Coronavirus related Legislation:
Briefing for churches in Wales

Every effort has been made to verify the accuracy of this information, but it should not be relied upon for the purposes of legal advice.

Regulations for places of worship in Wales from June 7 2021 (Level 1 restrictions)

Wales began to move to Level 1 restrictions on June 7 2021. Welsh Government has published detailed guidance for places of worship, and those responsible for places of worship are urged to read it carefully. However, this guidance has not yet been fully updated for Level 1.

It remains lawful to arrange to arrange worship in places of worship. The Public Health (Coronavirus Restrictions) (No. 5) (Wales) Regulations, as amended on June 4 permit a place of worship to remain open.

According to clause 16 of the regulations, in the context of COVID-19 the principal additional legal duty of the ‘person’ (which can be a body such as a PCC) responsible for the building is to:

1(a) take all reasonable measures to ensure—
(i) that a distance of 2 metres is maintained between any persons on the premises (except between members of the same household or a carer and the person assisted by the carer);
(ii) where persons are required to wait to enter the premises, that a distance of 2 metres is maintained between them (except between members of the same household or a carer and the person assisted by the carer),
(b) take any other reasonable measures for that purpose, for example measures which limit close face–to-face interaction and maintain hygiene such as—
(i) changing the layout of premises including the location of furniture and workstations;
(ii) controlling use of entrances, passageways, stairs and lifts;
(iii) controlling use of shared facilities such as toilets and kitchens;
(iv) otherwise controlling the use of, or access to, any other part of the premises;
(v) installing barriers or screens;

(vi) providing or requiring use of personal protective equipment, and
(c) provide information to those entering or working at the premises about how to minimise the risk of exposure to coronavirus.
(2) Measures that may be taken under paragraph (1) also include—
(a) not carrying out certain activities;
(b) closing a part of the premises;
(c) allowing and enabling a person who ordinarily works at the premises to isolate for a specified period due to testing positive for coronavirus or having had close contact with somebody who has tested positive, where that person—
(i) has been asked to do so by the Welsh Ministers;
(ii) has been required to do so by a notification given by a contact tracer;
(d) collecting contact information from each person at the premises and retaining it for 21 days for the purpose of providing it to any of the following, upon their request—
(i) the Welsh Ministers;
(ii) a contact tracer
(e) taking reasonable measures to ensure that such contact information is correct.

There are, of course, other legal requirements – such as general health and safety, safeguarding children and vulnerable adults, data protection, and so on – which remain in force also, and they should not be forgotten when making arrangements to re-open.

Welsh Government has drawn up detailed guidance regarding implementing these legal requirements. Clause 18 of the regulations places a duty on the ‘person’ responsible for the premises to have regard to this guidance (and other relevant Government guidance – see below). It is important, therefore, that the ‘person’ responsible reads this guidance carefully.

There is no upper limit on the numbers who may attend an act of worship – each place of worship should calculate a safe maximum within the Regulations above and enact it. However, according to Schedule 1 Section 4(3)(c)(iv) a congregation of more than 30 is not permitted indoors unless the service is held in premises ordinarily used for that purpose. See under FAQs below regarding using buildings other than places of worship for the purposes of worship.

In arranging the place of worship or meeting place so that each household maintains a 2m distance from other households, it should be noted that the members of an extended household may sit together. Currently (at Level 1) any three households (of any size) may form an extended household, and one additional household containing only one adult (with or without children) may join that extended household. Each household may be part of only one extended household. This may be of assistance to assuage the loneliness of some who otherwise would have to sit alone.

From June 7, organised outdoor activities for adults can take place for up to 4,000 people (if they need to stand) or 10,000 people (if all are seated). Brief guidance on this can be found here.

It is a requirement under Clause 20 of the Regulations for all those aged over 11 to wear a face covering in indoor public spaces, including places of worship, unless they have an illness or disability which prevents that. There is no legal exemption for worship leaders, but Welsh Government guidance says:
Those leading worship need not wear a face covering if it impractical to do so. However they should consider a range of other mitigations to ensure they can provide a barrier to transmission such as distancing, screens, visors and additional hygiene measures. 

