ notice? We are flexible as a childminding service & adapt to fit in with parents. The Part VII of childcare act is written for centre-based services. What happened to us having our own regulations?!!!

Reg 9 + 10: Yes, I agree with the Children First E Learning program and Paediatric First Aid Training. But I do not agree with the continual ongoing training similar to that imposed on childcare workers in centre-based services. Again, there is no information as to the training required. As there is no Schedule drawn up, yet we do not know what we are being asked. Or the implications of agreeing to a regulation when the minister can change and alter regulations after we have registered. Only that it is deemed by the minister, who can also demand training in areas and beliefs totally contrary to those of the childminder.

There’s no clarity as to what a minister may deem appropriate. Is the department trying to force childminders to undertake ongoing training as seen in other childcare centre-based facilities. What are the costs involved, will this training mean extending childminders working day by forcing us to undertake such training without monetary compensation. Is the department trying to force childminders into a role outside of their current responsibilities.

I agree, childminder need training BUT light trainings, easy to do at home on our own time for flexibility and at NO extra COSTS! DO you interview pregnant parents before they have their baby to see if they are suitable to be parents? If a childminder has the training, the vetting, and recommendations, you cannot leave the final decision to a person, it is very subjective, too much room for personal involvement. THIS IS NOT OK!

This will be a barrier for any new childminders.

It should be so that if we already hold childcare qualifications these are recognised as adequate training. With regards to the “interview” this is ridiculous. The parents are conducting their own interviews when we meet them. They wouldn’t entrust us to care for their children if they thought we weren’t suitable.

What a disgusting and disgraceful way to treat us when we offer excellent service

Reg 11 opens the door to a curriculum being expected by childminders. infants and toddlers should never be subjected to a curriculum, or goals and achievements being expected of them preschoolers and school age children should be free from lesson plans in the childminders home. As this should be down time for the children. Let them explore and develop at their ease. Will childminders be expected to write up reports on children. how can we mind our children if we are writing up reports on them. I open from 7.30 to 7.30 to facilitate a mum working in retail. I also open Saturdays for her. I do not have time to write up reports after I close as the other mandatory paperwork will take up so much time Reg 12: may reduce the flexibility the childminder can offer to the parents. Reg 15: is unworkable. I as a childminder cannot expect someone to be constantly available to me during my opening hours. How can someone commit to this on an ongoing basis without monetary compensation. this is not something that I could afford to do in any form.

We are working fine as we are.

As self-employed person different things happen in our life’s, and we need flexibility. So therefore, informing Tusla of everything that happens is not feasible. We will no longer be treated as self-employed we will be treated as employees.

If these regulations are enforced, I will stop childminding.

majority of these regulations are taking away from the “home from home” experience that childminding is all about

I will not allow anyone to come into my home and tell me how to run my business after 20years.

I don’t agree with majority of what is being proposed, if they go ahead, I will be at a total loss of income, financial burden, time consuming regulations. The stress will become too much which is exactly the reason I could no longer work in a creche based environment.

If the Minister’s position is to destroy in home childminding in Ireland, then these regulations will achieve that aim. If, however, he wishes to avoid decimating childminding in Ireland then he needs to take the grave concerns of childminders into consideration and work with childminders.

It is my home; I am helping my community by proving a care that is not available in our town. I have 5 spaces and 20 families requested my service!! it’s a human-to-human service. Yes, regulation is good but DO NOT forget what a childminder is. Parents are responsible. Cover us more with proper wording and contract and legal support but don’t burden us of admin and rules that cannot be acceptable for our family’s life. You are running the childminding world with these regulations. do not put us in the same bulk as early years providers and day care centres. I want to do it right, I want to provide NCS, I want to provide quality care, so I agree with training and support but not with being told how to live, how to breathe. Ireland needs more care, help us help families!

These new rules and regulations are going to make it very hard for childminders to stay in business. I agree the likes of first aid is important, but I just want to mind children in my home without rules. If I wanted such rules and regulations which completely take the fun from the job, I would work in a creche. I will be holding off registering for as long as possible. I am up to date with training, insured and qualified with contracts and certain policies and over 20yrs experience. that should be enough, this thing of having to have a fire map displayed in my own home is ridiculous. As if in the event of a fire I will stop to look at that to see where the door is in my own home. honestly like.

