Information for the rest of Wales (outside the above Health Protection Areas) and guidelines applicable to the whole of Wales from September 14
It is now lawful to arrange to re-open places of worship. Welsh Government has, in partnership with churches and other faith communities, drawn up guidance regarding implementing these legal requirements for worship and other religious activities. Separate guidance has been issued regarding community activities – see below. Clause 13 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.
Central to being able to hold any activity in any place of worship is conducting a full risk assessment. When the activity is held by another organisation in your building, the risk assessment should be carried out jointly – and remember that the legal responsibility rests with the person or organisation responsible for the building (which is also the case when a faith community uses a building belonging to someone else). The Health & Safety Executive’s template can be accessed here.
As regulations change frequently, Welsh Government’s policy is to update its FAQs page in the first instance, The section on places of worship, weddings and funerals can be found here. When looking for Government guidance on recent changes, therefore, you should start there. However, the FAQs do not answer every question, so you should then turn to the fuller guidance referenced above and below.
For the avoidance of doubt, the “Rule of 6“, limiting social gatherings indoors to 6 people, is not applicable to those activities which are permitted in places of worship (even in the boroughs which are subject to additional restrictions), provided that they accord with the regulations and guidance referenced below.
What the regulations say
In accordance with Clause 12 of the latest 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:
(a) take all reasonable measures to ensure—
(i) that a distance of 2 metres is maintained between any persons on the premises (except between two 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 two 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.
(2A) Measures that may be taken under paragraph (2) also include—
(a) ceasing to carry out certain activities;
(b) closing a part of the premises.
(c) collecting contact information from each person at the premises or, in relation to persons from the same household, from one of them, 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 public health officer,
(iii) a person designated by the local authority in whose area the premises are located to process information for the purposes of contacting persons who may have been exposed to coronavirus.
From September 14, there is an additional legal requirement under Regulation 12B that every person (P) must wear a face covering in relevant indoor premises (including places of worship and community centres).
(2) But this is not required—
(a) where an exemption applies under paragraph (3);
(b) where P has a reasonable excuse not to wear a face covering, as to which see paragraph (4).
(3) An exemption to the requirement to wear a face covering applies—
(a) where P is a child under the age of 11;
(b) where P is in premises where food or drink is sold, or otherwise provided, for consumption on those premises.
(4) The circumstances in which P has a reasonable excuse to not wear a face covering include—
(a) where P is unable to put on, wear or remove a face covering because of a physical or mental illness or impairment, or a disability (within the meaning of section 6 of the
Equality Act 2010(19));
(b) where P is undertaking an activity and wearing a face covering during that activity may reasonably be considered to be a risk to P’s health;
(c) where P has to remove the face covering to communicate with another person who has difficulty communicating (in relation to speech, language or otherwise);
(d) where P has to remove the face covering in order to avoid harm or injury, or the risk of harm or injury, to themselves or others;
(e) where P is at the premises to avoid injury, or to escape a risk of harm, and does not have a face covering;
(f) where P has to remove the face covering to—
(i) take medication;
(ii) eat or drink, where reasonably necessary;
(g) where P is asked to remove the face covering by an enforcement officer.
Welsh Government defines a “face covering” as follows – “The World Health Organisation recommends a minimum of three layers in a face covering. Face coverings must cover the mouth and nose”. There are exceptions to the requirement to wear a face covering for medical reasons or disability, and it is permitted to remove the covering to communicate with another person who has difficulty communicating (in relation to speech, language or otherwise) [Regulation 12B(4)(c)]. Children under the age of 11 are not required to wear face coverings. Fuller guidance for the public is published here and for premises managers here.
On September 14, Welsh Government updated the FAQs page on its website with the following: We consider that those leading worship or a ceremony may have a reasonable excuse not to wear a face covering if they cannot effectively do so while wearing one, as long as they have taken other sufficient mitigations such as staying continually over 2 metres away from others and wearing a visor.
However, this “reasonable excuse” is not included in the Regulations or the guidance for places of worship, so it is important that any decision that the worship leader need not to wear a three-layer face covering, and appropriate alternative mitigations taken, are included in the church’s risk assessment for arranging a service.
Welsh Government has said that from August 3 it is no longer necessary to maintain a physical distance of 2 metres between individuals under 11 years of age , or between those children and adults, but this change has not been incorporated into the Regulations. It is especially important, therefore, that in arranging any activity involving children under 11 that a risk assessment is drawn up taking this into consideration – as well as other matters regarding safeguarding children.
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.
Funerals and weddings
In the case of funeral services held indoors, there is a legal restriction on who may attend. Under Clause 14(2)(h) it is permissible 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.
