Changes and focus areas for 2026/27
Inclusion and SEND oversight
The most significant governance change is a new requirement for trusts to demonstrate oversight of the SEND (Special educational needs and disabilities) provision. This includes, but is not limited to:
- Disadvantaged pupils
- Children known to social care or with an education, health and social care plan (EHCP), and
- Children with inclusion priorities within the local authority
Trusts are now expected to monitor participation and outcomes consistently across academies and evaluate the impact of inclusion strategies.
Action: Designate a trustee, or a separate committee, with specific responsibilities for this area
Procurement requirements
Trusts now must:
- Consider using DfE approved procurement options, and retain evidence of any decisions made
- Have approved frameworks in place when obtaining agency staffing, unless an alternative can demonstrably provide equal or better value
- Use DfE-approved energy arrangements where appropriate
- Align Management Information System (MIS) contracts with the DfE’s MIS framework by 1 September 2027
Action: Treat these as mandatory requirements, not merely as best practice.
CFO qualification requirements
For larger trusts, the Department for Education (DfE) is moving towards mandating professionally qualified CFOs.
- From 1 October 2026, recruitment exercises should specify that candidates hold an appropriate qualification, typically an accounting qualification
- From 1 September 2027, the expectation becomes significantly stronger, with Trusts who appoint a non-qualified CFO having to notify the DfE.
Action: While this is unlikely to impact those currently holding CFO positions, trustees will need to ensure that this requirement is linked to appropriate succession planning and financial leadership.
Trustees’ financial expertise
ATH 2026 emphasises the formal assessment of trustees’ financial knowledge and practical skills, particularly trustees involved in finance committees and audit & risk committees
Action: Identify gaps and fill them by appropriate training and/or recruitment of suitable trustees.
Approving executive remuneration
Under new approval limits for executive pay, DfE approval will be required before implementing:
- Remuneration packages in excess of £174,000
- Performance-related payments in excess of £25,000
Action: Each trust must demonstrate thatall its executive pay decisions represent value for money.
– i.e. they are evidenced based, following an agreed pay policy – and must justify any disproportionate increases
MAT funding
For greater transparency, the annual statutory accounts of multi academy trusts (MATs) must now explain:
- How funds are distributed across the constituent schools
- What expenditure is incurred centrally vs at a local level
- The methodology used to calculate central (‘top slice’) charges
This will not be required until the preparation of the statutory accounts for the year ended 31 August 2027.
Action: MATs should formalise, and update where necessary, their funding model.
Going concern and the accounting officer
ATH 2026 strengthens the accounting officer’s responsibilities concerning the trust’s going concern.
Action: accounting officers must notify both the board and the DfE of any concerns regarding the trust’s ability to operate as a going concern.
Fraud, irregularity and public funds
The DfE have increased the emphasis on the existing obligations around preventing fraud prevention and protecting of public money within the sector.
Action: Continue to ensure that controls are in place, and report instances to DfE as soon as possible.
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Frequently asked questions: Academy Trust Handbook 2026
What are the most important changes in the Academy Trust Handbook 2026?
The Academy Trust Handbook 2026 introduces several significant governance and financial management changes. These include stronger trustee oversight of SEND and inclusion, new expectations around CFO qualifications, increased scrutiny of executive pay, tighter procurement requirements, greater transparency over MAT funding arrangements, and enhanced responsibilities relating to going concern assessments.
For many trusts, the biggest challenge will be ensuring governance structures, policies and reporting processes are updated ahead of implementation dates.
When do academy trusts need to comply with the Academy Trust Handbook 2026?
The Academy Trust Handbook 2026 takes effect from 1 October 2026, which is one month later than in previous years.
Trusts should use this additional preparation time to review governance arrangements, financial controls, recruitment plans, procurement practices and reporting processes. Some requirements have later deadlines, such as the Management Information System (MIS) procurement framework requirement and certain multi academy trust (MAT) funding disclosures, which extend into 2027.
