Policy Scan 2025

4.1. Implementation of the National Curriculum in all academies

Overview from The Children’s Wellbeing and Schools Bill: Explanatory notes

The bill introduces a requirement for all academies to teach the national curriculum. Currently, local authority-maintained schools are required to follow the national curriculum, as defined by the Education Act 2002. Academies are not required to teach the national curriculum, although they can if they choose. They are obligated to meet the curriculum requirements of section 78 of the Education Act 2002, which requires schools to offer a “balanced and broadly based curriculum”. The measure will be commenced after the independent Curriculum and Assessment Review has concluded and the Government has responded to its recommendations. Academies are not required to teach the national curriculum until commencement.¹

¹https://publications.parliament.uk/pa/bills/cbill/59-01/0151/en/240151en.pdf

Overall assessment

7 out of 10 trust CEOs believe that the implementation of the national curriculum across all academies would not affect their work. 13% believe it might have a positive effect, however the majority of them believe that it would require some revisions. 1 in 5 CEOs believe this would have a detrimental impact on their work.

Considerations for policy implementation

1. Loss of flexibility and innovation

Respondents expressed concern that the proposed policy would limit the flexibility to adapt the curriculum to local contexts and student needs, stifling innovation. The freedom to design bespoke curricula is seen as a key factor in schools’ success.

• Academy freedoms have allowed trusts to create innovative and effective educational programs tailored to meet their students’ needs, which has contributed to their success. Oftsed has inspected under the EIF and been asked to assure that such curricula are at least in line with NS expectations. By forcing a one-size-fits-all approach to all schools, the ability to innovate and cater to individual learning styles may be diminished.
• Most trusts use the NC as a starting point but then go beyond it to a more ambitious, more relevant curriculum offer, particularly matched to the local needs of pupils in terms of contextual safeguarding, and as the world changes so quickly e.g. AI, fake news etc.

2. Impact on teacher workload

Several respondents highlighted the significant workload implications of redesigning established curricula to comply with new national curriculum requirements. This would place additional strain on staff already working within time and resource constraints.

• We have spent a considerable amount of time creating our curriculum, schools would have to re-design it based on the NC, adding to teacher workload.
• Whatever the new recommendations are, they will mean unpicking and rewriting our shared ‘spiral curriculum,’ which will take time and effort.

3. Challenges for Special and Alternative Provision (AP) schools

Respondents pointed out that the one-size-fits-all approach would be particularly problematic for SEND and AP schools, where curricula must be adapted to meet specific needs.

• As a trust of special schools we need flexibility to be able to design the curriculum to meet the aspirational outcomes for our our young people – for some this will be level 2 qualifications, for some it will be full-time employment, for others it will be to have greater autonomy over their lives and so less reliance on others.

• Our AP trust runs our curricula based on need and stage, not age.
• Pupils with severe learning difficulties require a different curriculum from mainstream. A rigid NC would not meet their needs at different stages.

4. Staffing and resource constraints

Staffing shortages and limited resources were cited as critical factors affecting curriculum decisions. Respondents noted that enforcing a standard curriculum could further complicate these challenges.

• Choices that we take are driven by staffing decisions and staff availability (e.g. a lack of computing teachers, a lack of DT teachers), time available within the curriculum, which is driven by a contextual understanding of the students in our schools (e.g. prior attainment in English and Maths), the 1265 teacher contract (which limits the hours available in the school week). We currently implement the NC in full as do the majority – but flexibilities to meet contextual and workforce needs are important in running any competent and financially stable organisation.

4.2. Requirement for all new teachers to hold qualified teacher status

Overview from The Children’s Wellbeing and Schools Bill: Explanatory notes

The Bill will ensure that new teachers entering the classroom in state-funded primary and secondary settings will either hold, or be working towards, QTS, a regulated professional status that is granted to teachers who have demonstrated that they have met the Teachers’ Standards, and that this is followed by a statutory induction period. Academy trusts have control over teacher qualifications, which means that they are not currently required to employ teachers with QTS. Having QTS is currently a legal requirement for teachers to be able to teach in maintained primary, secondary, and special schools (where funding is provided through local authorities) in England, subject to limited exceptions set out in The Education (Specified Work) (England) Regulations 2012. Statutory induction is the bridge between initial teacher training (“ITT”) and a career in teaching. The Bill would introduce legislation to ensure academies and local authority-maintained schools are required to employ teachers with QTS and extend the requirement of statutory induction to qualified teachers in academy settings for them to work as a teacher there. This would mean there is an aligned approach on the employment of teachers across all state-funded primary and secondary schools.²