The Government guidance regarding funerals is here, and those arranging a funeral must have regard to these. (It should be noted that although this guidance is addressed to local authorities, it is relevant to funerals held in places of worship also). Note that it is no longer permissible to sing during funeral services, and the requirement to wear a face covering applies to funerals.
Welsh Government updated the regulations regarding funerals on Friday August 21 in order to allow indoor memorial gatherings of up to 30 people to happen following funeral services. This does not change the regulations regarding funeral services themselves.
In the case of weddings and civil partnership ceremonies (which must be held indoors), there is a similar restriction on who may attend, under Clause 14(2)(g), which provides that an individual may:
attend a solemnization of a marriage or formation of a civil partnership—
(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 is available here.
The requirement to wear a face covering is applicable to weddings and civil partnerships. However, on September 14 Welsh Government updated the FAQs on its website to include the following: Guests will need to wear coverings, but given the importance to couples of the ceremony and the level of risk involved, we consider it is reasonable for the couple to remove their coverings for a kiss, for taking vows and for a “first dance”, as long as other measures are in place to protect people attending the ceremony from the risk of contracting coronavirus, for example, guests staying 2m away from the couple at all times.
However, this mitigation is not included in regulations nor has it yet been incorporated into Welsh Government’s guidance on weddings, so if it is desired to take advantage of it, this should be incorporated into the risk assessment for the service.
Although not a matter for places of worship directly (unless they provide catering for weddings), couples who wish to postpone their wedding may find useful the guidance from the Competition and Markets Authority on reimbursing costs.
Community use of places of worship
From August 7 the additional restrictions placed on multi-purpose community centres have been relaxed, and this includes community use of places of worship. On August 27 Welsh Government published guidance for the safe operation of community centres. The Wales Council for Voluntary Action has drawn up additional practical guidance for re-opening community centres, which may be useful for community use of places of worship also. WCVA’s guidance was updated on October 9.
The Welsh Government’s community centres guidance includes a step-by-step guide to taking decisions regarding re-opening, and that section will prove particularly useful to decision makers.
Cytun draws attention to two matters in particular:
- The Welsh Government’s community centres guidance states: Regulation 12 of the Health Protection (Coronavirus Restrictions) (No 2) (Wales) Regulations 2020 places a duty on those responsible for the centre to collect contact information from each person at the premises or, in relation to persons from the same household, from one of them, and retaining it for 21 days for the purpose of providing it to the Welsh Ministers or to a public health officer upon either’s request. Further information about Test, Trace, Protect is available, along with guidance on keeping records of staff, customers and visitors, and practical guidance for community centres reopening. This is a surprising interpretation of the regulations (which say that such steps may be taken, rather than that they must be taken), but in the light of the wording in this guidance, places of worship are advised to collect contact details for attendees at community activities, ensuring that the information is kept and destroyed in line with data protection regulations (GDPR).
- The community centres guidance does not change the list of activities permitted within a community centre, but it does note that the list of permitted activities may change from time to time, or in specific geographical areas, and that it is the responsibility of those responsible for the centre to ensure that they know what is permitted or not. Clause 14 in the Regulations currently (August 28) in force across Wales states that the public may gather indoors only for the following purposes [omitting purposes not relevant to community use of places of worship]:
(a) obtain medical assistance, ….
(b) provide or receive care or assistance, including relevant personal care, within the meaning of paragraph 7(3B) of Schedule 4 to the Safeguarding of Vulnerable Groups Act 2006(24), where the person receiving the care is a vulnerable person;
(c) provide or receive emergency assistance;
(d) donate blood;
(e) work or provide voluntary or charitable services;
(g) attend a solemnization of a marriage or formation of a civil partnership—
(i) as a party to the marriage or civil partnership,
(ii) if invited to attend, or
(iii) as the carer of a person attending.
(h) 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;
(hza) participate in a gathering of no more than 30 people at open premises to—
(i) celebrate a solemnization of a marriage or formation of a civil partnership that takes place on or after 22 August 2020,
(ii) celebrate the life of a deceased person whose funeral is held on or after 22 August 2020;
(ha) attend a place of worship;
(i) meet a legal obligation …;
(j) access or receive public services
(ja) access childcare or participate in supervised activities for children;
(jb) access educational services;
(k) in relation to children who do not live in the same household as their parents, or one of their parents, continue existing arrangements for access to, and contact between, parents and children, and for the purposes of this paragraph, “parent” includes a person who is not a parent of the child, but who has parental responsibility for, or who has care of, the child; (ha) mynd i fan addoli;
(o) avoid injury or illness or escape a risk of harm.
