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The Security Industry Authority updated its licensing criteria on 1 December 2025. Most of the coverage focused on training requirements and overseas criminal record checks. What got less attention was the documentation standard — and how the SIA uses incident records when deciding whether you are a fit and proper person to hold a licence.
After 14 years in the Metropolitan Police, including time with specialist firearms units and covert surveillance teams, I have been on both sides of that assessment. I know what documentation holds up and what gets pulled apart. I built Original Note because the security industry deserved the same standard we were held to in policing.
Here is what the 2026 changes mean for your records, and what you need to have in place before your next renewal.
What Changed in December 2025
The SIA's Get Licensed criteria now explicitly references "other information" that may be taken into account when assessing fitness to hold a licence — not just at application stage, but during the licence period itself. That means an incident on your record, if it comes to the SIA's attention, can trigger a review at any point.
The SIA also has the power to suspend a licence while that review takes place. You do not have to be charged with anything. A complaint, an allegation, a civil claim — any of these can initiate the process.
Your documentation is your defence.
What the SIA Actually Looks For
When the SIA reviews an incident involving a licensed operative, they are not looking at your version of events in isolation. They are looking at the contemporaneous record — what was written at the time, before anyone had a chance to think about how it would look.
A report written at the end of a shift is not contemporaneous. A report written the following morning is not contemporaneous. A WhatsApp voice note is not a contemporaneous record in any legal sense.
Contemporaneous means captured at or immediately after the point of occurrence, in a format that has not been altered after the fact.
In policing, that standard is drilled into you from day one. In the security industry, it is rarely taught and almost never enforced — until something goes wrong.
The Three Things That Sink an SIA Review
Based on experience of how these processes play out, the documentation failures that do the most damage are consistent:
No timestamp. "Late evening" is not a time. "Around 11pm" is not a time. A specific time in 24-hour clock, recorded at the point of incident, is a time. Without it, the sequence of events cannot be established, and any account you give later can be challenged as reconstruction rather than record.
No specificity on grounds. "The subject was aggressive" is an observation. "The subject raised his voice, made direct eye contact, and advanced to within one metre before being redirected" is evidence. The SIA, like any investigative body, applies the second standard. If your report reads like the first, it will not withstand scrutiny.
No CCTV reference. If CCTV covered the incident and you did not note it at the time, that footage may no longer exist when it is needed. Most systems overwrite within 24 to 72 hours. A contemporaneous note of camera coverage, time, and who was asked to preserve it costs nothing. Its absence can cost everything.
What Good Documentation Looks Like in 2026
The standard you should be working to is the same standard a court would apply if the incident became the subject of proceedings. That means:
A specific time and location, recorded immediately. A factual account of what was observed, said, and done — in sequence, without editorialising. Subject description including any ID taken. Witness names and contact details where available. CCTV reference and preservation request. Police involvement including force reference number and attending officer details if applicable. Signature and identification of the reporting operative.
Every element of that list has a reason behind it. None of it is bureaucracy for its own sake.
The Practical Problem
The challenge is not knowing what good documentation looks like. Most experienced security operatives understand the standard instinctively.
The challenge is producing it consistently, under pressure, at the end of a demanding shift, on a form that may not prompt for every required element.
That is the problem Original Note was built to solve. Every incident is captured at the point of occurrence. Timestamps are server-locked. GPS is automatic. The structured form prompts for each required element before submission. An AI quality check reviews the completed report and flags missing information before the record is sealed.
Not because operatives are careless. Because the moment after a difficult incident is exactly the wrong time to rely on memory for a list of fifteen required data points.
Before Your Next Renewal
If your licence is due for renewal in the next twelve months, the time to review your documentation practice is now — not after an incident, and not when the SIA makes contact.
Ask yourself: if a complaint were made about an incident from six months ago, what would your record show? Would it establish a clear, contemporaneous account of what happened, when, and why you made the decisions you made?
If the answer is anything less than yes, the documentation practice needs to change before the next incident — not after it.
Try Original Note free for 7 days. No credit card required. Guards do not need to install anything — it runs in any phone browser.
Or download our free SIA incident report template to see the full documentation structure your records should meet.