Risk assessments

On January 20 the coronavirus regulations in Wales were updated to make it a legal obligation on the ‘person’ (or body) responsible for “regulated premises” (including places of worship, community centres, etc) to undertake a risk assessment prior to allowing public access to the premises for any purpose. This has been good practice since spring 2020, and we know that most denominations/networks have produced templates designed for their own churches. It should be noted that the wording of the regulations makes it a requirement to conduct a full risk assessment (covering general health and safety matters as well as those relating to coronavirus specifically) even if the building is open only occasionally (e.g. for funerals) or for much more limited purposes than usual (for example to host a food bank).

Welsh Government has chosen to word the regulations by referring to Health and Safety regulations made in 1999, which have been amended several times since, and then require them to be read as if they were worded differently from the actual wording. So, in order to assist our member churches to update their risk assessment and templates in accordance with the law, we have prepared a guide to what is now mandatory, which can be downloaded here.

We would draw particular attention to four aspects of the regulations:

  1. Our understanding is that the effect of the regulations is to make conducting a full risk assessment – covering general health and safety risks and fire risks as well as the coronavirus related issues – mandatory for all “regulated premises”, even for premises where that was not previously the case.
  2. The regulations require a review of the risk assessment to be made each time the coronavirus regulations are amended or the uses of the premises change (as this would be a significant change in the matters to which it relates) and also when the wider situation regarding the pandemic changes (as this would be reason to suspect that it is no longer valid).
  3. The regulations require the risk assessment to be in writing when five or more persons are working at the premises. As ‘working’ includes working voluntarily, this would cover nearly all circumstances likely to be relevant to faith communities. The regulations also require consultation with these ‘workers’ in drawing up the risk assessment.
  4. There are special requirements relating to risk assessment for young people ‘working’ in the premises.

We hope that the document will be of assistance to you, but please note that it is not legal advice, and professional advice should be sought if there is any doubt about how to apply the regulations in your particular circumstances.

The Health and Safety Executive has produced a Covid risk assessment template, and this is recommended as a starting point for churches drawing up their own risk assessments.

The guidance for places of worship includes an updated section on ventilation. This provides a summary of the latest scientific information which emphasises the need for good ventilation when people from different households meet indoors. Unfortunately, this section is rather technical and difficult to interpret. In preparing a risk assessment, therefore, and preparing to open, we recommend instead using the more user-friendly summary of the same information in the guidance for community centres (scroll down) or the guidance from the Health and Safety Executive, especially the practical suggestions in sections 4-6. If the summer brings good weather, the simplest solution will be to keep external doors and windows (other than fire doors) open during services and events, but a full risk assessment should be prepared.

Funerals and weddings

In the case of funeral services held indoors, there is a legal restriction on who may attend. Under Schedule 1, clause 2(6)(d), an individual may gather with others to attend a funeral:  
(i) as a person responsible for arranging the funeral,
(ii) if invited by a person responsible for arranging the funeral, or
(iii) as the carer of a person attending.

Welsh Government guidance regarding funeral services can be seen here.
It is permissible to hold a wake or funeral tea in regulated premises for up to 30 people indoors; or for up to 4,000 people outdoors (if people need to stand) or for 10,000 people outdoors (if all are seated).

In the case of weddings and civil partnership ceremonies, there is a similar restriction as with funerals on who may attend, under Schedule 1, Clause 2(6)(c), which provides that an individual may:
attend a solemnisation of a marriage, formation of a civil partnership or alternative wedding ceremony—
(i) as a party to the marriage or civil partnership,
(ii) if invited to attend, or
(iii) as the carer of a person attending;

The guidance to which one must have regard when arranging a wedding or civil partnership ceremony is available here.
Wedding receptions can take place at regulated premises for up to 30 people indoors and up to 4,000 people outdoors (if people need to stand) or up to 10,000 people outdoors (if all are seated).

The guidance requires all those aged over 11 to wear face coverings during the ceremony, with the following exceptions:
Those leading the ceremony need not wear a face covering if it impractical to do so. However they should consider a range of other mitigations to ensure they can provide a barrier to transmission such as distancing, screens, visors and additional hygiene measures. …
The couple do not need to wear a face covering during; the walk down the aisle, the vows, the first kiss, and photos taken indoors.
 