(p) exercise with others, in a gathering of no more than 30 people, at a fitness studio, gym, swimming pool, other indoor leisure centre or facility or any other open premises.
The previous requirement that “services” offered must be “essential” has been withdrawn, and also the requirement that the Local Authority must give permission for such services to be provided in the building. It is therefore a matter for the ‘person’ (including body such as PCC, Elders’ Meeting, etc) responsible for the building to decide what is offering a “service” and what constitutes “worship”.
With regard to the definition of “worship”, Welsh Government have said they do not wish to introduce a legal definition, and that they trust each faith community to interpret the term in a responsible manner in the context of their own tradition.
With regard to “voluntary or charitable services“, it should be noted that it is permitted to gather to provide such services, but not for the public to access them. Therefore, Cytûn’s guidance is that a committee may be convened and work undertaken (in a Covid-secure manner) in order to agree on steps towards re-opening community activities, but such activities should not be re-opened immediately unless they fall into one of the above categories.
With regard to “public services” and “educational services“, no detailed definition is provided, but it is our understanding that buildings may not currently be let to commercial operations (thus not voluntary, charitable, educational or public services) which are not included in the above list (such as weight loss clubs which do not include exercise); nor for activities which are purely social with no element of “public service” or “education”; nor those which are closed activities for the members of a club or society only (and therefore not “services” or “public”).
Cytûn’s strong recommendation is that any decision to re-open a community activity under the auspices of the place of worship, or by hiring the building, should be clearly minuted, with an explanation of the reasoning adopted in coming to that decision, in case questions are raised at a later date.
Links to guidance on other matters relevant to places of worship
There is further Welsh Government guidance that will be relevant for some places of worship:
- Tourism and hospitality businesses (including cafés operated by churches). Hospitality Cymru has developed detailed guidance for cafés based on Welsh Government’s guidance.
- Retailers (including shops and charity shops run by places of worship)
- Workplaces (all places of worship are workplaces for employees and/or volunteers, but this guidance will be especially relevant to specific workplaces such as church offices)
- Culture and heritage destinations and venues (including historic places of worship open to the public)
- Rehearsing, performing and taking part in the performing arts – this guidance published on September 15 refers explicitly to the conduct of such activities in places of worship. Note that this guidance is very detailed and considerable work is required in order to recommence arts activities. This guidance does not permit the resumption of congregational singing.
- Child care and play schemes registered with the Local Authority (covering also child care which is exempt from registration, for example because it is less than two hours’ duration). In the case of regulated children’s activities, it is the responsibility of the childcare provider to ensure the consent of the Local Authority to the arrangements.
- Open access playschemes for children (Although the heading to this guidance refers to “playschemes”, they are relevant to a wide range of organised activities for children).
- Guidance on youth work
It will be seen that detailed adherence to the guidance regarding child care, “playschemes” and youth work may require some reorganisation of the building, and possibly restricting access by other users, in order to resume activities for children and young people safely. Children under the age of 11 are not required to wear face coverings.
- Landlords of residential property. Until 31 March 2021, most residential tenants in Wales – including those in properties owned by places of worship – will be entitled to six months’ notice of termination of their tenancy, except in some limited circumstances. The relevant regulations can be seen here. Cytun is not able to provide legal advice regarding residential tenancies, and church landlords should take appropriate professional advice if necessary.
The best way to fulfil the legal obligations is to carry out a risk assessment covering at least those matters listed in clause 12 of the Regulations (above). A number of denominations have drawn up templates for this purpose. The templates prepared by the Church in Wales and the Presbyterian Church of Wales have been drawn up based on the Regulations applicable in Wales. Churches of other denominations and non-denominational churches would need to adapt some of the contents to their own governance arrangements.
It is likely that every place of worship will wish to use posters to guide people who enter the building. The Church in Wales and the Baptist Union of Wales have published bilingual posters that can be used for this purpose.
The law permits up to 30 people to gather in the open air, subject to physical distancing, for any purpose. In accordance with Clause 14A more than 30 may gather for the following reasons:
(a) work or provide voluntary or charitable services;
(b) where the person is an elite athlete, train or compete;
(c) meet a legal obligation;
(d) access or receive public services;
(e) access childcare or participate in supervised activities for children;
(f) access educational services.
These Regulations do not require the drawing up of a risk assessment for such open air meetings, but in the case of activities organised by a place of worship it may be a legal requirement to do so for other reasons (e.g. with regard to safeguarding children and vulnerable adults), and it is good practice to do so whenever an event is organised.
