Academy Trust Handbook 2025

There are several other key updates and changes trusts need to be aware of. In this article, we’ve broken down the updates and their implications for trusts.

Digital and cybersecurity standards: new guidance

Trusts must work towards meeting six core digital and technology standards by 2030, covering broadband, network switching, wireless networks, cybersecurity, filtering and monitoring, and digital leadership.

Impact: Trusts need to conduct a technology audit, complete the DfE’s self-assessment, and begin strategic planning. This is a significant shift towards digital maturity and cyber resilience.

Executive pay transparency: new guidance

Boards must ensure that their approach to executive pay is 'transparent, proportionate, and defensible', with an agreed pay policy in place. The pay policy should ensure that executive pay is reasonable, defensible, and evidence-based. Salary bands and rationale must be documented and subject to scrutiny.

There has been a shift in terminology where executive salaries 'may' be challenged by the DfE, whereas in previous guidance, this has been that executive salaries 'can' be challenged. A subtle shift, which suggests an increased intent to scrutinise both executive pay and the policies in place to support the pay.

Impact: Trusts may need to revise pay policies and improve board oversight to ensure a robust decision-making process.

Cyber ransomware payments: revised guidance

Trusts are explicitly forbidden from paying ransomware demands. Any such payments have no guarantee of restoring access or services and are likely to result in repeat incidents.

Impact: Trusts need robust incident response plans, staff training, and possibly updates to cyber insurance policies.

Estates management: revised guidance

Additional guidance has been released for ‘School estate management standards’. The standards set out practices and processes required to effectively manage the school estate. It is designed to support schools in managing their estates effectively. It is built on good estates practice, whilst also observing legal requirements. Trusts should now ensure that they are aware of and are applying this new standard.

Impact: Trusts must align estate strategies with DfE standards, including assessments for risks like RAAC (Reinforced Autoclaved Aerated Concrete).

Intervention criteria: revised guidance

Educational performance is no longer a reason for issuing a Notice to Improve; with the focus now being on governance and financial irregularities.

In addition, the DfE reserves the right to reclaim public money from a trust if it finds that the funds have been misused, misappropriated, or involved in fraudulent activity.

Impact: Trusts must prioritise strong governance and financial compliance to avoid intervention. Trusts must ensure transparency and accountability in the use of public funds; must promptly report any suspected fraud or irregularity to the DfE; and be prepared for financial clawback if wrongdoing is confirmed.

Internal scrutiny thresholds: revised guidance

Income thresholds for internal scrutiny are now based on the last audited accounts, not projected income.

Impact: Some trusts may cross the £50 million threshold, which will require changes to governance structures and the establishment of an audit and risk committee.

Repercussive transactions: expanded guidance

The definition of a repercussive transaction has been expanded to state that these are transactions which are 'likely to set a precedent' and 'could cause additional costs to arise for other parts of government.' All novel, contentious, and repercussive transactions must be referred to DfE for approval before the transaction is even agreed.

Impact: Trusts must ensure timely referrals of any such transactions to the DfE and must not proceed until approval has been given.

Procurement compliance: expanded guidance

Additional guidance has been included to reflect the Procurement Act 2023, emphasising value for money, use of DfE tools, and managing conflicts of interest. There is also now specific reference to ensuring that appropriate due diligence is in place for procurement.

Impact: Trusts must review procurement policies and ensure staff are trained in the updated rules.

Accounting Officer duties: expanded guidance

Where the Accounting Officer has always had to assure Parliament and the public of high standards of probity in the management of public funds, the extent of this assurance has been expanded to include specific reference to ‘feasibility’ and the three elements of value for money—economy (reducing the cost whilst maintaining quality), efficiency (maximum output for a given input, or maximum input for a given output), and effectiveness (achieving intended outcomes or objectives).

The Accounting Officers duties have also been expanded to now state that the board should be notified in writing where the Accounting Officer is considering action, which, although it conflicts with the duties of the Accounting Officer, ensures regularity, propriety, value for money, and feasibility. If the Accounting Officer is to make a decision that is contrary to their usual value-for-money responsibilities, then it could be seen as contentious and hence needs board approval.

Impact: There are now higher expectations for financial leadership and ethical governance placed upon the Accounting Officer.

Sustainability and climate action: encouragement

Trusts are encouraged to appoint a sustainability lead and develop a climate action plan by 2025.

Impact: While not mandatory, this aligns with broader DfE goals and may influence future funding and reporting expectations.

If you have any questions about the updates to the ATH or would like a discussion about circumstances specific to your academy trusts, please contact Rebecca Crowther, Matt Doyle-Healey, Helen Blundell or Dave Darlaston.