²https://publications.parliament.uk/pa/bills/cbill/59-01/0151/en/240151en.pdf

Overall assessment

There is a diverse set of views on this provision. One in five respondents believe it might have a positive impact (however, the majority of these believe it would require some revisions). The rest of trust CEOs are split in two similar groups of about 40% each, believing it either will not affect their work or have a negative impact.

Considerations for policy implementation

1. Challenges with teacher recruitment and retention

A significant concern was the current recruitment and retention crisis, with many schools already struggling to find qualified teachers. Respondents warned that enforcing this requirement could worsen the problem, especially in hard-to-staff areas and subjects.

• In some geographical areas, and in some schools, recruitment is a significant challenge and we have employed unqualified staff to ensure consistency and quality in the absence of staff with QTS

• There is a crippling staff shortage, so anything which allows innovation, such as the flexibility to employ knowledgeable and relational individuals who we might coach to become great teachers, is not helpful right now.

2. Pathways to Teacher Qualification

Several respondents supported a more flexible approach that allows schools to train unqualified teachers on the job while ensuring they eventually gain QTS. This model has proven effective in developing teaching talent from within support roles.

• We currently, when we can’t recruit qualified teachers, appoint graduates as unqualified teachers who over a period of usually two years we work with to gain QTS. This would prevent this and cut off an important alternative when recruitment has proven impossible.
• We have developed a lot of our own teachers by recognizing capacity in classroom based support staff who  we have ultimately put through assessment only routes. We have used unqualified teachers to manage infant size class rules when we have been 2 or 3 children over and cannot afford to add a qualified teacher, but know it does not dilute quality.
• Some of our teachers start out as teaching assistants or other support roles and are developed and encouraged to become qualified teachers through having opportunities to teach prior to gaining their qualifications.

3. Specialist and vocational roles

There were concerns that this policy could limit the ability to recruit specialists, such as sports coaches or vocational experts, who may not have QTS but bring valuable skills to the classroom.

• Some DT and Music staff don’t wish to be qualified teachers, but they are great in the classroom and have specialist skills which are needed to meet the NC.
• This would limit our ability to use industry experts, although this is only <2% in our workforce.
• There are experts in music, sports, Art and MFL that don’t necessarily have QTS. We would lose these.

4. Impact on Special and Alternative Provision (AP) Schools

Respondents highlighted the unique challenges faced by special schools and AP settings, where recruitment is particularly difficult, and staff often transition from support roles to teaching.

• As an AP trust we use breakout and small groups based on need which we couldn’t afford to fully staff with qualified teachers
• We are aiming for all teachers to be qualified but within the special school sector this is more complicated as there are very few routes to qualify as a special school teacher and a high number of unqualified staff in the system

• Finding teachers who want to work in the SEND world is very challenging. We use qualified teachers where we can and have unqualified on teacher training courses, however, we would have difficulty filling all vacancies without unqualified teachers 

4.3. The introduction of the School Teachers’ Pay and Conditions Document (STPCD) into academies

Overview from The Children’s Wellbeing and Schools Bill: Explanatory notes

The Bill will extend the statutory teachers’ pay and conditions framework to include academy schools and alternative provision academies, creating an overarching framework for all state schools.³

In late January, Secretary of State Bridget Phillipson clarified the direction of this proposal, stating that there will be minimum thresholds for teacher pay, though there will be no upper limit. ⁴

³https://publications.parliament.uk/pa/bills/cbill/59-01/0151/en/240151en.pdf

⁴https://schoolsweek.co.uk/phillipson-well-introduce-academy-pay-floor-but-no-ceiling/

Overall assessment

The vast majority of respondents (79%) believe that this proposal would not affect their work. The remaining CEOs are split in similar groups of about 10% each believing it would have positive or negative impact on their trust.