The regulations also permit holding an “alternative wedding ceremony”, defined as meaning a ceremony:

  1. based on a person’s faith or belief or lack of belief, to mark the union of two people, other than a ceremony for the purposes of solemnising a marriage or forming a civil partnership,
  2. held in regulated premises, and
  3. organised by a charitable, benevolent or philanthropic institution;

This would include a service such as a blessing of a civil marriage, or a religious (or non-religious) ceremony not including the legal registration of the marriage.

Pastoral visiting

Pastoral care of the kind offered by faith communities (as opposed to the kinds of formal and informal care covered by the Social Services and Well-Being (Wales) Act) is not mentioned in the regulations. However, the Welsh Government’s guidance for places of worship includes the following:
Faith leaders should avoid entering another household to provide pastoral care unless reasonably necessary and should consider alternative ways of providing support such as over the telephone or virtual meetings, meeting someone outdoors or in a COVID-19 secure setting.
However if an individual is in need of pastoral support it is reasonable for a faith leader to meet with that individual indoors for compassionate reason. This maybe because a person is struggling with restrictions on meeting others generally or they may be suffering from a physical or mental illness, have suffered a bereavement or you may be concerned about their general wellbeing or welfare.

Under current circumstances, therefore, extreme caution is advised. The risk of spreading the virus inadvertently should be considered prior to undertaking any indoor visit. If the weather is fine, an outdoor visit should be considered in preference to an indoor one – up to 30 people may gather in a private garden. Or, if appropriate, consideration may be given to meeting in a cafe or similar setting, where up to 6 people from 6 different households may sit at a single table.
It would be wise to keep a written record of the decision to visit and the reasons for it.

Welsh Government has published detailed guidance on visiting care homes and visiting hospitals. Guidance on care home visits was amended from April 26 to provide for the number of designated indoor visitors to be increased from 1 to 2 and to give more flexibility around visits from young children

Community use of places of worship and community centres

Community centres (and therefore also places of worship being used for community activities) can open for most organised activity subject to the limits on numbers. Schedule 1 Clause 4(1) provides that the maximum number of people who can be present in any event other than worship is 30 indoors or 4,000 outdoors (where people need to stand) or up to 10,000 outdoors (where all are seated).
However, in line with restrictions elsewhere, community facilities can not be used for parties.

Welsh Government guidance on community centres (not updated for Level 1) can be found here and for the performing arts (including singing and playing musical instruments) (updated on May 14) here.

The most obvious place where the guidance is not tailored to Level 1 is regarding serving refreshments . Following discussion with officials from Welsh Government, we are for now recommending the following:

  1. Where a community centre or place of worship has formal café facilities, then these can be opened following the current guidance. This guidance must be followed in full even when food and drink is served free of charge or for a donation, for example following a service. Informal mixing is not permitted. A full risk assessment must be completed before providing food and drink.
  2. Where a centre or place of worship holds a current Food Hygiene Certificate, and a full general risk assessment has therefore been carried out (perhaps pre-Covid) and the location is known to the authorities, then food and drink may be served (for payment, for a donation or free of charge) if the centre can be arranged and operated as a café – table service only; restricting to 6 the number at each table unless they are members of the same household; ensuring 2m between each household at all times; wearing face coverings when not sat at table; keeping records for Test Trace Protect; and so on, in line with the guidance for cafés. A full risk assessment must be undertaken before doing so.  
  3. Where no Food Hygiene Certificate is held, or where it is not possible to set out the centre in café format or follow the guidance, then food and drink should not be served at the present time. If those attending an activity in the centre wish to eat or drink, they should bring their own food and drink, which should not be shared between households.

Other guidance

There is further guidance that will be useful for some places of worship:

Churches which are part of a denomination, especially where the denomination is the trustee of the local building, should seek the advice of their denomination regarding any specific denominational requirements. It should be noted that the guidance issued by a number of cross-border churches is based on the Regulations applicable in England rather than those applicable in Wales. This is a matter for the individual denomination, and where there is any conflict between denominational advice and the Welsh Regulations, this should be raised within the relevant denomination.

