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What to Do When the Two-Adult Rule Doesn’t Work for Your Organization

Many youth safety trainings tell organizations to keep two adults present with any child. The rule is a good one when an organization can staff it, but not many organizations can do that. The rule also breaks down fast for a mentoring program or a small nonprofit running on three volunteers. Two-deep leadership works when you have the people to run it. When you don’t, you need an alternative.

The Rule Has No Single Legal Source

Most organizations assume some law requires two adults with every child. Almost no states have such laws. A 2021 California law requires two mandated reporters present, not literally two adults, whenever staff or volunteers are with children. That same law now exempts one-to-one mentoring programs entirely, as long as the organization has screening, training, reporting, and regular-contact policies in place instead.

Federal law goes even narrower. A 2018 federal statute limits one-on-one, unobservable contact between adults and minor athletes, but only for organizations affiliated with the U.S. Olympic and Paralympic movement. It does not apply to youth sports leagues generally, and it does not apply to YSOs outside sports at all.

The two-adult “requirement” actually comes from insurers, denominational offices, and national organizations with deep staff. It is an aspiration, not a proven practice, and it is not the standard of care for all youth organizations.

The Rule Also Lacks Proven Effectiveness

It also is not evidence-based.  A 2024 review of procedures to combat online abuse noted that two-deep leadership and the “rule of three” have never been evaluated for effectiveness. Organizations use them because experts recommend them, not because research shows they prevent abuse. The same review states directly that the rule “may not be ideal” for programs built around one-on-one relationships, including mentoring.

Two-deep leadership remains a fine choice if you can staff it. But the rule is a tool, not the goal. The goal is an observable, interruptible environment where no adult has unsupervised, unaccountable access to a child. Organizations without the staff to enforce a two-adult rule can build that environment a different way.

Look at What Similar Organizations Do

Beyond the law and the research, there’s a third useful check: what do organizations your size, with your staffing, do? A national organization with paid staff and a deep volunteer bench operates under different constraints than a three-person nonprofit running a mentoring program on volunteer hours.

That comparison matters more than whether you match a national organization’s policy manual. If most similarly sized organizations in your field have found a workable alternative to two-deep leadership, and yours hasn’t, that gap is worth closing. If most organizations your size can’t staff two-deep leadership either and rely on the same observable, interruptible principles instead, that shared practice tells you your approach is reasonable, not that you’re cutting corners.

Ask around. Talk to peer organizations in your network, at your conferences, in your denomination or association. What you learn will tell you more about whether your policy is defensible than any national organization’s rulebook will.

For Programs Without Enough Adults

If your organization cannot guarantee two adults at every activity, build the underlying principle instead of the headcount:

  • Add windows or open sightlines to any room where staff or volunteers work alone with children.
  • Schedule unpredictable walk-throughs by a supervisor during activities.
  • Require one-on-one meetings, like tutoring or counseling sessions, to happen only in open, visible spaces.
  • Set a visual-distance rule for pickup, drop-off, and transportation, so a parent or second adult can see the interaction even without directly supervising it.

None of these practices has stronger research backing than two-deep leadership does. They are means of reaching the same goal: keep interactions observable and interruptible, even when you can’t put a second trained adult in the room.

For One-on-One Mentoring Programs

Mentoring cannot run on two-deep leadership. The relationship depends on one adult and one child meeting regularly. MENTOR, the National Mentoring Partnership’s national standards, do not ask mentoring programs to add a second adult. They ask programs to build safety a different way:

  • Conduct a comprehensive background check, a face-to-face interview, and reference checks with every mentor before matching.
  • Provide at least two hours of pre-match training covering physical contact boundaries, digital communication rules, transportation policy, and mandatory reporting.
  • Monitor every match on a regular schedule, not just at intake.
  • Keep parents informed and involved throughout the relationship.

California’s mentoring exemption essentially codified this exact structure: screening, training, reporting, and regular contact, in place of a second adult. Any mentoring program, in any state, can build the same framework.

The Bottom Line

Your organization does not need to copy a national organization’s policy manual. It needs a documented supervision plan that matches how your program operates. If two-deep leadership fits your staffing, use it. If it doesn’t, write down the alternative you’re using instead, and be sure every board member and supervisor knows what it is. A policy that exists only in someone’s head protects no one.



Want to go deeper? Our online course Protecting Other People’s Children walks program leaders through building a complete child safety policy step by step, including supervision models suited to your organization’s actual size and staffing.

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