Too much work on top of childminding, I will retire.

it is too unclear at present what EXACTLY will be put into these regulations. I am Tusla registered…only because it is the rules to do so when taking on the fourth preschool child. But I have phone calls weekly looking for care…and I can see after 25 years minding children that the most important thing to parents is whether they can trust you with their child. I have never once been asked for qualifications, or whether I am garda vetted or insured by any parent. They have also never asked for the NCS. people just want to know they are leaving their child with someone they can trust and will love their child as they do. I HONESTLY hope the agency listens to the minder of Ireland and their parents. understanding that there is a huge lack of childcare places so those of us who are there should be appreciated and not pushed out by paperwork and regulations…it is our home …that is what the parents like about it…they love that they can start their 6mt old baby with you and you will mind them for the next 12 years possibly…we are a part of their family as much as they are of ours. I also would like to mention that I feel a sibling clause should be considered. what is a childminder supposed to do with a parent who is pregnant and you have no space for their child? currently I have a family who I have the two children…mum is pregnant with third but I will have no space for the child….he will have to go to go to a different setting …minded separately from his siblings??? This I find crazy and should be addressed. another point I would like to raise is the lack of flexibility with the ratios. take for example when there is a cross over of an hour between one child being dropped and another being collected…it will put you over the ratio for that hour, but it will be of benefit to the parent rather than finding somewhere else for the child for one hour? and the other setting does not want the child for just one hour either as it could mess up their ratios also

I am a home-based childminder, and I don’t intend to register with Tusla as I feel the service I am providing is a home for home and the parents of all the children I have minded are very happy with my services and have taken up my service feeling happy with what I provide. I do not need any agency/Tulsa telling me what to do. I am helping out families and I explain from the get-go how I operate. Therefore, when I take on a child the parents are happy and content. ….. I provide a home from home environment and that has been enough for any of the parents of children I mind. I am happy in what I do but if things are to get too political for me and I am going to be told this & that about my service to childminding after 20 plus years ‘I will give up’ I do not need the hassle. I understand for service providers outside of the home crèches etc then things should probably be different.

It is likely that I will retire (unwillingly) from Childminding before the 3-year period for registration has ended.

Will not be registering, am going to close my setting down., within 3-year period.

I personally feel that I will no longer self-employed, and my time will be consumed with admin.it will give me no choice but to step away from childminding and seek alternative work.

I’m currently registered and I plan on staying registered.

These regulations don’t recognise childminders they are trying to change them.

Too many regulations for childminders.

There is way too much paperwork, and regulations for what most childminders and parents are looking for, I entered into childminding to offer a home away from home for children, not to provide a creche facility.

I will probably leave the service leaving an extra shortage of childcare in this country. Absolutely ludicrous what they are trying to make us do. Why fix what’s not broken very hurt and disheartened of the whole situation.

They are totally disproportionate to what I do and are designed to fail. I would rather go to jail first. This will totally destroy childminding in Ireland, leaving it open to a monopoly by largescale corporations.

I’m hoping to have left the childminding at that stage.

Not interested in becoming Tusla registered so I gave up childminding.

Parents chose childminders because we offer a flexibility that centre based childcare services cannot, but these regulations are constricting the flexibility we have always given. Parents also choose childminders as they do not want “Institutional Childcare” and would prefer that their children are minded in a Home from Home environment.

Parents who choose to use childminders instead of childcare centres do so because they want their children to have as close to home environment as possible. That is not possible if the childminder has to spend a considerable amount of time filling out paperwork and progress reports. Our role is to be the second “mammy” to these children. It is also vital that children are allowed breathing space away from monitored, rigid learning and just be kids. Let them learn by observing and imitating and keep structured learning for when they start school.

I have been childminding for many years, registered with Childminding Ireland. they have always offered support and any advice when needs. I think with a lot of the regulations stated that there is going to be a lot of admins and that the home away from home care is going to change…not sure I will continue when all the changes come about.