Relationship to denominational advice and to regulations applicable in England
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.
Amongst the most important differences between the Regulations in England and in Wales are:
- In England it is permissible to lower the physical distancing indoors to 1 metre if additional safety precautions are taken; but in Wales it is a legal requirement to take all reasonable steps to keep to 2 metre distancing indoors.
- In England there is an upper limit of 30 on the numbers who may attend a baptism, wedding or funeral service (unless it is part of another public service of worship); in Wales, attendance at weddings and funerals (but not baptisms) is restricted to invitees (see above)- but the maximum number is determined by each place of worship rather than by regulation.
The Presbyterian Church of Wales has published helpful information on some of the other differences between regulations in England and Wales.
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, in order to see what they will be looking for and how they will proceed in order to ensure compliance with the law.
Here are answers to some frequently asked questions. We will add to this section on a regular basis.
Musical instruments and singing
The Welsh Government guidance currently advises against congregational singing and the playing of wind instruments indoors. A soloist may sing behind an appropriate screen if that is essential to the worship. On August 7 the guidance regarding playing pipe organs was amended to read: The decision whether to play an organ that requires air to be pushed through the mechanism should be based on a risk assessment and adherence with physical distancing, for example from the remainder of the congregation and avoiding use of a registrant, hand hygiene and cleaning guidance. It is advised that you use alternative instruments such as a piano, electronic instruments or recording.
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.
These restrictions apply to weddings and funerals.
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.
Government guidance does NOT allow leaving the building untouched for 72 hours to be a substitute for cleaning.
Test, Trace, Protect and the NHS Covid-19 app
Clause 12(c) of the Regulations clarifies legally that places of worship may decide to keep a list of attendees and thus may refuse admission to anyone who refuses to co-operate. Full guidance on this has been published here: https://gov.wales/keeping-records-staff-customers-and-visitors-test-trace-protect. This does not require keeping a list of all those who have attended a service unless people have been unable to maintain a physical distance of 2 metres, for example those who take part in a wedding or baptism service. However, some denominations recommend that such a list should be kept at all activities and any place of worship may choose to do so. If it is decided to keep a list, it is important to adhere to data protection regulations (GDPR).
Welsh Government guidance on safe use of community centres, including community use of places of worship, states that those responsible for such centres must collect contact information of participants in activities. Places of worship are therefore advised to collect contact details for attendees at community activities, ensuring that the information is kept and destroyed in line with data protection regulations (GDPR).
Welsh Government is recommending that those who have a mobile phone able to do so should download the NHS Covid-19 app. You can see Welsh Government guidance here and further information here. The app is available in Welsh and English. It will be a matter for individuals to decide whether or not to download it, but places of worship will need to decide whether they wish to print and display QR code posters to enable people to log in as they enter your building. Cytun would draw your attention to the following as you decide how to proceed:
1. In Wales, even if you display a QR code, you will still need to collect names and contact details by traditional means for potential use by the Test Trace Protect service, as people arrive at community activities (but not necessarily at worship, where collecting details is optional). You would therefore need to arrange for admission arrangements to your building to allow for the collection of details on paper and to allow individuals to scan the QR code, while all continuing to maintain a 2m distance at all times.
2. Having logged in to the building, you will remain logged in until you log into another building, or until midnight the same day. You will receive a notification should anyone else who is diagnosed with Covid-19 have entered the building during that period, even if you had in fact left the building before they arrived. You will not be told when the other person was in the building, but you will be required to self-isolate for 14 days. Faith communities will, therefore, need to be aware that staff and volunteers may need to self-isolate on the basis of a notification through the app, even though they have not in fact been in contact with anyone who has Covid-19.
3. Similarly, the app warns you whenever your phone has been for 15 minutes near the phone of someone who has Covid-19. It is wise, therefore, to turn the app off if you leave your phone in a place where it could be close to other phones without being close to the phones’ owners (for example in a leisure centre). When you receive a self-isolation notification, you will not be told when or where the contact was noted.
4. Building owners/managers will not be informed when Covid-19 is found to have been present via the app – you will need to wait for the Test Trace Protect service or public health services to contact you.
5. In England, it is a legal requirement for some kinds of buildings to display a QR code, including some places of worship. There is no equivalent legal requirement in Wales.
Individuals who are anxious about attending
There is no requirement on anyone to attend a place of worship for any purpose, and it is important to ensure pastoral care for anyone who is anxious regarding this.
- 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.
- Welsh Government has produced a suite of easily read materials for the public offering general advice on keeping safe.
