COVID-19: Church of England “Step 4” Guidance

On the afternoon of 16 July 2021, the Church of England updated its COVID-19 Guidance and in our post COVID-19: Church of England update, we provided links to the new and revised documents:

This subsequent post includes extracts of some aspects included in the 12-page document Opening and managing church buildings in step 4 of the Roadmap out of Lockdown, V.1, (“the Guidance”); readers are nevertheless urged to read the full document.


The release of this Guidance coincides with the Government’s move to Step 4 of its roadmap on the 19th July, and it is only applicable from that date; the document will evolve as further guidance is published by Government and other bodies that link with the life as a Church. It is important, therefore, to use the most recent version, as indicated by the date and version number, and to take note of the changes in the box in the header.

The move to Step 4 was enabled, legally, by the snappily titled The Health Protection (Coronavirus, Restrictions) (Steps etc.) (England) (Revocation and Amendment) Regulations 2021, SI 2021/848 which come into force at 11.55 p.m. on 18th July 2021. Extracts from the associated Explanatory Memorandum are reproduced in our post COVID-19: Revocation of regulations in England.

Although the Department for Business, Energy & Industrial Strategy, Cabinet Office, and Ministry of Housing, Communities & Local Government issued new guidance on Wedding and civil partnership ceremonies, receptions and celebrations: guidance from Step 4 and COVID-19: arranging or attending a funeral or commemorative event, but at the time of writing, the MHCLG document COVID-19: guidance for the safe use of places of worship and special religious services and gatherings during the pandemic had not been updated since 16 June 2021.

Overview of the Guidance

“In this guidance we will try to highlight sensible measures that should apply to most church situations following the latest guidance we have from Government departments and public health bodies. In addition we will provide a risk assessment template that aims to help parishes decide if additional measures are needed, taking into account those vulnerable in a community as well as (for example) local infection rates.”

“A clear rationale will also help with communicating why additional measures may be taken, and why these measures will vary from place to place and event to event. In every situation there is likely to be a range of feeling about risk, both to ourselves and to others, that will need to be accommodated by our churches in a way appropriate to each of them. Online and hybrid worship services have opened up opportunities in this regard and local practice at services may differ to accommodate different groups of people”.

“This document is intended to be a first step in thinking about future practice in relation to coronavirus and public health, briefly covering a spectrum of church activities and signposting where further information can be found.”

“The relevant parts of Church of England guidance for most situations have been gathered in this single document. Where further measures may be considered by local churches we will link to appropriate additional guidance. If issues covered in previous guidance are not included here it is because they are no longer a specific consideration in Step 4.”

General approach within the Guidance

“The responsibility for making decisions about how to proceed lies with the incumbent. This applies to acts of worship, to events run by the PCC or church community, and to decisions on whether to hire out spaces or allow other events to proceed. Incumbents should feel empowered to make locally appropriate decisions, including taking different approaches to different types of services and events where the risks may vary”. Assistance may sought from the Archdeacon.”

“[I]t is important that the person acting as the ‘venue manager’ carry out a risk assessment. This is part of keeping yourself, volunteers, staff and visitors safe. You can use the template and guidance provided in the government’s Events and Attractions guidance, or you can use the Church of England’s own template, whichever works best for your context. You can also create your own assessment or re-use a previous template so long as you ensure the assessment is up to date and regularly reviewed”.

“Everyone has a different set of criteria by which they judge whether they feel safe in different situations. For many people, the relaxation of restrictions is a source of significant anxiety. This could include members of clergy, lay leaders, PCC members, members of congregations and of our wider communities, and care should be taken not to make assumptions about how someone else is feeling about moving to Step 4.

Clergy and lay leaders with specific needs or anxieties which may mean they are unable fully to exercise their ministry should speak to their Bishop or Archdeacon. The NHS has provided some tips on coping with anxiety about coming out of lockdown.” The document list seven steps churches may consider to ensure they provide a safe and accessible space.”


Aside from the general approach within the Guidance, supra, most of the legal and practical issues to be faced by congregations and clergy during Step 4 are included in this first version of the Guidance. Given the overall responsibility of the incumbent, some of the advice such as that on singing and bellringing is necessarily ambivalent, allowing choices to be made at the local level. However, with regard to Holy Communion, the approach of the Roman Catholic Bishops in England and Wales to retaining Holy Communion under one kind, and the suspension of the physical Sign of Peace seems more appropriate where infection rates are continuing to rise.

Given the short timescale and the apparent intractability of some of the issues, full credit should be given to those responsible for putting the document together. Whilst there will be those who disagree with certain aspects, it must be borne in mind that this is only “version 1”.

The guidance comes into effect on Monday, at which point the majority of existing guidance notes on the C of E website will be removed, as they will have been superseded.

David Pocklington

Cite this article as: David Pocklington, "COVID-19: Church of England “Step 4” Guidance" in Law & Religion UK, 16 July 2021,


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