Many of those who are responsible for places of worship are concerned about their liability for conforming to the regulations, especially when they are changing regularly. It may be helpful, therefore, to read Welsh Government’s guidance for enforcement officers, to see what they will be looking for and how they will proceed in order to ensure compliance.

Some FAQs

Here are answers to some frequently asked questions. We will add to this section on a regular basis.

When can other activities restart?

In its announcement on June 4, Welsh Government indicated that it hopes to move fully to Level 1 restrictions on June 21. This would include Increasing numbers for indoor organised gatherings and restarting indoor events. However, they also warned that the situation regarding the Delta variant of coronavirus means that there is no guarantee that such a step can be taken on that date.

Musical instruments and singing

Welsh Government guidance includes a detailed section on instrumental music and choral/group singing, and it should be studied carefully. Congregational singing is not permitted.

On April 8, the Technical Advisory Group to Welsh Government published details of the scientific evidence relating to places of worship and spread of the Coronavirus. This includes a detailed analysis of evidence relating to singing and playing musical instruments on pages 5-7. We understand that Welsh Government has asked to receive further scientific advice on these matters.

Where an organised professional or amateur choir or instrumental group wishes to sing, play or practise, there is detailed guidance to follow and this should be read carefully. In essence, groups of 6 may rehearse together indoors and then lead music in worship either indoors or outdoors, and this permits groups of 6 to come together for the worship itself. Those joining such a group of 6 (and their families) need to be aware that if any one of the group is required to self-isolate all 6 must do so.

Where it is desired to include dance or singing as part of an organised activity for children or young people, the following passage in Welsh Government guidance must be noted:
where activities include dancing, using dance moves that avoid direct contact or practice individual skills. When singing ensuring face to face singing is avoided, even where social distancing is maintained Singing should take place outdoors where possible.

Wind instruments may not be played.
Where it is desired to consider using a pipe organ, consideration should be given to using the Church in Wales’s bespoke risk assessment template.

Outdoor worship

Organised outdoor activities for adults can take place for up to 4,000 people (where people need to stand) or up to 10,000 people (where all are seated). Brief guidance on this can be found here.

It is permissible, with great care, to arrange for groups to lead singing outdoors, but congregational singing is not currently permitted. Welsh Government’s current guidance regarding singing can be seen here.

Serving refreshments before or after worship

Current Welsh Government guidance is not tailored to Level 1 regarding serving refreshments in places of worship and community centres. Following discussion with officials from Welsh Government, we are for now recommending the following:

  1. Where a community centre or place of worship has formal café facilities, then these can be opened following the current guidance. This guidance must be followed in full even when food and drink is served free of charge or for a donation, for example following a service. Informal mixing is not permitted. A full risk assessment must be completed before providing food and drink.
  2. Where a centre or place of worship holds a current Food Hygiene Certificate, and a full general risk assessment has therefore been carried out (perhaps pre-Covid) and the location is known to the authorities, then food and drink may be served (for payment, for a donation or free of charge) if the centre can be arranged and operated as a café – table service only; restricting to 6 the number at each table unless they are members of the same household; ensuring 2m between each household at all times; wearing face coverings when not sat at table; keeping records for Test Trace Protect; and so on, in line with the guidance for cafés. A full risk assessment must be undertaken before doing so.  
  3. Where no Food Hygiene Certificate is held, or where it is not possible to set out the centre in café format or follow the guidance, then food and drink should not be served at the present time. If those attending an activity in the centre wish to eat or drink, they should bring their own food and drink, which should not be shared between households.

Cleaning the building

Welsh Government’s guidance for places of worship includes useful general guidance. Public Health England has published more detailed guidance about general cleaning and about cleaning a building when it is found that someone with Covid-19 has been present.

Test, Trace, Protect

Regulation 21(3) notes that one “reasonable measure” to safeguard people against coronavirus is:
collecting contact information from each person at the premises and retaining it for 21 days for the purpose of providing it to any of the following, upon their request—
(i) the Welsh Ministers;
(ii) a contact tracer;
and taking reasonable measures to ensure that such contact information is correct.

