Top 10 emerging risks for academy trusts

2026/2027

As academy trusts navigate an increasingly complex educational, financial and regulatory environment, boards face a growing range of risks that have the potential to impact organisational resilience, educational outcomes and long-term sustainability.

Drawing on recent Academy Trust Handbook developments, DfE initiatives and the key themes currently being discussed across the sector, 2026/27 presents both new and evolving challenges that trustees and governance professionals must keep firmly on their radar.

Effective boards will not only monitor traditional areas of risk but also anticipate emerging threats, ensuring their trust remains agile, compliant and well-positioned to respond to a rapidly changing landscape.

The following highlights the key emerging risks that academy trust boards should be considering as part of their strategic oversight and risk management arrangements during 2026/27. We also recommend every academy trust completes a risk horizon scan, which we comment on further below.

Financial sustainability & going concern

Continued funding pressures, increasing staffing costs, SEND costs, national insurance impacts, and falling pupil numbers are placing pressure on trust finances.

Key trustee questions:

Are we modelling downside scenarios?

Do we have sufficient cash reserves and liquidity?

Are rolling 12-month cash flow forecasts being reviewed?

What are the triggers for escalating going concern concerns?

Cyber security & digital resilience

Cyber attacks on schools continue to increase, with growing reliance on cloud-based systems and AI tools. DfE expectations around digital standards and cyber resilience continue to strengthen.

Emerging concerns include:

Ransomware attacks

Loss of pupil data

Cyber risks associated with AI adoption

Weak incident response plans

Third-party IT supplier vulnerabilities

Boards should receive regular cyber assurance reporting.

SEND, inclusion & alternative provision pressures

Risks include:

Rising EHCP demand

Insufficient specialist provision

Financial strain from SEND support

Inequitable outcomes across schools

Increasing scrutiny of inclusion practices

Boards will need evidence that pupils with additional needs are being identified and supported consistently across the trust.

Estates governance & building condition

The DfE Education Estates Strategy represents a significant shift towards proactive, data-led estate management.

Emerging risks include:

Deferred maintenance backlogs

Building safety concerns

Asbestos and fire safety compliance

Climate resilience of buildings

Poor estate data affecting funding decisions

Trusts will be expected to demonstrate stronger estates governance and oversight.

Funding reform & capital investment changes

The move away from historical capital funding approaches and increasing reliance on estate condition data creates new funding risks.

Boards should consider:

Whether estate data is accurate

Readiness for new DfE returns

Long-term maintenance affordability

Capital project governance

Value for money of major investments

Governance capability & trustee skills

The Academy Trust Handbook 2026 strengthens expectations regarding trustee financial knowledge and board capability.

Key risks:

Skills gaps on boards

Insufficient financial challenge

Over-reliance on CFOs and executives

Weak evidence of challenge in minutes

Lack of succession planning

Trustees are increasingly expected to demonstrate understanding of finance, risk and compliance.

Procurement, value for money & public accountability

The Academy Trust Handbook 2026 increases focus on procurement decisions, DfE buying frameworks and evidence of value for money.

Risks include:

Poor procurement documentation

Failure to demonstrate market testing

Conflicts of interest

Weak contract management

Increased scrutiny of executive decision-making

Procurement continues to be a common area of audit and regulatory findings.

Safeguarding beyond traditional safeguarding

Safeguarding expectations continue to broaden.

Emerging themes include:

Online harms

AI-generated content risks

Mental health concerns

Attendance and persistent absence

Contextual safeguarding

Extremism and radicalisation risks

Boards should ensure safeguarding assurance frameworks evolve alongside these threats.

Climate change & sustainability

Climate risks are becoming both a governance and financial issue.

Growing considerations include:

Climate action plan implementation

Energy cost volatility

Flooding and overheating risks

Sustainability reporting expectations

Carbon reduction initiatives

Many trusts now have climate obligations that require active board oversight rather than operational ownership alone.

Martyn's Law & emergency preparedness

The implementation period for Martyn’s Law continues, with enforcement anticipated from 2027.

Trusts should now be considering:

Lockdown procedures

Evacuation and invacuation plans

Emergency communications

Site-specific preparedness

Staff awareness and training

This is likely to become a future area of scrutiny and regulatory assurance.

Risk horizon scan 2026/27

A risk horizon scan is a forward-looking exercise that helps academy trust Boards identify and assess emerging risks, opportunities and external developments that could affect the trust over the next one to five years. The purpose is to support trustee discussions on the strategic risks expected to emerge, enabling proactive oversight, challenge and assurance planning.

When should it be completed?

As a minimum, academy trusts should carry out a formal risk horizon scan annually as part of their strategic planning and risk management cycle. However, Boards may also wish to refresh the exercise following significant events such as major regulatory changes, trust growth, mergers, financial challenges, cyber incidents or significant changes within the wider education sector. Emerging risks should then be incorporated into the trust’s risk register, assurance framework and internal scrutiny programme where appropriate.

Questions every Board should consider:

What strategic risk could materially affect the trust within the next three years that is not currently receiving sufficient board attention?
Which risks have accelerated most significantly during the last 12 months?
Where do we have the least independent assurance?
What keeps our executive team awake at night?
Which risks could result in regulatory intervention?
Are emerging risks reflected within the internal scrutiny plan?
Do our committees provide sufficient coverage of the changing risk landscape?

Practical example: How an academy trust might use a risk horizon scan

For example, an academy trust undertakes its annual risk horizon scan as part of its summer strategic planning cycle. The executive team, including finance, education, estates, HR, safeguarding and IT leads, identify emerging developments that could affect the trust over the next three years.

During the exercise, they highlight several increasing risks, including rising SEND demand, increasing cyber threats, the implementation of Martyn’s Law, deteriorating estate condition data, and growing financial pressures linked to staffing costs and pupil number changes.

The Audit and Risk Committee then reviews and challenges the findings before presenting them to the full Board.

As a result, trustees decide to commission a cyber security review, increase oversight of SEND performance and funding pressures, include estates governance within the internal scrutiny plan, and update the trust’s strategic risk register and assurance map.

The horizon scan therefore moves beyond simply identifying risks and directly informs Board priorities, assurance activities, training plans and resource allocation for the coming year.

In short, a horizon scan should not sit on a shelf. Its purpose is to help trustees identify tomorrow’s risks today, enabling the trust to take action before those risks become significant issues.

Closing remarks

As academy trusts continue to overcome an evolving risk landscape, boards must ensure that risk management remains forward-looking rather than solely focused on current operational pressures.

While financial sustainability, workforce challenges, cyber security, estates compliance and regulatory change remain prominent concerns, trustees should also make time to consider the risks emerging over the horizon that could fundamentally affect their trust’s future position.

An effective way to stimulate strategic discussion is through the challenge question: “What risk could materially affect our trust in the next three years that is not currently receiving sufficient board time?” By regularly reflecting on this question and maintaining a dynamic approach to horizon scanning, Boards can strengthen resilience, improve decision-making and ensure they are better prepared to respond to both expected and unforeseen challenges in 2026/27 and beyond.

We always recommend that you seek advice from a suitably qualified adviser before taking any action. The information on this page is intended as a general guide only. While we work to keep our content accurate and up to date, we cannot guarantee that it reflects the position at the time you are reading it. No responsibility for loss occasioned by any person acting or refraining from action as a result of this material can be accepted by the authors or the firm. For more information on our editorial process, click here.