Considerations for policy implementation

1. Impact on workforce design flexibility and innovation

Several comments focused on how adopting STPCD could limit trusts’ ability to innovate in workforce management and appraisal systems. There were fears that a more regulated structure could stifle creativity and adaptability.

• The inability to set our own appraisal in particularly related to performance related pay will be a major step backwards for accountability.
• All of our teachers are currently employed on more flexible academy contracts; this works for both parties moving back to the overly regulated STPC will stifle innovation and cost more money.

• The minimum stops us taking a risk on people in outlier situations. The market means there already is a de facto minimum for standard teachers.

2. Creating a level playing field

For some trusts, the introduction of STPCD is an opportunity to reduce competition between schools and trusts and promote fairness in pay and conditions.

• A level playing field for all. It will remove perverse incentives and competition.
• Big Trusts lure staff with big salaries, which can leave small, stand-alone schools struggling to compete, especially in coastal areas.

4.4. The right for the Secretary of State to give direction to academies

Overview from The Children’s Wellbeing and Schools Bill: Explanatory notes

Currently, when an academy trust fails to meet its legal obligations, it breaches its funding agreement with the Department. Following a breach of the agreement, the Department, on behalf of the Secretary of State, may issue a Termination Warning Notice and subsequently a Termination Notice where applicable. However, in cases where an academy trust’s non-compliance is minor, termination may not be a proportionate response, especially where the academy in question is not otherwise eligible for intervention. The Bill proposes to introduce the power to issue a direction to academy trusts to comply with specific duties or to prevent the unreasonable use of a power, rather than escalating to termination to provide trusts the opportunity to rectify the situation without threat of termination where this would not be appropriate or proportionate. Where a trust does not comply with the direction the Secretary of State may seek to enforce the direction through seeking a mandatory order rather than looking at termination.⁵

⁵https://publications.parliament.uk/pa/bills/cbill/59-01/0151/en/240151en.pdf

Overall assessment

Half of the respondents believe that this would not affect their work. About 20% each believe it will have a positive impact or a negative impact. 9% of CEOs (more than for other questions) are not sure about the impact of this policy.

Considerations for policy implementation

1. Relevant application for accountability and fairness

Some respondents felt that this policy could promote fairness and accountability across the academy sector, particularly if it addresses serious issues. However, they emphasised the need for transparency and clear guidelines.

• The Sec of State already has powers in the form of the Funding Agreement. This lever should be used more often to curtail malpractices like industrial-scale Permanent Exclusions and other forms of off-rolling.
• All schools should be performing to a high standard. If this is done well, it could be a positive step.
• There is nothing wrong with giving this power to the SOS per se. The issue is ensuring that the power is exercised constructively with nuance and intelligence.

2. Clarity and definition needed

A recurring concern was the vague language in the proposed policy. Respondents warned that terms like “unreasonably” and “relevant duty” are too broad and open to interpretation, which could lead to inconsistent or unjustified interventions.

• Greater clarity and definition are required to define the instances where the Secretary of State would act.
• In principle it sounds reasonable, however, “unreasonable” is difficult to define, and there is no knowing what “relevant duties” may be imposed on academies in the future, by this or another government.

3. Potential for misuse

There was concern that the power could be misused without proper checks and balances and run counter to academy freedoms. Respondents stressed the importance of ensuring decisions are made fairly and based on evidence.

• It’s not the concept that’s a problem—it’s making sure the people making decisions understand the impact of their actions.
• The drafting is far too loose and could give the Secretary of State powers of intervention whenever they liked. It is also based on a misunderstanding of the constitutional nature of academies as independent charities. The Secretary of State has the role of regulator not line manager.

4.5. Requirement for primary academies to provide access to a breakfast club

Overview from The Children’s Wellbeing and Schools Bill: Explanatory notes 

The bill proposes that academies must secure a club that is at least 30 minutes in duration, includes food, is free and open to all pupils in Reception to Year 6 on roll at the school. The existing school food standards – The Requirements for School Food Regulations 2014 – prescribe the foods and drinks that must be provided, which foods are restricted, and those which must not be provided. The club does not have to be on school premises but must be accessible to pupils within the school.⁶

⁶https://publications.parliament.uk/pa/bills/cbill/59-01/0151/en/240151en.pdf

Overall assessment

This is the most positively evaluated provision with half of respondents believing it might have a positive impact. However, of those who have responded positively, three quarters have suggested revisions would be necessary, mainly around the funding of the breakfast clubs. A quarter of respondents believe this would not affect their work and a quarter believes it would have a negative impact.

