In September 2021, The Countess responded to an open call by the Irish Prison Services for submissions on proposed rule changes within the prison system. The IPS sought to update its rules to take into account general European practice in prisons. The changes proposed by The Countess cover various aspects of prison rules, including but not limited to the issue of housing dangerous males in the female estate, an issue The Countess was a groundbreaker on. Our submission examined the issues of non-custodial sentences, access to children, children in prison amongst other issues, putting forward its own set of proposed changes to improve the situation for women in prison, most of whom are inside for non-violent petty offences.