Academy Trust Handbook updates
On 25 June 2025 the Department for Education (DfE) published the latest edition of its Academy Trust Handbook which comes into effect on 1 September 2025, the first after a full year of the Labour government and the first since the closure of the ESFA.
Each year, the Handbook evolves to reflect the DfE’s latest expectations around governance, financial oversight, and accountability. For those leading and managing academy trusts, understanding these changes is essential not just for compliance, but for ensuring your trust remains resilient, transparent, and well-governed. With the release of the 2025 edition, this blog highlights the key updates from the 2024 version and what they mean for your role in strategic leadership and operational delivery.
Much like the 2024 version (which can be viewed at the end of this blog), changes are minimal. The 2025 Handbook represents a maturing regulatory environment, with a stronger emphasis on strategic governance, digital readiness, and sustainability. The HM Treasury Managing Public Money guidance is referenced throughout the Handbook and is becoming a more commonly referenced set of guiding principles that academy trusts will need to be more familiar with.
Digital and technology standards
Trusts were reminded of the importance of the digital and technology standards from the 2024 Handbook, in the 2025 version the expectation of what needs to be met by 2030 is made clear and broken down into six core standards:
- Broadband internet
- Network switching
- Wireless network
- Cyber security
- Filtering and monitoring
- Digital leadership and governance
See our detailed blog for more information: How can academies meet digital and technology standards?
School estate management standards
On 23 April 2025 the DfE published policies and processes required to manage the school estate effectively. Section 1.20 of the Handbook has been updated to reference this. The School Estate Management Standards provides a clear, four-tiered framework to help schools in England manage their estates more effectively. From meeting basic legal obligations to adopting sector-leading practices, the Standards guide schools in aligning estate planning with educational goals. They cover everything from health and safety compliance to strategic asset management, offering practical support for school leaders, governors, and estate professionals striving to create safe, efficient, and future-ready learning environments.
Sustainability
The Handbook now includes a link directing all trusts to further guidance on sustainability leadership and climate action plans in education.
The DfE has made its expectations clear: by 2025, every education setting in England should have a named sustainability lead and a climate action plan in place. While the guidance isn’t statutory, it is a strong signal that sustainability is moving up the agenda, and academies are in a prime position to lead.
See our recent blog Why should academies prioritise sustainability leadership and climate action plans?
Accounting officer duties
The Handbook has made clearer that there are three elements to value for money the Accounting Officer must consider in their management of public funds being economy, efficiency and effectiveness. The definitions of regularity, propriety, value for money, and feasibility are also provided for clarification.
The accounting officer must continue to take personal responsibility (which must not be delegated) for assuring the board that the trust is complying with the funding agreement and Handbook.
Section 1.37 states “The accounting officer must advise the board, in writing, if action it is considering is incompatible with the articles, funding agreement or handbook.” An addition to state “This includes where such action conflicts with the duties of the accounting officer, to ensure regularity, propriety, value for money and feasibility.” has been added.
Procurement
In the procurement basics section (2.24) it has been added that the Trust must ensure appropriate due diligence is in place and that Trusts should consider DfE opportunities when making purchasing decisions for goods and services.
Executive pay
The DfE have added to the guidance on the setting of executive pay that they, the DfE, may challenge any executive pay decisions. To reduce the impact of this challenge, it is emphasised that decisions about executive pay must follow a robust evidence-based process, ensuring the process is transparent, proportionate and defensible.
Requirement to have an audit and risk committee
Whilst many Trusts opt to have a dedicated audit and risk committee anyway, it is a requirement for any Trusts with income exceeding £50m. The DfE have clarified that this threshold is based on the most recent set of audited accounts.
Repercussive transactions
Trusts must gain approval from the DfE before entering into any , being those likely to set a precedent and cause pressure on other trusts or the broader public sector to take a similar approach and hence have wider financial implication. This year’s Handbook has added to section 5.5 to clarify that this includes where a trust’s proposal could cause additional costs to arise for other parts of government. A link has also been added to the DfE’s guide for novel, contentious and repercussive transactions.
Cybercrime
Particularly relevant after a recent BBC Panorama documentary, Trusts have previously had to obtain permission to pay any cyber ransom demands, whereas the new Handbook states that paying these demands is now strictly forbidden. The rationale being that it does not guarantee systems returning to normal and only encourages more attacks.
You can view our recent cybercrime blog here.
Oversight, support and intervention
A new paragraph has been added to section 6.16 which links to the DfE’s published Financial support and oversight for academy trusts guidance and “sets out how DfE will work with trusts to identify, at an early stage, any financial issues that might affect the trust. It sets out the support available to trusts and, where there are concerns, the types of action DfE will take.”
Notices to Improve
The following has been removed as an area that a Notice to Improve could be issued: “Trustees lacking the skills, knowledge and experience to exercise effective oversight of the trust’s operations and performance, including educational performance”
Fraud
A new paragraph has been added to section 6.21 which confirms that the DfE may recover funds where there is evidence of irregularity or fraud.
If you have any questions on what the changes might mean for you and your trust please don’t hesitate to contact the Price Bailey Academy Helpdesk ([email protected]) or your Price Bailey audit manager.