Welsh Government guidance for places of worship says Whether this measure is one that is “reasonable” and is, therefore, one that must be taken depends on the extent to which people who don’t know each other may interact on the premises and whether there is a risk of close interaction.  Churches therefore should consider carefully keeping an attendance list for wedding or baptism services. However, some denominations recommend that such a list should be kept at all activities. If it is decided to keep a list, it is important to adhere to data protection regulations (GDPR).

Welsh Government guidance for community centres interprets the regulations to require keeping a list of attendees at community activities, so it is recommended that this continue for all community activities in places of worship.

Detailed guidance on keeping Test, Trace, Protect records can be found here.

It is not mandatory in Wales to display a QR code in places of worship to enable use of the Covid-19 app, but churches may choose to do so.

Welsh Government announced on April 26 that those working or volunteering, who can no longer do so from home, may order two Covid-19 tests per week. Guidance and information can be found here. Such testing is voluntary, but may well prove reassuring for those who work or volunteer in churches, church cafes and shops and community centres.

Individuals who are anxious about attending

The Chief Medical Officer for Wales has written to those who are clinically extremely vulnerable (those who were ‘shielded’ in March-July 2020), indicating that they can leave their homes, go to work, etc from March 31 2021.

There is no requirement on anyone to attend a place of worship for any purpose, and it is important to ensure pastoral care of anyone who is anxious regarding this.

  1. It may be of help to some to use the risk assessment tool for individuals which has been devised by Welsh Government. Although drawn up principally for workplaces, it can be used by anyone up to 79 years of age and gives an indication of the individuals’ risk level with regard to Covid-19. The United Reformed Church has drawn up a similar risk assessment for members of congregations including those aged over 80. It uses a slightly different metric.
  2. Welsh Government has produced a suite of easily read materials for the public offering general advice on keeping safe.
  3. Welsh Government has created badges and lanyards for individuals to wear in order to remind others to keep their distance.

Baptism by immersion

Welsh Government guidance is as follows:

Where a full immersion is required as part of a ritual this should be carefully planned.  Where possible the person should self-immerse or be attended by a member of their own household.  If this is not possible they should be attended by a single officiant.  The congregation should remain out of range of any splashing at all times.
Only one person should be immersed at any one time. If non-chlorinated water is used in the baptistery it must be drained and cleaned between each baptism.  A swimming pool must follow Welsh Government guidance and guidance has also been prepared by UK Active and Swim Wales.
The officiant can place their hands on the head of the person being immersed but they should not cradle the person or touch them in any other way.  Any words that must be spoken over or near the person should be kept to a minimum. The officiant should wash their hands between each individual being baptised and maintain  a distance of 2 meters except at the point of immersion.
The officiant should wear a face covering when they are closer than 2 meters to the individual being baptised, A face visor will not be sufficient. The individual being baptised should remove their face covering for the immersion.

The Baptist Union of Great Britain has published brief guidance regarding some ways of arranging believers’ baptism in the current circumstances. Not all the suggestions in this guidance will be acceptable to all member churches of Cytun. It is important to conduct a risk assessment prior to arranging a service of this kind.

Infant baptism

Welsh Government guidance says:

Where rituals or ceremonies require water to be applied to the body, small volumes can be splashed onto the body. Where practical others present should move out of range of any potential splashing. Where an infant is involved it should be held by a member of the family. All individuals involved should thoroughly wash their hands before and after and ensure good hand washing and respiratory hygiene.
The officiant can place their hand on the infant but should not cradle the infant or touch it in any other way. If speaking over or near the infant cannot be avoided this should be kept to the absolute minimum. The officiant should wear a face covering when they are within 2 meters of other people. A face visor will not be sufficient. Strict hand hygiene should be maintained through out.
The water should be drained and the font or vessel should be cleaned between each baptism.

Depending on the denominational tradition involved, an officiant who wishes to avoid touching the baby may be able to administer the water using a liturgical vessel or a common vessel (such as a cup or a large spoon) from arm’s length, and this may be more dignified and practical than ‘splashing’ the water as suggested by Welsh Government. A practice using a doll could be arranged to ensure that the method chosen is appropriate.