Considerations for policy implementation

1. Funding challenges

One of the most common concerns mentioned by the vast majority of respondents was the lack of adequate funding for the proposal. Respondents warned that unless fully funded, the policy could place a significant financial burden on schools, many of which already offer breakfast clubs at their own cost.

• The current funding allows for the food but not staffing. We have a model that  enables all pupils to have food but not pre school supervision without staff costs.
• It needs to be fully funded to be affordable – based on current figures it is not affordable for our trust to introduce at the current funding rate.
• We already offer this service, for a small charge which barely covers our costs, it is the funding of such provision which could be its undoing.
• Adequate levels of funding would be required. The burden cannot be pushed back onto the already over-stretched budgets of schools.

2. Staffing and capacity issues

The practicalities of implementing breakfast clubs raised concerns, particularly regarding staffing availability and physical space in schools. Respondents cited difficulties recruiting staff for early-morning shifts and the lack of facilities in some schools.

• We offer breakfast clubs in our primaries and I’m not against the principle at all. My concern is about the logistics of implementation. I have to find solutions to storage of breakfast ingredients in schools with no kitchens, location for the breakfast club especially if the whole school attends, staffing it, clearing it away, where do staff prepare their day if classrooms have to be used.  I’ve not got my head around these issues yet!
• It is very difficult to find staff to cover them as it requires a very early start and unless there is another job to combine it with, there is insufficient pay.
• For primary leaders, this is an extension to the school day and will have a possible impact on the viability of existing provision.
• It would affect the work of Trusts with small rural schools where staffing is hard to come by for breakfast clubs. It also needs to be fully funded, considering additional hours for caretakers opening schools early, additional heating and other costs, food costs, staffing costs, and cleaning costs.

3. Impact on small and rural schools

Concerns were raised about the feasibility of the policy in small village schools and special schools. Transport issues, low uptake, and high staffing demands could make it impractical for these schools.

• Our pupils are mostly brought to school on LA transport from a wide area. They won’t bring children into the breakfast club so a club will be the preserve of affluent families who can afford to drive their children into school.
• It will not be possible for all schools (e.g. special schools or schools in particularly rural areas) because of transport
• The viability of any small rural school provision is in question. There is no infrastructure to enable geographical solutions e.g. where 6 MATs and LA schools are in close proximity. It is a locality provision – it cant be school level unless a provision for 2-3 pupils is fully funded.

Targeted approach preferred

Several respondents suggested that the policy should focus on providing breakfast for disadvantaged pupils rather than making it a universal requirement. This targeted approach could maximise impact while limiting the cost burden.

• I would prefer to see the funding for this to be used in other key areas of education. The state does not need to pay for breakfast for many families (including my own). The money should be focussed more on the disadvantaged and vulnerable.
• At a time of tightening budgets and increased costs it may reduce income generated by some schools. In my view, it needs to be more targeted.

4.6. Limit to the number of branded items of uniform

Overview from The Children’s Wellbeing and Schools Bill: Explanatory notes 

The bill proposes to create a limit in primary legislation on the number of branded uniform items that a school can require. The decision on whether there should be a school uniform policy and, if so, what it should be and how the uniform should be sourced, rests with school governing boards. Where schools choose to have a uniform, they must limit the number of branded items to three for primary schools and four (including ties) for secondary schools. ⁷

⁷https://publications.parliament.uk/pa/bills/cbill/59-01/0151/en/240151en.pdf

Overall assessment

7 out of 10 trust leaders do not believe this policy will have an impact on their trust. 2 out of 10 believe it could have positive impact whereas 1 in 10 believe it may have a detrimental effect.

Considerations for policy implementation

1. Concerns about implementation and unintended consequences

While the goal of reducing costs was broadly supported, several respondents raised concerns about the practical challenges and potential unintended consequences of limiting branded items.