Academy Trust Handbook 2024
Finance leases
The Financial Reporting Council (FRC) have long promised changes to the FRS 102 accounting standards that academy trust accounts must comply with. One of these proposed changes will change the way leases are accounted for to move them in line with International Accounting Standards (IFRS) and will result in operating leases, which academy trusts have always been permitted to enter into, being accounted for as if they were finance leases, which have previously been prohibited in the Handbook without prior approval. Quite when these changes will take place is still yet to be confirmed but when they do this would cause issues in the academy sector where in accounting terms there is essentially no difference between finance and operating leases which would make assessing what is and isn’t allowed more difficult. In March 2024 the DfE therefore promised changes to the Handbook to make this issue simpler and they have now followed through on that promise in the 2024 Handbook.
From 1 September 2024 academy trusts do NOT need ESFA permission to enter into any of the following leases regardless of whether they constitute a finance or operating lease:
- leases related to IT equipment (for example laptops, tablets, desktop computers, printers, photocopiers, servers, door entry security systems, CCTV Systems, whiteboards and touch screen boards)
- leases related to telephony (for example mobile phones, landline phones and telephone systems)
- leases related to catering and cleaning equipment (for example tills, water coolers, vending machines, dishwashers, washing machines, ovens, fridges, freezers, water boilers, small kitchen appliances, crockery and cutlery)
- leases related to furniture (for example desks, tables and chairs)
- leases related to bathroom and sanitary items (for example hand dryers, towel dispensers, sanitary bins)
- leases related to gym equipment (for example treadmills, free weights and weight machines, rowing machines and exercise bikes)
- leases related to groundskeeping equipment (for example lawn mowers, string trimmers, leaf blowers and salt spreaders)
- leases related to LED lighting systems or to support renewable activity (for example lightbulbs, control mechanisms and control panels)
- leases related to minibuses and other vehicles for the use of the school
- leases related to temporary classrooms and equivalent structures (but not land leases they sit on, which may require separate consent)
In the vast majority of cases, for the purpose of whether to seek approval, Trusts will not have to assess whether a lease they are considering entering into constitutes a finance lease or an operating lease. This will ease administrative burden and offer greater flexibility to achieve the best value for money from prospective lessors. However, should a lease fall outside of these categories, it will still need to be considered whether it constitutes a finance lease or an operating lease as a finance lease outside of these categories still requires ESFA approval. If you find yourself looking at leasing any such assets please contact the Price Bailey Academy Helpdesk or your audit manager and we can assist you with the operating vs finance lease assessment. Approval is still required for operating leases on land or buildings with a term of over 7 years or granting a leasehold interest on land and buildings to any other party.
For financial statement reporting purposes, an assessment will still need to be made until the changes to FRS 102 come into force which are currently expected to be effective for accounting periods beginning on or after 1 January 2026. So for academy trusts, not until the year ended 31 August 2027.
Internal scrutiny
All trusts are required to run a programme of internal scrutiny each year be it through an in-house internal auditor, a Trustee, an independent peer review from a CFO at another academy trust or a bought in Internal Audit service from a company like Price Bailey. The new Handbook states that for Trusts who have annual revenue exceeding £50 million (which will only therefore affect very large trusts) they should deliver their internal scrutiny using a bought in internal audit service or an in-house internal auditor. From 1 September 2025 this will become a must meaning that those Trusts with revenue exceeding £50m will not be permitted to deliver their internal scrutiny through a Trustee or a peer-review.
The Handbook also clarifies that Trustees or peer-reviewers undertaking this work should have suitable qualifications relevant to the area being reviewed and that auditors should be members of a relevant professional body.
If you are not a Price Bailey external audit client and are interested in internal audit services please contact our head of education Tom Meeks ([email protected]) who can advise further on our offering.
Other changes
In the 2023 Handbook Elective Vehicle Salary Sacrifice (EVSS) schemes did not require ESFA approval where no liability falls on the trust should an employee not fulfil their contractual obligations with the scheme provider. We are aware of a small number of trusts using such schemes. Following cross-government discussions the Handbook now states that Trusts must approach the ESFA for such schemes early in the planning stage both in relation to new schemes and accepting further employees onto existing schemes.
With fraud against academy trusts becoming more common and the majority occurring as a result of cybercrime, the 2024 Handbook expands upon the must included in the 2023 Handbook which stated “Academy trusts must also be aware of the risk of cybercrime, put in place proportionate controls and take appropriate action where a cyber security incident has occurred.” to add reference to the DfE’s published guidance on cyber security stating: “Trusts should take appropriate action to meet DfE’s cyber security standards, which were developed to help them improve their resilience against cyber-attacks”. As a minimum we would expect all trusts to insist on anybody with access to its IT infrastructure to undertake the National Cyber Security Centre’s Cyber Essentials certification.
An expansion has been made to the list of examples where a Notice to Improve (NtI) may be issued on the grounds of governance to include “trustees and the executive failing to manage their school estate and maintain it in a safe working condition strategically and effectively”. If your trust does not already have an estate vision, strategy and asset management plan, this should be a priority for the coming academic year.
Clarification has been added of the need to explain in the annual Trustees’ Report a clear plan for managing reserves with the ATH wording changing from: “The board of Trustees must set a policy for holding reserves and explain it in its annual report” to “The board of Trustees must set a policy for holding reserves, and explain it in its annual report, including a clear plan for managing reserves.
A paragraph has been added to state: “Trusts should refer to the DfE’s digital and technology standards, which were developed to support trusts in making more informed decisions about technology.”
Clarification has been added to confirm that when publishing business interests on the Trust website nil returns must also be disclosed.
We always recommend that you seek advice from a suitably qualified adviser before taking any action. The information in this article only serves as a guide and 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.
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