Communion services

Welsh Government guidance about using food and drink (including the Holy Communion) in worship is designed to cover a wide range of faith practices, and can be difficult to interpret. The practices of different churches regarding communion vary considerably, and churches which are part of a denomination should seek the advice of their denomination in the first instance.
We offer the following general guidance, to be adapted to the theological understandings of individual churches:
1. It is not permitted to break a loaf or to share bread during the service. Wafers may be used, or bread may be prepared and packaged in advance. Some churches ask communicants to bring their own bread, but careful consideration should be given to how to deal with those who forget or those who are visiting and were unaware of this (see 4 below).
2. A common cup may not be used to share wine. Traditions which use individual glasses may do so, but it is better to arrange for the glasses to be filled ready in the pews or to be picked up on arrival at the service, rather than distributing them during the service. They should be carefully washed following the service, or disposable glasses should be used.
3. Traditions which require the blessing of the bread and wine prior to distribution should pay particular attention to the following section of the guidance:
Speaking, singing and chanting should not happen across uncovered consumables (other than consumables to be used by the individual alone). Instead consumables should be securely covered, and prior to the receptacle being opened, surfaces should be cleaned, hands must be washed or gloves worn.
4. A number of commercial suppliers provide individual packs containing a wafer and a plastic cup of wine and these can be blessed subject to the guidance above. Alternatively, they may be distributed to the pews prior to the service or be left for collection by worshippers as they arrive. If worshippers are asked to bring their own bread, a supply of these packs may be kept in reserve for worshippers who forget or are visiting. Some churches will be reluctant to use these packs due to the volume of unreusable plastic which they contain.

Confirmation, ordination and the laying on of hands

Welsh Government guidance says:

Physical distancing of 2 metres to limit close face-to-face interaction and strict hygiene safeguards must be maintained at places of worship. Where absolutely necessary for a faith-specific requirement interactions within a 2 metre distance may take place provided they are brief, kept to a minimum and face-to-face interaction is avoided. These interactions should only take place when it is absolutely essential and it would be unreasonable to maintain physical distancing in the circumstances (for example, the laying on of hands in the ordination of new ministers). For any such interactions, face coverings must be worn, including by the individual leading the act of worship. Face visors do not offer sufficient protection when individuals are within 2 meters of each other.

Children and young people

Places of worship are able to provide registered and unregistered childcare, and the guidance linked here should be studied carefully.

Organised outdoor and indoor activities are permitted for children up to 18 years of age (the age on 31 August 2020). Welsh Government’s detailed guidance can be found here. This guidance states:
activities run for the development and well-being of children and young people, such as sports clubs, drama classes, parent and toddler groups, youth groups and religious groups are allowed. Outdoor activities were able to restart from 27 March 2021 and indoor activities from 3 May 2021. This applies to all persons who were aged under 18 on 31 August 2020. There is no limit on the number of children and young children that can attend these activities, but organisers should be mindful of the space available. Organisers of these activities have a duty to take all reasonable measures to ensure that these activities take place in a way that minimises exposure to coronavirus. Therefore, they should consider the space available to allow social distancing wherever possible with children and to limit the number of children who can attend in order to achieve that, allowing for 2m distancing between children. They should also try to undertake as much of the activity outdoors as is practicable. While activities can restart outdoors, organisers should remember that virtual meetings are still safer and should continue to be used where possible.
Social gatherings such as parties and residential activities are not currently permitted.

Guidance for childcare and play for those aged 0-12 can be found here, and this applies to unregistered child care arrangements, such as those arranged by many places of worship during times of worship.

Welsh Government guidance for youth work can be found here.

Note that children under 11 do not need to wear a face covering. The regulations do not exempt children from keeping a social distance or other legal requirements, but Welsh Government guidance for community activities states:
In circumstances where young children mix with others, it may not be practical to attempt to maintain continual 2 metre distancing (between children, or even between children and adults). This is in part because it is harder for younger children to understand the concept of physical distancing, and in part because appropriate support from carers will often require closer contact.
For young children (those of primary school age or younger), it is in any case less essential to attempt to rigidly maintain continual 2 metre distance between them, or between the children and any adults outside their household or extended household. Studies have found that young children are less likely to transmit the virus, whether to other children or to adults, and the virus appears to take a milder course in children than in adults for most cases. 
However as young children can still transmit the virus, parents of young children should still exercise their good judgement and take care especially to encourage their children to follow hand hygiene measures and keep close contact to a minimum wherever possible.