• If a school now needs to transition to an unbranded jumper, only the children whose families cannot afford this will be wearing the branded jumpers until they no longer fit. To prevent this clear de-lineation of the economic status of children, schools will likely intervene to ensure the new unbranded jumper was given to all. Is this the right use of funds?
• The bill in its current form includes PE kit, and also defines “branded” as anything where you prescribe the item from one supplier. This is a lovely idea- to reduce costs for parents- but needs to be less precise in the wording to avoid significant issues for schools.

2. The importance of belonging and identity

Some respondents highlighted the role of uniform in fostering a sense of belonging and school identity. They warned that removing too many branded items could undermine this sense of community and increase inequality through informal status symbols.

• This should be determined locally. Branded uniforms can have a positive impact on pupils’ sense of identity. It is overly prescriptive to limit the number of branded items centrally without any knowledge of context.
• It is so important in creating a sense of belonging that children are part of something, and many schools provide branded items for free or for the same price as available at a supermarket. Most schools also run ‘new to me’ second hand clothes shops to enable parents to access lightly used kit to replace lost items or address the needs of growing children.

4.7. Other trust CEO comments on the schools bill

Trust CEOs were also asked to share their overall assessment of the bill. There were a range of responses, both critical and supportive. This section aims to summarise the main considerations trust CEOs shared that they would expect further legislation to address.

1. Lack of coherent vision and strategic planning

Respondents highlighted that the bill lacks a clear long-term vision for education and appears fragmented, with multiple overlapping initiatives that risk overwhelming the sector.

• All of these things are piecemeal and lack an overall strategy (white paper). As they are all bolted together they lack coherency and are in danger of far out-stripping the capacity and resources required to properly implement. Where is the planned, costed strategic plan, where is the GANTT chart to show how these things will roll out?
• Overall, it doesn’t provide a clear vision for the future and there has been no consultation prior to the bill being presented to parliament which is not a good way to gain buy-in from stakeholders.

2. Funding and resource concerns

A recurring theme was the inadequacy of funding to support the proposed changes, particularly for SEND provision and infrastructure improvements.

• The biggest issue is funding and SEND. We all want to do our very best for our children and families but unless funding is fair, and covers the increased costs imposed by the government the situation simply worsens.
• I’m unsure whether anyone has costed the proposals and therefore have a perspective on affordability. I have heard anecdotal figures being shared but gaining a greater sense of the financial impact would be helpful in the current climate.
• Funding! We are in favour of improving aspects of wellbeing for children and young people but the lack of real funding hinders what can be achieved.

3. Erosion of academy freedoms

Respondents expressed concern that the bill could reduce the autonomy that has allowed academies to innovate and respond to local needs effectively.

• Aspects of the bill feel quite reactionary and undermine the good work of many trusts. As opposed to seeing trusts as valued partners, parts of the bill signal a lack of, forgive the pun, ‘trust’.
• The incremental legislation specifically on academies runs the risk of eroding a spirit of innovation, of stifling locally creative ways of addressing barriers and challenges. So it’s less about individual proposals and more about the impact on how the sector thinks about itself and how it can and should operate in the best interests of the communities that we serve.

Considerations for implementation

1. Concerns about implementation and capacity

There is some concern about how this will work in practice, and how much additional resource individual schools will need in order to have the desired impact. As this is a new initiative, it is unclear exactly how much resource will be available. 

• The indication is a team could call on some reasonable finance…. I want to see how this can be used. One person visiting a few times cannot raise standards. Where Trusts do this it is highly invested and multi-faceted.
• There will be too few RISE teams to be effective. It would be better for HMIs to maintain a relationship with the schools they inspect if they are less than good.
• The RISE advisers do not have the necessary links to the system leaders who work in the sector. The teams do not have the necessary administrative support and much good work will be lost. Schools will not have access to the necessary support.

2. Return to previous initiatives

RISE teams feel to some like a fresh attempt at previous initiatives, which did not have the desired impact. 

• It feels like a return to the Education Advisor roles many years ago – they had limited impact as they did not have the capacity to engage in meaningful school improvement – it became another accountability measure rather than school improvement.
• Using a historical perspective, it will be light touch, without a joined up approach and the long term vision that MATs have of their schools and not have sufficient time or resources to embed strategic improvement.
• This feels like a return to LA SI teams ‘swooping in’ and has the potential to duplicate tasks and create an additional workload for academies – in being accountable to yet another body – when we have spent the last few years curating internal and external expertise.

