Many trustees still call it by its old name. The Department for Education renamed it the Academy Trust Handbook in 2021, and the 2026 edition has effect from 1 October 2026. This guide sets out what the handbook is, what changed this year, the requirements that fall on the board and its officers, and the records a trust needs so that it can show, rather than assert, that it complied.
What the handbook is, and why it binds
The Academy Trust Handbook is the DfE's "overarching framework for financial governance, management and other controls, for academy trusts in England". Until 2021 it was the Academies Financial Handbook; the new name came with an edition that reached further into governance, and the search term has outlived it. Older editions also refer to the Education and Skills Funding Agency, which became part of the DfE in April 2025; the handbook now speaks of the DfE throughout. It covers single academy trusts and trusts with many academies, free schools, studio schools, university technical colleges, alternative provision and special academies.
It is not advice. The introduction says that compliance "is a condition of the funding agreement between each trust and the Secretary of State for Education", and that trustees, accounting officers, principals, senior leaders and others with responsibility for governing, managing or auditing a trust "must understand this handbook and adhere to its contents". The wording is deliberate: "must" marks a requirement, all of which are collected in a separate Schedule of Musts, and "should" marks minimum good practice which trusts should apply unless they can show an alternative better suits their circumstances.
The handbook reflects HM Treasury's Managing public money and the Seven Principles of Public Life – selflessness, integrity, objectivity, accountability, openness, honesty and leadership – and it sits alongside company law and charity law, because academy trustees are both company directors and charity trustees. The DfE reviews it at least annually. The 2026 edition, published on 15 July 2026, is "effective from 1 October 2026" and replaces the 2025 edition, which took effect on 1 September 2025.
What changed in the 2026 edition
The handbook lists its own main changes. In summary:
- Inclusion and collaboration. New paragraphs 1.16 to 1.20 on trusts' responsibilities for inclusion. Trusts must comply with their legal duties, including those on safeguarding, SEND, admissions and place planning, and their legal duties to cooperate with local authorities and other agencies where relevant (1.16 and 1.20). They should embed inclusion across their provision, take a clear trust-wide approach to inclusion, make sure the board has assurance over inclusive practice, designate a trustee, or establish a committee, to support oversight of inclusion, including SEND, and work constructively with local authorities (1.17 to 1.20).
- Digital and technology standards. A reminder that trusts should be working towards meeting the DfE's digital and technology standards, including the six core standards by 2030 (1.21); the DfE expects the filtering and monitoring standards set out in Keeping children safe in education to be met already.
- Trustees' financial knowledge. A stronger position on the board having sufficient financial expertise, with financial training for trustees, particularly finance and audit and risk committee members (1.31).
- CFO qualifications in larger trusts. For trusts with over 3,000 pupils, the CFO should hold a professional accountancy qualification or the CIPFA level 7 qualification, with recruitment exercises from 1 October 2026 expected, and from 1 September 2027 required, to specify it; from 1 September 2027, a trust planning to appoint a CFO who is neither a qualified accountant nor a holder of the CIPFA level 7 qualification must inform the DfE in advance and explain why (1.46).
- Financial planning and going concern. Integrated curriculum and financial planning (2.13), and a stronger obligation to report on the trust's ability to operate as a going concern (2.21).
- Procurement. Trusts must consider DfE buying opportunities and record their decision-making (2.27). They must use the Government Commercial Agency's Supply Teachers and Education Recruitment framework for supply staffing unless they have an alternative compliant agreement at rates no higher than the framework's; the DfE's Energy for Schools service or a DfE approved energy deal unless an alternative of equivalent value for money has been sourced, applying when energy contracts are renewed; and the DfE's management information system framework as soon as practicable after it launches (planned for September 2027) and in line with the expiry of their current contract. Any extension of a management information system contract that expires before the launch must be for no more than 12 months, a new contract must include the DfE's MIS Core Principles, and where a contract runs beyond the launch, trusts must not use extension options that delay transition (2.28 to 2.30).
- Pay and pensions. Electric vehicle salary sacrifice schemes allowed under conditions (2.37); prior DfE approval before offering an alternative to the teachers' or local government pension schemes (2.40).
- Severance and publication. More on severance payments (5.7 to 5.14), and multi-academy trusts must publish on their website, by 31 January, a summary statement accompanying the annual accounts that outlines how funds are distributed across their schools (5.32).
- Intervention. What the Secretary of State may do where a trust breaches its funding agreement (6.17).
The GOV.UK page also records an update on 17 September 2026 clarifying the procurement requirements for energy and management information systems. Read the current version rather than a summary, including this one, before changing a policy.
The people it names, and what each must do
Part 1 sets out who is responsible for what. The requirements that most often matter in practice:
- Members: at least three, and there should be five or more; none may be an employee or occupy a staff establishment role on an unpaid voluntary basis; the majority should not also be trustees; none may be subject to a section 128 direction (1.3 to 1.6).