I am self-employed in my own home. Set my own fees. Flexible daily to parent’s requirements. Home setting is sought. My home is my home not a separate building creche facility. Regs are completely not suitable for a childminder setting. I will not continue if these regs come in as too much paperwork and not feasible for me to operate to these rules. I have successfully built a high reputation and self-enrolled in courses and qualifications to enhance my business and these regulations are not sustainable for a sole trader in private home.

I care for children in my home, I provide a family experience, all these regulations will take away from that with all the red tape attached. It will take the caring out of it & treat it like a business not a home environment.

I will be closing my doors in 2026, the regulations are not suitable for childminding in a home.

Childminding came to me when I retired from foster care. I had one child then with a waiting list of 20 at our local creche I had 2 children then a sibling. I can’t take anymore and work 4 days a week, I would like to stop but parents can’t find childcare, I’m registered with Childminding.ie for supports and knowledge, I can carry out updated courses with them and I’m fully insured. I worked with Tusla and won’t again.

It seems to be a lot of work, which I imagine will need to be kept up. The fear would be that it will push a lot of amazing childminders out due to the administrative side.

These regulations are not for childminders in a home from home setting and in my opinion will need to be radically changed to convince the majority of childminders to be on board with them. They are predominantly directed to centre based and purpose-built settings and are not conducive to a childminder carrying out the very important profession of caring for children in a home-based quality setting. There is an onus of a lot of extra unnecessary paperwork whereby a singlehanded childminder along with possibly their own children to look after too, perhaps taking up much valuable quality family time in their evenings or detracting from the quality of care that childminders provide for their mindees. I firmly do not believe that these regulations as is, are fit for purpose in a family home. However, I do think that there does need to be some in place that are not so strict and regimental that offer guidance for the wellbeing of the children and their families, but especially so for the positive mental wellbeing of the childminders who would otherwise be anxious and stressed out by this burden. Children sense these feelings acutely therefore it is not good for them either.

This is exactly what I don’t want. It will make my home a centre-based facility and not a home from home.

I am my own boss I take care of other children to the best of my ability. My childminding is a home from home environment. I will not become subject to any rules set out by an “agency “.

I feel that too strict regulations will prevent many capable, trained, and lovely childminders to do this job. These regulations seem to fit a small business where a minder takes care of 6children. It absolutely cannot fit childminders that care for one or two kids alongside own children. We’re not an early childhood setting. We’re a house that opened up and welcomed in the children of one or two families. I’m totally up for childminders needing childcare qualifications and first aid courses. Totally up for having contracts and keeping some form of records. But this is way too much. It’s daunting!

I feel as a childminder for the last 13 years and provided a very good caring service to many children in my close net Town. That these regulations are going to destroy it and the home from home childcare will be gone. To be honest our job is very tiring as it is, rather than creating more unnecessary work for us keeping policy’s that us or our parents are interested in. Only keeping a Tusla working in a job, who prob hasn’t minded a child in their life. For me, the care and attention will be given to the children in my care not to silly paperwork and Tusla.

My childminding service is a home-to-home environment. There is no need to change what we are already doing. more focus needs put on minders who are not registered!! We work long hours on little food and toilet trips we don’t have time for inspectors or courses! We have a life outside of our job also! I will definitely be giving up childminding when these regulations come into force! The demand is high in my area an as explained to parents it just won’t be viable for me or my family! My parents don’t care about the extra help with cost as long as their kids are happy, and I think staying with childminding Ireland were doing a fantastic job before all this nonsense started! Too much paperwork and things that are not even needed!!!

This is pushing childminders out of a business that is very much needed, we are here for families from 1 hour a day to 10-hour days. Starting at 7 am in the mornings. We are flexible home from home. Treating kids like our own kids letting them sleep wherever they fall asleep like they do at home. Watch tv colour bake plant flowers day by day its different I am called mammy. I am cuddled I mop up tears fix bobo. Just like their mammy dose my husband is loved more than me. My kids are like big brother and sister. My families love my flexible care and love fir their kids. Don’t fix what’s not broken…

These regulations, the non-existent communication process, the so-called consultation process are all unfit for purpose. I would encourage every stakeholder in this to get onto county councillors and TDs immediately to object to the introduction of these proposed regulations. They will destroy childminding in Ireland, leading to no diversification in the market for parents.

