Under the proposals, SEN statements will be replaced by single education, health and care plans, requiring co-operation between all local services.
However, the Special Education Consortium and Standing Committee for Youth Justice have raised concerns that the legislation excludes children and young people in custody.
Clause 69 of the bill states that single plans will be suspended if a young person enters custody, with local authorities reviewing their case on release.
In a briefing note on the issue, the two organisations point to the fact that an estimated 60 per cent of young people in custody have a communication disability and 15 per cent have a statement of SEN, compared to three per cent of the general population.
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