In line with its usual approach, the Department for Education published an amended version of the Academy Trust Handbook in the Summer of 2025, which was effective from 1 September 2025, with a further update on 22 October 2025.

The changes from the 2024 edition were as follows:

• A requirement to be working towards meeting the DfE’s digital and technology standards by 2030 (this requirement may be strengthened closer to 2030). Six core standards cover broadband internet, wireless network, network switching, digital leadership and governance, filtering and monitoring and cybersecurity.
• Additional guidance on estate management issues, including school estate management standards, reinforced autoclaved aerated concrete (RAAC) and capital funding.
• Updating details of the accounting officer’s duties, in particular the definitions of regularity, propriety, value for money and feasibility upon which accounting officers must report annually.
• An accounting officer has an obligation to advise a Trust Board if any proposed action is incompatible with the Trust’s Articles of Association or Funding Agreement or the Academy Trust Handbook. Some further guidance on this has been added. In such circumstances, we would recommend that legal advice is taken and this can be included when the accounting officer raises the concerns with the Board.
• Procurement requirements have been supplemented by the addition of reference to various guidance notes.
• Requirements around Trust Boards’ involvement in setting executive pay have been strengthened. The term ‘executive’ is not defined and so it is a matter for each Trust Board to determine the specific roles within its Trust to which its executive pay policy will apply.
• Clarification that the £50m income figure at which a Trust must have a dedicated audit and risk committee and must have internal as well as external financial scrutiny is based on the previous year’s audited accounts.
• Novel, contentious or repercussive transactions for a Trust must always be approved by DfE before the transaction is agreed and the transaction occurs. Precisely what falls within this requirement has long been a very grey area. This uncertainty is heightened by an amendment which says that repercussive transactions include those which ‘could cause additional costs to arise for other parts of government’. It is not clear how a Trust can be expected to know how its actions might impact in this way.
• There is a new specific requirement that a Trust which is subject to a cyber attack must not pay any cyber ransom demand.
• There is a link to further information on DfE oversight and support (including intervention).
• A Notice to Improve (NtI) can no longer be issued in relation to educational performance. The financial management and governance grounds upon which an NtI can be issued are set out in paragraph 6.17 of the Handbook. The implications of an NtI are in paragraphs 6.18 – 6.20 and at 6.21 there is a new paragraph confirming that DfE may recover funds from a Trust where there is evidence of irregularity or fraud.

As in previous years, these changes do not represent a material shift by DfE in any policy areas. In most cases, the aim is to provide additional clarity and guidance to Trusts. The requirement in relation to digital standards is perhaps most important, although there is some flexibility in that it is a requirement to be working towards rather than achieving the standards by 2030, although this may change. We suspect most Trusts will have made good progress in this area in any event. 

If any of the changes highlight a particular issue for a Trust, we would be pleased to work with you and provide advice on the issue in question. For any further queries, please contact me.