Academy Trust Handbook 2026: What Has Changed and What Trusts Should Do Next

The Department for Education has published the Academy Trust Handbook 2026, which comes into effect on 1 October 2026.

This year's changes cover inclusion, financial competence, digital standards, procurement, workforce decisions and public transparency. Some will affect decisions trusts are already making, including senior appointments, contract renewals, pension proposals and financial planning.

Most trusts will not need to redesign their governance arrangements. They will need to establish what has changed, who is responsible and what evidence the board will receive.

Updating policies may be part of the response, but it will not be enough on its own. 

Understanding "must" and "should"

The Handbook uses "must" for mandatory requirements.

"Should" describes minimum good practice. A trust can take a different approach, but it should be able to demonstrate why that approach is better suited to its circumstances.

Trusts therefore need to consider both formal compliance and the evidence supporting their decisions. 

Inclusion becomes a trust-wide responsibility

The 2026 Handbook introduces new expectations around inclusion and collaboration.

Trusts should establish a clear, trust-wide approach to inclusion. Boards should have sufficient assurance over the quality and consistency of inclusive practice, and a trustee or committee should support oversight of inclusion, including SEND.

Trusts should also work constructively with local authorities and other agencies where responsibilities are shared.

Boards need a trust-wide view of how pupils are identified, supported and able to participate fully in school life.

If Ofsted or the DfE asked how your board knows that inclusive practice is consistent across the trust, what evidence would you provide?

For some trusts, this will mean reviewing their inclusion strategy, board reporting, and partnership arrangements.

Digital standards require a funded plan

Trusts should be working towards meeting the six core DfE digital and technology standards by 2030.

These cover broadband, network switching, wireless networks, cyber security, filtering and monitoring, and digital leadership and governance. The DfE expects trusts already to be meeting the filtering and monitoring standards set out in Keeping Children Safe in Education.

Technology projects often require significant investment and several years of planning. Boards should understand the trust's current position, the gaps that remain and the cost of addressing them.

The DfE self-assessment provides a useful starting point for developing a funded and realistic plan. 

Financial knowledge cannot sit with the CFO alone

The Handbook strengthens expectations around the financial knowledge and expertise of trustees.

Boards should ensure there is sufficient financial knowledge across the board, its committees and the local tier. Training should cover financial management, control, monitoring and reporting, particularly for members of finance and audit and risk committees.

Trusts should identify any skills gaps and consider whether training is improving the quality of board challenge.

Expectations around CFO qualifications are also increasing for larger trusts.

For trusts with more than 3,000 pupils, CFO recruitment exercises beginning on or after 1 October 2026 should specify that the person should be a qualified accountant and a member of the relevant professional accountancy body, and/or hold the CIPFA Level 7 qualification.

This becomes mandatory for recruitment exercises beginning on or after 1 September 2027.

If a trust plans to appoint a new CFO who is not a qualified accountant or does not hold the CIPFA Level 7 qualification, it must inform the DfE in advance and explain its decision.

There is no requirement to replace an existing CFO, but larger trusts should review their succession and future recruitment plans.

Curriculum and financial planning should work together

The 2025 Handbook said boards were "encouraged" to take an integrated approach to curriculum and financial planning. The 2026 edition now says boards "should" do so.

As "should" is defined as minimum good practice, this strengthens the expectation.

A three-year forecast does not demonstrate integrated planning on its own. Pupil numbers, staffing structures, curriculum decisions, educational priorities and affordability need to be considered together.

Board papers should show how educational decisions influence the budget and how financial pressures affect curriculum and workforce plans. 

Financial sustainability becomes a live board issue

Going concern is often considered during the annual accounts process. The new wording makes clear that it must also be monitored throughout the year.

The accounting officer must notify the trust board when the trust's ability to operate as a going concern is at risk. Trustees must then take ownership and the necessary action, including notifying the DfE.

Trusts need to decide what would trigger this escalation. Possible indicators include sustained cash-flow pressure, falling reserves, an unmanageable deficit or a significant reduction in pupil numbers.

The board needs timely information, and an agreed route for escalating concerns before the trust is in serious difficulty.

Procurement decisions need a clearer audit trail

Trusts must consider DfE purchasing opportunities when buying goods and services and record their decision-making.

There are also specific requirements for supply staffing, energy and management information system contracts.