- Trustees: collectively accountable for the trust and its oversight, with the chair responsible for the board functioning effectively. They must ensure regularity, propriety and value for money in the use of the trust's funds and take ownership of financial sustainability (1.26). The board must meet at least three times a year (2.3) and must approve a written scheme of delegation of financial powers (2.4). Members, trustees and committee members, including those on local committees, must each have an enhanced DBS certificate, without a barred list check unless they also engage in regulated activity (1.58).
- The accounting officer, normally the senior executive leader, appointed in writing and personally responsible to Parliament for the trust's resources. They must advise the board in writing if a proposed action is incompatible with the articles, funding agreement or handbook, and, if the board proceeds anyway, notify the DfE's accounting officer "immediately in writing" (1.42 and 1.43).
- The chief financial officer, whom the board must appoint and to whom detailed financial procedures are delegated, and who should attend finance and audit and risk committee meetings. The CFO and the accounting officer should be different people and should be employed by the trust; appointing either one who is not an employee is for exceptional circumstances and needs the DfE's prior approval (1.34 and 1.44).
- The governance professional, the clerk to the board, who must be someone other than a trustee, principal or chief executive (1.48).
Transparency is a requirement in its own right. The trust must keep a register of business and financial interests for, as a minimum, members, trustees, local governors and senior employees serving at any point over the past 12 months, including interests arising from close family relationships, and keep it "up to date at all times" (1.51 to 1.54). It must publish its governance structure, the register and each trustee's and local governor's attendance records on its website (1.55), and make available on request the agenda, the approved minutes and the papers for every meeting of the trustees, local committees and committees, with confidential items separable (1.56 and 1.57). Changes to members, trustees, the accounting officer and CFO, and in trusts with several academies to headteachers and local governors, must be notified through Get Information about Schools within 14 calendar days of the change, with the trust's website and Companies House updated accordingly (2.54 to 2.58). Our board minutes guide covers how long the minutes themselves are kept.
Money: the decisions that must be approved, notified or recorded
Part 2 and Part 5, on financial management and delegated authorities, are where most trusts meet the handbook day to day. Several requirements are, in substance, record-keeping duties:
- The budget. The board "must approve and minute their approval of a balanced budget, and any significant changes to it" (2.10). A proposed revenue deficit that cannot be covered by unspent funds must be notified to the DfE within 14 calendar days of the meeting (2.17). The budget forecast return must be approved by the board and submitted to the DfE by the deadline the DfE sets each year (2.15 and 2.16).
- Management accounts every month, shared with the chair every month and considered by the board when it meets (2.18 and 2.19).
- Procurement and insurance. Trusts must consider DfE buying opportunities "and record their decision-making" (2.27), and should record their decision on whether to join the risk protection arrangement (2.46); the trust must either have adequate insurance cover in compliance with its legal obligations or be an RPA member, and RPA members may still need commercial insurance for risks the RPA does not cover (2.45). Procurement must follow the rules and thresholds in the Procurement Act 2023 and its associated regulations, using the Find a Tender service (2.25).
- Executive pay. A documented, evidence-based process in an agreed pay policy, with "documented decision-making with rationale and approval by the board"; nobody involved in deciding their own pay (2.31 and 2.32). Executive remuneration must not increase at a faster rate than that of the trust's teachers unless there is a clear justification, and where the trust considers there is one it must seek DfE approval in advance (2.33). From 1 October 2026, new appointments paying over £174,000 (or the pro rata equivalent for part-time staff), or with performance-related pay over £25,000, need DfE approval before the post is advertised (2.34).
- Related party transactions. Every contract with a related party reported to the DfE before it starts or is renewed; the DfE's prior approval for goods or services supplied to the trust above £40,000 in a financial year, and for any novel, contentious or repercussive deal whatever its value; the "at cost" rule above £2,500 cumulatively; and "sufficient records" to show each was conducted to public-sector standards (5.41 to 5.45 and 5.51; the full section is 5.36 to 5.56).
- Special severance. DfE approval before any offer where the non-statutory or non-contractual element is £50,000 or more (gross, before tax), and before any special severance payment that is part of an exit package of £100,000 or more, goes to someone earning over £174,000, or is novel, contentious or repercussive (as any confidentiality clause in a special severance is). Below £50,000, trusts should apply the same scrutiny and have a justified business case, and severance should not be paid where it could be seen as a reward for failure (5.7 and 5.11). Before any binding commitment the trust must consider whether the payment is in its interests and justified by a legal assessment of its chances at tribunal (a settlement should not be offered where that assessment gives the trust at least a 50% chance of success), and any settlement must be less than the likely award. In every case trusts "must clearly record and retain evidence of the management and approval process, including any legal advice", the reasons for the decision, the supporting evidence and how value for money was ensured (5.10 to 5.13). No confidentiality clause in any severance may prevent whistleblowing disclosures under the Public Interest Disclosure Act 1998 or stop the DfE obtaining the information it needs (5.14). Compensation payments with a non-statutory or non-contractual element of £50,000 or more, and all ex gratia and other special payments, also need the DfE's prior approval (5.16 to 5.18).