What does the new SEND and inclusion oversight requirement mean for trustees?
Trustees are now expected to demonstrate active oversight of SEND provision and wider inclusion outcomes across their academies.
This includes monitoring participation, educational outcomes and the effectiveness of inclusion strategies for pupils with SEND, disadvantaged pupils, children known to social care and those with education, health and care plans (EHCPs). Many trusts may choose to appoint a dedicated SEND link trustee or establish a committee with responsibility for inclusion oversight to help meet these expectations.
Does every academy trust need a professionally qualified CFO?
Not immediately, but things are moving in that direction.
From 1 October 2026, larger trusts recruiting a chief financial officer (CFO) should specify an appropriate professional qualification as part of the role requirements. From 1 September 2027, trusts appointing a non-qualified CFO will need to notify the Department for Education (DfE).
While this is not expected to affect most existing CFOs, trusts should consider the implications for succession planning and future financial leadership recruitment.
What financial expertise should academy trustees have?
Trustees are not expected to be accountants, but boards must be able to demonstrate adequate financial knowledge and oversight.
The 2026 handbook places particular emphasis on trustees serving on finance, audit and risk committees. Trusts should assess existing skills, identify any gaps and address them through targeted training, development or recruitment. A strong mix of financial, educational and governance expertise can help boards make more effective strategic decisions.
How do the new executive pay approval rules affect academy trusts?
DfE approval will be required before implementing remuneration packages exceeding £174,000 and performance-related payments above £25,000.
Trusts will also need to demonstrate that executive remuneration decisions are evidence-based, consistent with their pay policies and represent value for money. Boards should ensure that decision-making processes are well documented and that any significant pay increases can be clearly justified if challenged.
What procurement changes should trusts be aware of?
The handbook strengthens several procurement expectations that were previously presented as best practice.
Trusts must now consider DfE-approved procurement options and retain evidence of procurement decisions. There are also stronger requirements around agency staffing frameworks, energy procurement arrangements and Management Information System contracts.
These changes reflect the DfE’s increasing focus on value for money, procurement consistency and stewardship of public funds.
What new reporting requirements apply to multi academy trusts (MATs)?
MATs will need to provide greater transparency about how funding is allocated and used across their schools.
Annual statutory accounts must explain how funds are distributed between academies, distinguish between central and local expenditure, and describe how central charges or ‘top slice’ arrangements are calculated.
Although these disclosures first apply to accounts for the year ending 31 August 2027, trusts may benefit from reviewing and documenting funding methodologies now.
What happens if an academy trust faces going concern concerns?
The accounting officer has a clear responsibility to escalate concerns about the trust’s ability to continue operating as a going concern.
If concerns arise, they must be reported to both the board and the DfE. This places additional emphasis on financial forecasting, cashflow monitoring, reserves planning and early identification of financial risks.
Trusts experiencing budget pressures should seek advice promptly rather than waiting until issues become critical.
Is fraud prevention still a major focus for academy trusts?
Yes. Although the formal requirements have not changed, fraud prevention remains a key area of focus for the DfE.
Academy trusts should continue to maintain strong internal controls, clear financial procedures, effective segregation of duties and robust oversight arrangements. Boards should also regularly review fraud risks, whistleblowing procedures and governance controls to help protect public funds and comply with regulatory expectations.
How can academy trusts prepare for the Academy Trust Handbook 2026?
The best approach is to start planning before the new requirements take effect. Trusts should:
- Review governance structures
- Assess trustee skills
- Evaluate SEND oversight arrangements
- Consider future CFO recruitment needs
- Examine executive pay processes
- Review procurement and funding transparency requirements
Early preparation can reduce compliance risks and help trusts implement changes in a controlled and strategic way. BKL’s education specialists can support academy trusts with governance reviews, financial management, compliance and sector-specific advisory services.