3. Need for alignment with existing frameworks

There is concern that different parties, all with an overall mandate of school improvement, may not all proceed in the same way. If there is a mismatch between RISE teams, Ofsted and trust-level views of quality, there is a fear that this could create more work and less clarity. 

• The conception of quality that the RISE teams use must be mirrored by other bodies (Ofsted). It is very difficult for schools to improve when different people look for different things. While the RISE teams will have much expertise and wisdom, they will need specific training in what to look for, what to commission and why.

Trusts are best placed to provide the capacity and expertise needed to transform weak schools, and they have a track record of success. It remains the case that the swiftest and most effective intervention happens when weak schools are brought into a high-performing group with shared governance and accountability.

Overview of the Reform to Ofsted Inspections

On 3rd February 2025, Ofsted launched its consultation, seeking the views of parents, carers, professionals and learners, on its proposed new approach to inspecting and reporting on education providers, from the autumn.   The new Ofsted report cards are planned to include a colour-coded 5-point grading scale. An overall effectiveness grade will not be awarded. The proposed scale ranges from ‘causing concern’ at the lowest end, through ‘attention needed’, ‘secure’ and ‘strong’, to ‘exemplary’ – where a provider’s practice is of such exceptional quality that it should be shared with others across the country so they can learn from it. ⁹

⁹https://www.gov.uk/government/news/ofsted-sets-out-proposals-for-fairer-education-inspections-and-new-more-detailed-report-cards

Overall assessment

Ofsted reforms have received the most negative feedback across the three policy developments. Contrary to proposals in the Schools Bill and the introduction of RISE teams, the vast majority of CEOs believe this will impact the sector, and two thirds believe it will do so negatively.  

A smaller proportion believe it will negatively impact the schools within their trust, however, 53% of CEOs reported that they do believe it will have a negative impact. A similar proportion believe it will have a positive impact (18%) as those who believe it will have no impact (17%). A significant minority (13%) are unsure of the impact it will bring. 

Considerations for implementation 

1. Clarity and accountability

Some welcome the information that has been provided so far, though they are looking to keep building on the added clarity. Many others, however, feel less clear now they have read the new proposal than they previously did.

• It seems to be a complicated, multiple faceted report. I like that the pressure to be outstanding has gone, not because I think good is good enough but because the pressure this places on staff makes the process more stressful than it needs to be.

• Some of the wording in the descriptors needs revision but I think the report cards are probably as good an idea as Ofsted was likely to come up with. The key thing is that there is no overall grade. Implementation needs to be consistent but I fear that given Ofsted’s track record, this could be where it all fails.
• The changes are even more likely than the current framework to lead to greater unreliability and inconsistency of inspections due to the increased number of areas that will be judged.

2. Concerns about the new measures

There are mixed views on the introduction of additional measures: some welcome the change in scope while others feel certain elements have gone too far and risk penalising schools working in areas of disadvantage as well as increasing workload.

• The key element of the proposals that cause me concern is the focus on achievement and whether schools with below average intakes such as ours will be constantly judged as requiring attention because we don’t fit the average picture.

• Schools will now have to concentrate on nine areas rather than four and despite Ofsted saying they don’t want to increase workload, it inevitably will because of the high stakes of inspection.
• It is very disheartening to read the new Ofsted toolkit’s reference to a school causing concern where their pupils’ test and examinations over time is well below the national average.  This categorisation will always result in its application as by definition not all results can be above average.

3. Uncertainty about implementation

CEOs are unconvinced that the proposals contain enough substance to be well executed, and whether the teams responsible for evaluating schools against the new scorecard will have sufficient time and experience to make those assessments.

• Ultimately it will all be dependent on the quality of inspectors and the time they have to inspect i.e. the translation of the framework into practice which is ever the case.

• More stress and pressure for schools/trusts, little time to adapt to new framework, much of the Report card feels like it might be pre-determined before inspectors even arrive onsite so HTs will be fighting against the tide from the outset of inspections with ceilings for their ratings. The time and expertise needed to grade each strand seems beyond a typical inspection team.