Where it is desired to include dance or singing as part of an organised activity for children or young people, the following passage in Welsh Government guidance must be noted:
where activities include dancing, using dance moves that avoid direct contact or practice individual skills. When singing ensuring face to face singing is avoided, even where social distancing is maintained Singing should take place outdoors where possible.

Church governance meetings

When a church governance (elders, deacons, PCC) meeting needs to be held, adherence to the above regulations should be ensured and the local risk assessment must permit. Where some members of the meeting are elderly and/or in poor health, this should be taken into account in the risk assessment. Such meetings may not be held in a private dwelling, although up to 30 people may meet in a private garden.

Worshipping in premises not owned by the faith community

In the amendment regulations issued on May 14, the opportunity was taken to clarify that the maximum of 30 attendees indoors does not apply to religious services, provided that a service held indoors is held in premises ordinarily used for that purpose. This means that it is no longer permitted to hire a building not ordinarily used for worship in order to hold an indoor service with a congregation greater than 30.

Following consultation with Welsh Government, we have received the following information:
A church community which rents a specific building on a regular and established basis, such that the use of the building could be described as being ordinarily used as a place of worship, would be able to continue to worship in that building.  The intention is not that they should not be allowed to continue to attend as it is  an established and regular pattern.  Obviously its use would be dependent on the reasonable measures under regulation 16 having been put in place.
What is not permitted is the use of buildings on an ad hoc or one off basis as a place of worship.  In terms of reasoning for the change, it is to ensure that gatherings for the purpose of worship can be conducted in a way in which minimises risk of exposure to coronavirus. 

It is the ‘person’ responsible for the premises who is required to ensure conformity with the regulations and arranging a risk assessment. It is, therefore, necessary to discuss with that ‘person’ how and when worship may resume. The larger a congregation that is meeting in a building ordinarily used for worship but not a place of worship, the wiser it would be to contact the relevant Local Authority to explain what is happening and ensure that there is no misunderstanding.

Support schemes provided by UK and Welsh Governments

The UK Government has announced the extension of the Job Retention (furlough) scheme until the end of September 2021. The scheme is available to businesses whether they are open or closed, but the full regulations should be studied carefully. Taxation law is a specialised field, and you are advised to seek professional advice if you are unsure how to proceed in this regard.

The following Welsh Government funding will support community activities carried out by faith groups. It will not provide support for religious activity.

  • The Voluntary Services Recovery Fund is available to all third sector groups, including faith groups. It aims to prevent inequalities which have arisen as a result of Covid-19 from becoming entrenched. It can fund recovery focused community activity which is volunteer led.
  • The Third Sector Resilience Fund provides a mix of grant and loan funding for third sector organisations under three strands; survive, adapt and improve. It does accept applications from faith groups, however due to the loan element it may only be suitable for some groups. Applicants need to be incorporated organisations or prepared to incorporate before funding is finalised.
  • The Community Facilities Programme provides capital grants at two levels, up to £25,000 for small projects and up to £250,000 for larger schemes. The grant must be used for the improvement of well used community buildings .This can include facilities operated by faith groups as long as they are open to the wider community.

There are a large number of other grant programmes offered by organisations outside of the Welsh Government which will provide funding for projects led by faith groups. This includes Welsh Churches Act funds operated by local authorities (refer to your local authority website)  and programmes run by the National Lottery Community Fund, the Community Foundation Wales and a variety of trusts and foundations. Information on these sources of funding and many more can be found on the Funding Wales website.

The Business Wales website includes comprehensive information about other support schemes which are available and about an expanded apprenticeship scheme to assist those who are out of work due to the pandemic.

WCVA has collated a detailed list of sources of funding available to third sector organisations, many of which are open to applications from churches and faith groups.

It is also worth any faith group making contact with their local county voluntary council for support in identifying local and national funding sources. You can find information on your local county voluntary council at Third Sector Support Wales.

Gethin Rhys
06.06.2021