Academy Trust Governance Guide 2026: what’s changed and what boards need to know

The Department for Education updated the Academy Trust Governance Guide on 15 July 2026, the same day it published the Academy Trust Handbook 2026. The guide is non-statutory; it sets out expected practice rather than legal duties in its own right, but several of this year’s additions point straight back to legally binding duties, either through the handbook or through wider education law. Last year’s update was modest; this one is substantial enough that every board should read the “What has changed” section in full before September.

Two genuine new legal duties, and neither sits in the handbook’s own schedule of musts

The handbook’s schedule of musts is the usual starting point for a compliance check, but two of this year’s most concrete new duties come from wider education law and only surface here, in the governance guide, not in that spreadsheet.

A limit on branded uniform and PE kit items, from September 2026

Schools must limit compulsory branded items of uniform and PE kit to 3 or fewer, rising to 4 if one of them is a tie, for secondary and middle schools. The limit applies to anything a pupil is required to wear, including branded bags and seasonal items such as summer dresses, and it covers loaned or gifted items too if wearing them is compulsory. Optional branded items don’t count, provided an unbranded equivalent is permitted. This comes from the Children’s Wellbeing and Schools Act 2026, amending the Education Act 1996, and boards should be reviewing uniform policies against it now rather than in the autumn term.

New allergy safety duties, from September 2026

Trusts must have an allergy safety policy, reviewed at least annually, publicised to staff and pupils, and published on the school website, and must have regard to statutory guidance on allergy safety. This sits alongside the existing duty to support pupils with medical conditions, but it’s a distinct, dated requirement rather than an extension of existing good practice.

Duties that also appear in the Academy Trust Handbook

Three changes in the guide echo duties we’ve already covered in our Academy Trust Handbook 2026 briefing, and the guide adds a specific date to two of them that the handbook itself states more loosely.

• Energy procurement: trusts must use DfE Energy for Schools or a DfE-approved energy deal from September 2026. The handbook describes this as applying when a contract is renewed; the guide gives the September 2026 date explicitly, worth using as the working deadline.
• Supply staffing: trusts must use the Government Commercial Agency’s supply teacher and education recruitment framework from September 2026, unless they hold a compliant alternative with rates no higher than the framework’s. Again, the guide is more specific on timing than the handbook.
• Executive pay pre-advertisement approval: from 1 October 2026*, DfE approval is needed before advertising any new appointment where remuneration exceeds £174,000, or performance-related pay exceeds £25,000. This is the handbook’s own effective date, at paragraph 2.34.

New sections added to the guide

• The new trust standards, referencing the 2026 schools white paper on trust quality.
• The maximising value for pupils programme (6.3.1), pointing boards to DfE’s benchmarking tools for resource management.
• The free school meal expansion grant and the inclusive mainstream fund (7.5.1). From the start of the 2026/27 academic year, pupils in households receiving Universal Credit qualify for free school meals regardless of household earnings. The new grant is worth £505 per pupil per year, calculated from the change in FSM eligibility between the October 2025 and October 2026 census, with a pro-rata rate of £295 per pupil for September 2026 to March 2027. Trusts receiving an allocation from the inclusive mainstream fund must publish an inclusion strategy as a condition of the grant.
• Digital and technology infrastructure (7.9.4): all schools should be working towards six core standards by 2030, covering filtering and monitoring, cybersecurity, broadband, network switching, wireless networks, and digital leadership and governance. Filtering and monitoring are the same standard KCSIE expects trust boards to assure themselves of, so this is worth reading alongside our KCSIE 2026 briefing.
• Sustainability leadership and climate action plans (7.14): every trust and school should nominate a sustainability lead and have a climate action plan in place.

Meaningful updates to existing sections

• Equality, diversity and inclusion (1.1.5): boards may now choose to collect and review aggregate diversity information about the board and the wider workforce, to support compliance with the existing public sector equality duty. This is a should, not a must, and any data collected must be aggregated, anonymised and handled in line with data protection law.
• Building an effective and diverse board (2.4): new emphasis on trustees, finance committee and audit and risk committee members having sufficient financial knowledge and expertise, with training recommended across financial management, control, monitoring and reporting.
• Inclusion and SEND (7.4.1): added emphasis on embedding inclusion across all aspects of a trust’s provision, rather than treating it as a single policy area.
• Other help with financial management (6.3.3) confirms the supply teacher framework duty covered above.
• Setting and managing executive pay (5.5) confirms the pre-advertisement approval rule covered above.
• Supporting pupils with medical conditions (7.10.3) confirms the allergy safety duty covered above.
• School uniform (7.17): confirms the branded items limit covered above.

Two smaller additions: a link to guidance on preventing and tackling bullying and harassment of school staff, in the section on staff wellbeing (5.4), and a link to information on DfE’s cyber security hubs, in the cyber security section (7.9.3).

Why this matters for boards

The uniform and allergy safety duties are the two to prioritise. Both are legally binding, both take effect in September, and neither shows up if you’re working purely from the handbook’s schedule of musts, so a compliance check built only around that spreadsheet will miss them.

The rest of this year’s update is really about board capability rather than new rules: financial literacy, diversity data, inclusion culture, sustainability leadership. None of it is mandatory, but DfE is clearly signalling what a well-run board should be doing, and Ofsted and external reviews of governance increasingly test against exactly this kind of expectation.

Practical steps before September

1. Review your uniform policy against the 3-item limit (4 if one is a tie for secondary and middle schools), including branded bags and seasonal items.
2. Publish an allergy safety policy, reviewed at least annually, on your school website and to staff and pupils.
3. Cross-check your energy and supply staffing contracts against the DfE frameworks, using the same audit you’re running for the handbook.
4. If recruiting to a senior post this autumn, check any appointment above the £174,000 or £25,000 thresholds against the 1 October 2026 pre-advertisement approval rule before the post goes out.
5. Review board and committee financial training plans against the new emphasis in section 2.4.

How Edurio can help

Board effectiveness, financial oversight and inclusion culture all show up as themes across this update, and all three are areas where staff and stakeholder feedback gives boards evidence they can’t get from a policy review alone. Our Effective Local Governance survey measures process efficiency, strategic alignment, and governor capability, and is useful as you brief your board on this year’s changes.

*A note on dates: the Academy Trust Handbook 2026 states the £174,000/£25,000 pre-advertisement pay approval rule takes effect from 1 October 2026 (paragraph 2.34). The Academy Trust Governance Guide states 1 September 2026 for what reads as the same rule. We’ve used the handbook’s date throughout this piece, as the primary statutory document, and have asked DfE to confirm which applies. We’ll update this note once we hear back.