These proposed guidelines are not tailored to childminders childminding in their homes. I’m so disappointed that the Tusla creche setting guidelines are mirrored in these childminding suggested guidelines. They are totally different setups and regulations need to differ appropriately – e.g. the safe sleep guidelines need to be more realistic in childminders homes…we do not have cots for the sole use of children resting. If the parents are happy to allow the child nap in their buggy – this is what is sufficient. Applying to change mindees takes 60 days’ notice – again this is impractical as children come and go more often. Why is there a change in ratios – again, confusing the childminding ratio again – now in these regs – only 2 children can be aged under 2 years – up to now it’s no more than 2 children under 15 months —Why this change? Childminders are not about learning and development of children; they are caring for them like a second mother would love them and nourish them. This childminding handbook is too formal and corporate for what our service is. All records are too formal – again we are a home from home, not a creche tied up with all of this paperwork. There is just too much red tape for all of these required records to keep. And lastly, everything is made public which is unnecessary, and I strongly disagree with this and unannounced inspections. Inspections are welcome when they are planned, not when they are unplanned.

They are taking the HOME element out if childminding. The flexibility, the family feel. Parents go to a childminder as it is a home from home setting. Children mix with different ages and a minder can mind all siblings in the same place. This will not be possible if the new regulations come in.

There is nothing in these regulations that would entice me to become a childminder if I wasn’t already working as one. When I did my QAP 12 years ago I was assured my role was to provide a home from home environment for the children in my care All the families in care for have chosen me above a creche for that reason

These proposed legislations are not compatible with a home setting. They will systematically destroy the childminding sector. And once we all step back from the childcare sector, the people proposing such nonsense regulations will be left to deal with the tsunami that will ensue.

Regulations proposed do not represent what a childminder/childminding is all about. We provide a home from home that is 100% what parents are looking for. All the children we look after while in our care also become a part of our family. It is also not what parents want from a childminder if that were the case they would send their children to a centre-based service. A lot of Childminders will cease to operate if these regulations come into effect without being amended to suit ‘childminders. We should have the option not to have to register with Tusla if minding 3 or less children as it stands presently. Why fix what isn’t broken? It should not become compulsory as set out in draft regulations. Also, why should we be inspected and have these reports available to the public with personal information. Where is GDPR for us childminders and for the families we look after. I as a childminder for 20 plus years am 100% against this.

There already is a major lack of childcare available for people especially babies, creches are full and waiting lists for years. If they enforce these regulations people have and will walk away, I will be one those people and this really saddens me I have worked as a childminder for 4 years in my own home registered with my local childcare committee before this I worked as a preschool teacher for 13 years.   What the government is outlining doesn’t benefit the childminder at all it only adds extra work stress and pressure in our homes.   Our homes should be a safe and stress-free place for all the family not somewhere strangers can come in without notice. We as childminders work for less than minimum wages long hours with hidden expenses i.e. heating electric car and home insurance and groceries. We welcome children into our homes to provide a home from home experience and they become part of our family on a daily basic and that’s what parent want. Alot parents don’t want a creche experience for small babies I personally have worked in 4 different creche and would not like my baby go into a creche We are not a premises or a crèche indeed of you worked in a creche you would have office staff cleaner cook to assist with all we are expected to do ourselves Alot add expense on us too like computer to be brought and storage for all our paperwork We should be given a medal for our dedication and help to families not made do this. Alot people will be out work and a lot of people will not be fit to work as there will be no childcare for babies.

My home is not the same as a creche or daycare setting. The children I mind are safe, happy and love to be in my home from home environment. All parents are happy with level of care and environment provided also.

I think this will be the end of children going to a homely environment where they literally become part of the family and are loved and cared for by a motherly figure, in my own experience I have had children now in secondary school who still call for a chat and a cuppa.

These regulations aren’t going to work. A lot of childminders aren’t going to go ahead with it. There will be an even bigger childcare crisis!

These proposed legislations are not compatible with a home setting. They will systematically destroy the childminding sector. And once we all step back from the childcare sector, the people proposing such nonsense regulations will be left to deal with the tsunami that will ensue.

These dots quickly scroll the page Top Bottom

August 28, 2024

admin

Childminders, Sector