DfE Estates Strategy: identifying key estates governance risks

Academy trusts

Below, is a practical estates governance risk review showing how the DfE Education Estates Strategy published in February 2026 changes the risk landscape for academy trusts.

Clearly identifying key governance risks is critical for effective oversight, as it enables trustees to focus their time, challenge and assurance on the areas most likely to affect compliance, safety, financial sustainability and the quality of education.

We hope academy trusts will find this blog useful to identify key estates related governance risks applicable to them and to understand where oversight, assurance and action are most needed.

Unlike operational risks (which focus on day‑to‑day delivery), governance risks focus on risks arising from oversight, decision‑making and accountability, such as: weak trustee oversight or challenge, poor quality management information, non‑compliance with regulatory expectations, inadequate assurance over high‑risk areas and failure to respond to sector or regulatory change.

Our risk review covers 7 key areas based on the DfE Education Estates Strategy:

Strategic oversight and accountability
‘Manage Your Education Estate’ and data returns
Funding reform and end of CIF
Renewal, retrofit and capital projects
Health, safety and compliance
SEND, inclusion and sufficiency
Related party, procurement and value for money

Strategic oversights and accountability

Estates strategy expectation	Key governance risk	Evidence of compliance
Shift to proactive, long‑term estate management	Estates planning remains reactive and short‑term, driven by emergencies rather than risk	• Existence of a 3–5 year estates strategy approved by trustees • Clear prioritisation of works based on condition, risk and resilience
Increased reliance on responsible body data	Trustees lack assurance over the accuracy and completeness of estates data	• Ownership of estate data clearly defined • Independent challenge over how condition data is compiled and reviewed
Boards expected to oversee compliance with estate standards	Estates risks not clearly reported at board/committee level	• Estates risks clearly articulated in the risk register • Regular reporting to the relevant committee with actions tracked

'Manage Your Education Estate' and data returns

Estates strategy expectation	Key governance risk	Evidence of compliance
Use of Manage Your Education Estate platform	Inaccurate or inconsistent data submitted to DfE	• Controls over data input and review • Evidence that data is reviewed by a suitably qualified officer
Annual estate management returns from autumn 2026	Returns submitted late or without appropriate challenge	• Clear timetable and ownership for submissions • Trustee or committee oversight of key returns
Increased DfE reliance on trust‑held data	Funding decisions based on flawed or outdated information	• Regular validation of condition surveys and assumptions • Use of professional advice where needed

Funding reform and end of CIF

Estates strategy expectation	Key governance risk	Evidence of compliance
Replacement of CIF with data‑led allocations	Trust is unprepared for the new funding model	• Understanding at board level of funding reforms • Scenario planning for future maintenance funding
Long‑term maintenance certainty	Over‑commitment of funds without proper appraisal	• Business cases for significant estates projects • Post‑completion review of major works

Renewal, retrofit and capital projects

Estates strategy expectation	Key governance risk	Evidence of compliance
Climate resilience and sustainability focus	Sustainability commitments are not embedded in decision‑making	• Consideration of whole‑life cost and energy efficiency • Alignment with trust sustainability or climate plans
Increased scale of capital activity	Weak project governance leading to cost overruns or delays	• Project management arrangements • Independent monitoring of large or complex projects

Health, safety and compliance

Estates strategy expectation	Key governance risk	Evidence of compliance
Prioritisation of safety, risk and resilience	Known risks (e.g. RAAC, asbestos, fire safety) not escalated appropriately	• Clear escalation routes for critical risks • Trustee visibility of high‑risk estate issues
Proactive maintenance	Statutory checks becoming overdue due to capacity constraints	• Compliance with statutory testing (fire, gas, electrical, water hygiene) • Follow‑up of remedial actions
Better quality learning environments	H&S risks undermine educational delivery	• Links between estates risks and educational continuity planning

SEND, inclusion and sufficiency

Estates strategy expectation	Key governance risk	Evidence of compliance
Alignment of estates with SEND priorities	Estates planning not aligned to SEND strategy	• Integration of estates plans with SEND and pupil need forecasts
Use of space and surplus land	Under‑used space creates safeguarding or financial risks	• Oversight of surplus/under‑utilised estate • Compliance with land and asset governance requirements

Related party, procurement and value for money

Estates strategy expectation	Key governance risk	Evidence of compliance
Increased estates spend	Non‑compliant procurement or conflicts of interest	• Procurement compliance for estates contracts • Registers of interest up to date and used
Larger contractor relationships	Over‑reliance on single suppliers	• Contract management arrangements • Benchmarking and value‑for‑money evidence
Reduced competitive bidding externally	Reduced internal challenge	• Evidence of challenge and options appraisal

As expectations around estates governance continue to rise, academy trusts that take a proactive, risk‑based approach will be best placed to demonstrate effective oversight, protect pupils and staff, and make informed decisions about future investment. By strengthening governance arrangements, improving visibility of risk and embedding effective challenge, trusts can move beyond compliance and ensure their estates actively support educational delivery both now and in the years ahead.

If you would like to discuss the implications of the DfE Education Estates Strategy for your trust, or explore how Price Bailey’s internal audit services can provide practical assurance over estates governance, our specialist academies team would be delighted to help – please use the form below to get in touch.

Current external and internal audit clients are also encouraged to contact the Price Bailey Academy Helpdesk with any queries.

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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