- 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 updated its advice regarding baptism by immersion on August 18. Here is the latest advice:
It at all possible full immersion baptisms should be avoided. The use of a baptistery should follow the same guidance as swimming pools. Read the Welsh Government guidance and guidance has also been prepared by UK Active and Swim Wales. Only one baptism should be allowed per session, the water should be drained and the baptistery cleaned. To comply with physical distancing guidance, baptisms should be by self-immersion (Self-immersion means only the candidate should be in the baptistery or pool and not touched by anyone unless they are from the same household) and no one should be baptised by another person, with exception of a member of their own household. Anyone else present should stay out of range of any potential splashing. A self – immersion baptism, in a safe external space designated for swimming such as a lido or beach that is patrolled by lifeguards would be allowed.
This paragraph is part of the Welsh Government’s statutory guidance regarding places of worship – https://gov.wales/guidance-reopening-places-worship-coronavirus-html. Anyone planning a believer’s baptism service in Wales must have regard to this guidance. It is important to conduct a risk assessment prior to arranging a service of this kind.
At a webinar on October 9, Welsh Government confirmed that, in principle, it is permissible to arrange baptism by immersion in a local swimming pool, provided that the pool authorities agree, but the service must still be conducted within the guidance on baptism above.
The Baptist Union of Great Britain has published advice regarding believers’ baptism which may be of help to other churches also. This can be found here: https://www.baptist.org.uk/Publisher/File.aspx?ID=257882 (pages 8-9). Note that these are denominational suggestions only, and some of the suggestions may not be acceptable to all Christian traditions.
Activities for children and young people
- Worship: With regard to the definition of “worship”, Welsh Government have said they do not wish to introduce a legal definition, and that they trust each faith community to interpret the term in a responsible manner in the context of their own tradition. Therefore, children’s activities held as part of a church’s overall worship provision are permitted, as are stand-alone worship activities for, or involving, children (such as Messy Church and similar – although provision of a meal is not currently permitted, unless it is possible to use a cafe for this purpose and maintain social distancing between households).
- Other activities for children and young people:
The Regulations permit “childcare” and “supervised activities for children”. Those arranging such activities should have regard to the relevant Welsh Government guidance:
Child care and play schemes registered with the Local Authority (covering also child care which is exempt from registration, for example because it is less than two hours’ duration). In the case of regulated children’s activities, it is the responsibility of the childcare provider to ensure the consent of the Local Authority to the arrangements.
Open access playschemes for children (Although the heading to this guidance refers to “playschemes”, they are relevant to a wide range of organised activities for children).
Guidance on youth work
It will be seen that detailed adherence to the guidance regarding child care, “playschemes” and youth work may require some reorganisation of the building, and possibly restricting access by other users, in order to resume children’s activities safely. It is good practice for churches to ensure that their safeguarding policies are updated to cover the risks associated with COVID-19, and that new risk assessments are compiled for these activities in current circumstances.
Children under 11 years of age are not required to wear face coverings.
Church governance meetings
It is no longer a legal requirement (outside the areas where local restrictions are in force – see top of the page) to work or volunteer from home unless that is impracticable, although Welsh Government continues to advise that home working/volunteering should continue where possible. Nonetheless, holding church governance meetings (e.g. PCC, Deacons, Elders, etc) within a church building or community centre is now permitted, subject to adherence to the above regulations and that the local risk assessment permits. All those in attendance will need to wear a face covering. Where some members of the meeting are elderly and/or in poor health and/or hard of hearing, this should be taken into account in the risk assessment.
Weight loss clubs
We know that many places of worship and community centres have received applications from weight loss clubs to resume their activities. Some of these requests refer to regulations relating to England or contain other erroneous information, but at least one local authority in Wales has said that such activity may resume. However, it is not for local authorities to determine what activities are conducted in places of worship. It is for the trustees and managers of each place of worship or community centre to decide which organisations may be invited to use the building and on what terms – the only exception being where a local authority or Welsh Government require the use of the building to provide a public service. A weight loss club is not a public service in this sense.
Cytûn’s understanding, confirmed by Welsh Government, is that weight loss clubs are not amongst those activities for which people may meet indoors. If a local decision is made to permit such use, we strongly recommend that the decision is made in a formal governance meeting, that the decision and the reasons for it are recorded, and that a full risk assessment is conducted prior to resumption. Welsh Government has promised to provide clear legal guidance on this matter shortly.
Worshipping in premises not owned by the faith community
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 regulations contain provisions enabling enforcement by local authorities, Welsh Ministers and – if necessary – the police. In addition, from September 14 local authorities were given additional powers to control premises, events and public places in their areas in order to help control coronavirus. These additional regulations can be read here.