Time for Honest Reflection on the S12, or what is known as the “Security Leadership Group"

Michael Kill, CEO, Night-time Industries Association

Since its inception, the S12, now more recently referred to as the "Security Leadership Group", has been one of the most divisive developments the private security industry has experienced in recent years.

It was introduced with positive rhetoric. In its early stages, it was supported by civil servants and positioned as a unifying vehicle — a forum intended to bring security leaders together to advance standards, strengthen the industry’s voice, and drive meaningful reform. On paper, that ambition was difficult to argue with.

Many of us committed extensive time over recent weeks in good faith to support that objective. However, it was always clear from early discussions that any such initiative could only advance on the basis of a unified and genuinely representative voice. That principle was fundamental, not optional. The aspiration was that this unity would form part of the public narrative presented to the wider sector, including at the Security Expo on 1st October.

Regrettably, the current structure risks delivering the opposite: division, exclusion and further siloing across the sector.

What many may not realise is that some of us were involved at the very beginning. We worked to help establish the governance framework and heads of terms that the organisation still sits upon today. The intention was clear — to create a representative, balanced structure that allowed the industry, in its full breadth, to have a credible and constructive voice. The principle was equality. An industry-first focus. Representation from across the entire sector.

The expansion of seats and the removal of the requirement for board members to be ACS-accredited were sensible steps and reflected practical discussions around compliance. Yet this progress has been diluted by the continued restriction of voting rights to ACS businesses only. While some barriers have recently been eased, including the allocation of two designated places for non-ACS businesses, this does little to resolve the underlying contradiction. The compliance framework applies equally once elected, so restricting voting rights achieves little beyond narrowing participation and reinforcing imbalance. With business licensing already under consideration, maintaining this limitation risks appearing tokenistic rather than genuinely inclusive, and it weakens confidence at a time when the industry requires cohesion.

At present, representation within S12 is heavily weighted towards large and medium-sized businesses, particularly within static guarding. Only a small allocation of spaces is available to small and micro businesses, despite the fact that these companies form the overwhelming majority of the sector. Small and micro firms likely account for over 80% of all UK security businesses, numbering well in excess of 10,000 companies. In door supervision and night-time economy provision especially, the backbone of delivery sits within these smaller enterprises. To leave such a vast community competing for minimal representation is difficult to justify.

We frequently hear the assertion that S12 represents “50% of the private security industry.” When examined more closely, that figure relates to turnover rather than the number of businesses. That distinction is critical. Representing a concentration of revenue is not the same as representing a concentration of enterprises. The role of a leadership group is not to mirror balance sheets or financial scale; it is to reflect the diversity, structure and lived realities of the industry. Financial weight does not equate to democratic legitimacy. By failing to reflect the true composition of the sector, the current model risks disenfranchising the very businesses that government industrial strategy consistently champions — SMEs as drivers of growth, fair competition and innovation. It is difficult to reconcile an initiative designed to shape the future credibility of the industry with a structure that marginalises the majority of its participants.

The imbalance is particularly concerning when viewed through the lens of door supervision. Door supervisors are often the first line of defence in pubs, clubs, hospitality venues and crowded public spaces. As Martyn’s Law progresses, their frontline role in public protection will only intensify. Yet this segment of the industry lags behind static guarding in governance structure and resource concentration. Challenges around tax parity, cash payments and worker exploitation are most acute here and are already under active review with HMRC. To under-represent this part of the sector within S12 undermines both its importance and the broader public protection objectives that reform is intended to serve. Furthermore, the current workstreams do not adequately reflect the day-to-day priorities of this large portion of the workforce and business community. When both representation and agenda-setting skew in the same direction, confidence inevitably diminishes.

Feedback from across the industry suggests that trust in the process has already been weakened by structural shifts perceived to accommodate certain interests. The public withdrawal of support by several trade organisations, alongside numerous individual businesses, reflects this growing discomfort. Many colleagues feel excluded and frustrated, convinced that the process risks reinforcing an entrenched and elitist culture rather than dismantling it.

None of this critique is rooted in personal grievance. It is rooted in principle. Considerable time and energy have been invested in good faith to build consensus. Constructive alternatives were proposed, some of which were adopted, including elements of the governance framework. But significant structural challenges remain unresolved. This is not about slowing progress. It is about ensuring that progress rests on foundations that can command sector-wide confidence.

The organisation speaks frequently of collaboration and standards. Yet parts of the wider operational ecosystem across the industry continue to involve layered subcontracting and labour supply chains that have historically contributed to opacity around employment status, cost allocation and workforce protection. Subcontracting in itself is not inherently problematic, but leadership bodies advocating reform must ensure that the environments and structures surrounding them withstand equivalent scrutiny. Access to ministers and proximity to policymakers should not be confused with genuine influence or structural reform. Visibility is not the same as impact.

Recent clarification from Minister Dan Jarvis that S12 is not a government-supported body and that engagement with ministers remains open to the wider industry is important. It dispels any perception of exclusivity and confirms that dialogue is not confined to a single grouping. The opportunity for meaningful, representative engagement still exists.

However, it is also becoming increasingly clear that many within the sector now believe the S12, in its current configuration, is fundamentally flawed and beyond meaningful repair. Confidence has been eroded to the point where some no longer see incremental reform as sufficient. Instead, there is growing appetite for a new, more considered and genuinely representative framework through which the full breadth of the industry can have its voice heard.

A fair and sustainable solution remains possible. Equal representation across micro, small, medium and large businesses, open to both ACS and non-ACS firms alike, supported by a governance-aligned secretariat structure, would restore balance and strengthen legitimacy. Modest adjustments to voting arrangements and seat allocation would provide equal footing and secure broader support. Without meaningful inclusion of the thousands of non-ACS businesses operating across the UK, credibility cannot be secured.

Reform in this industry is too important to be shaped through a narrow lens. Tax parity, professional standards, workforce protection, Martyn’s Law implementation and procurement reform are sector-wide issues that demand sector-wide voices. If we are serious about progression, parity and professionalism, representation must reflect the full landscape of the industry, not simply its largest balance sheets.

The private security industry deserves better. The next chapter must belong to everyone.