Trusts must use the Government Commercial Agency agreement for supply staffing unless they have an alternative compliant agreement with rates no higher than those available through the framework.

For energy, trusts must use the DfE Energy for Schools service or another approved deal unless an alternative with comparable pricing has been sourced.

All MIS contracts must align with the DfE framework by September 2027. Transition arrangements apply to existing contracts.

These requirements affect contracts being planned now. Trusts need an accurate contract register showing renewal dates, procurement routes and the evidence supporting each decision. Need help with your procurement strategy? We can help. Find out about our procurement service for schools and trusts here.

Executive pay requires earlier approval

Executive remuneration must not increase faster than teachers' pay within the trust unless there is a clear justification and prior DfE approval has been obtained.

From 1 October 2026, DfE approval will also be required before advertising a new appointment where remuneration exceeds £174,000, or the pro-rata equivalent, or where performance-related pay exceeds £25,000.

Trusts should check that recruitment and remuneration processes include the correct approval points. Approval cannot be left until a preferred candidate has been selected. 

Alternative pension arrangements require early DfE involvement

The 2026 Handbook explicitly addresses what trusts must do if they are considering offering an alternative to the Teachers' Pension Scheme or Local Government Pension Scheme.

A trust must approach the DfE to seek approval early in the planning process and before communicating any proposed changes to staff. The alternative arrangement must then receive DfE approval before any change is made.

This is a significant consideration for trusts exploring workforce redesign or changes to their employment offer.

The approval process needs to be included in planning from the start, before proposals are discussed with staff or any commitments are made.

Electric vehicle salary-sacrifice schemes

Electric vehicle salary-sacrifice schemes no longer require prior DfE approval where the trust has comprehensive arrangements to prevent any cost or liability falling on it and is not subject to a Notice to Improve.

Trusts must document these arrangements and follow the relevant DfE guidance.

MATs must explain how funding is distributed

Multi-academy trusts must publish a summary statement on their website by 31 January, alongside their annual accounts, explaining how funding is distributed across their schools.

The statement should be consistent with the relevant notes in the accounts and include an overview of the themes in the DfE's example.

It will provide a public explanation of central services, pooled funding, cross-subsidy and investment priorities.

Trustees and local leaders should be able to explain clearly why resources are allocated in the way they are. If that explanation is difficult, the trust may need to review both its funding model and the way it is communicated. 

What should academy trusts do before 1 October?

A proportionate gap assessment should identify:

• which requirements are new or strengthened;
• who is responsible for each change;
• which policies, processes or approval routes need updating;
• what evidence the board will receive;
• whether decisions already underway are affected; and
• when implementation will be reviewed.

Senior appointments, executive pay, pension proposals and upcoming contract renewals may require immediate attention.

Inclusion, digital standards, trustee training, CFO succession and integrated planning will need a longer-term response.

This should not become an exercise in creating more paperwork. The priority is to clarify responsibilities and make sure trustees receive the evidence they need. 

What does this mean for internal scrutiny?

The core internal scrutiny requirements have not changed substantially. However, the wider changes create new areas that trusts may need to include in their risk-based scrutiny programmes.

Changing a policy does not prove that the revised arrangements are being followed.

Internal scrutiny can examine recent decisions, test whether approval routes are working and review the evidence provided to trustees. It can also identify where ownership remains unclear, or controls are not working as expected.

The purpose is to provide independent assurance and identify practical ways to strengthen governance and decision-making.

Need someone you can trust to conduct your internal scrutiny audits? We can help.

Download the practical briefing

We have produced an 11-page briefing to help trustees and executive leaders understand the changes and prepare for implementation.

It includes:

• a detailed examination of the principal changes;
• an implementation roadmap;
• ten questions for trustees;
• a role-by-role ownership checklist; and
• suggested internal scrutiny priorities.

It can be shared with trustees and executive colleagues or used as a practical starting point for your trust's response.

Final thoughts

At Keystone Knowledge, we have seen regulatory updates become exercises in revising policies and ticking off actions. That may achieve technical compliance, but it does not always improve governance.

Boards need to know that the changes are understood, properly owned and reflected in decisions across the trust.

Most trusts will not need to start again. They should use the time before October to identify any gaps, confirm responsibilities, and agree what evidence trustees will receive.

If your trust would value an independent view of its readiness, Keystone can support you with a proportionate gap assessment, governance implementation or risk-led internal scrutiny.