- Gifts and hospitality. A policy and register on accepting gifts, hospitality and other benefits, which trusts should have and make all staff aware of; and, when the trust itself makes a gift, a duty to ensure the value is reasonable and within the scheme of delegation and that the decision is documented (5.33).
The pattern is consistent. The handbook rarely forbids a decision outright; it asks that the decision be taken by the right person, within the scheme of delegation, with approval sought where a threshold is crossed, and written down. Our conflict of interest guide covers the declarations that sit behind the related party rules.

Assurance, audit and the DfE's right to see the books
Part 3 requires every trust to have a programme of internal scrutiny, overseen by an audit and risk committee appointed by the board, with written terms of reference and an annual programme of work. Trusts with annual revenue income over £50 million, based on their last audited accounts, must have a dedicated committee and must deliver internal scrutiny through an in-house internal auditor or a bought-in internal audit service, or both; other trusts may combine the committee with another committee, such as finance. The committee should meet at least three times a year; employees should not be members and the chair of trustees should not chair it; and at least one member should have recent or relevant accountancy or audit assurance experience (3.6 to 3.11 and 3.17). Internal scrutiny must be independent of the senior leadership and finance team, and its annual summary report goes to the DfE with the accounts by 31 December (3.1 to 3.21). The trust must also maintain a risk register, fully reviewed by the board at least annually, and its management of risks must include contingency and business continuity planning (2.43 and 2.44). Every trust must also complete the school resource management self-assessment checklist and submit it to the DfE by the annual deadline (6.6).
Part 4 sets the calendar for the annual report and accounts: audited, submitted to the DfE by 31 December, published on the trust's website by 31 January, filed at Companies House by 31 May, and provided to every member (4.4). The accounting officer signs a statement on regularity, propriety and compliance, which the external auditor reviews (4.12 and 4.13).
Part 6 is where the records duty becomes explicit. The trust must give the DfE or its agents "access to all books, records, information, explanations, assets, premises and staff", and the DfE may take copies (6.3). The trust must retain records verifying provision under the handbook and funding agreement for "at least 6 years after the period to which funding relates" (6.5). The board must notify the DfE as soon as possible of fraud, theft or irregularity over £5,000, individually or cumulatively in any financial year, and of any unusual fraud whatever its value, giving full details with dates, the financial value of the loss, measures taken to prevent recurrence, whether it was referred to the police (and if not, why) and whether insurance or the RPA has offset any loss (6.10). Trusts must not pay any ransom or extortion demand, including cyber ransomware (6.15). Where there are concerns, the DfE may issue and publish a notice to improve; its examples include breaches of related party requirements, poor internal scrutiny and trustees failing to comply with their safeguarding duties (6.18).
The DfE publishes separate record keeping and retention information for academies and academy trusts, which the handbook signposts. A trust's retention schedule should cover board and committee papers, the register of interests, approvals sought from the DfE and the evidence behind each decision the handbook asks to be recorded.
The approval given by text before the meeting
The handbook assumes decisions are taken at meetings, or under a scheme of delegation, and minuted. Trusts do not always work that way. The CFO messages the chair on a Sunday to say the boiler quote has come in over the delegated limit and the contractor can start on Monday; the chair replies "fine, go ahead, we'll ratify". A trustee mentions in the board's group chat that her brother-in-law's firm could do the IT contract. The accounting officer, uneasy about a severance figure, says so in a direct message to the chair rather than in the formal written advice paragraph 1.42 requires.
Each of those is a record the handbook cares about: an approval outside the scheme of delegation, a related party interest that belongs on the register and in a declaration, and advice that must be given in writing. If they exist only on personal phones, the trust cannot produce them when the DfE exercises its right of access under paragraph 6.3, and the minutes of the next meeting show a ratification with no trace of what was actually decided, when, or by whom.
The fix is not to stop trustees and officers messaging each other; a trust that can reach its chair on a Sunday is being run. It is to have that conversation somewhere the trust holds, and to bring the decision back to the minutes. ComplyChat provides a channel for board and executive conversations, with everyone added told that it is on the record and able to object or leave. A mobile number verified by SMS is an identity on it, so members, trustees and local governors with no trust email account can be in the same channel as the executive. On paid plans, once the tenant is connected, conversations are kept in the trust's own Microsoft 365 subscription, under the retention schedules it already runs. It does not replace the scheme of delegation, the register of interests, the DfE's forms or the minutes; it keeps the conversation that led to them. ComplyChat Free is personal messaging with one private group, direct messages and three calendar months of recent history, with no Microsoft 365 archive; upgrading cannot restore expired history.
A question for the next board or audit and risk committee meeting: if the DfE asked to see how the last decision above a delegated limit was approved, would the trail start with the minutes, or with somebody's phone?
Questions people ask
How much does the CEO of an academy trust earn?
The Academy Trust Handbook sets no salary scale for academy trust chief executives; the board of trustees decides executive pay through a robust, evidence-based process documented in its pay policy, and the DfE may challenge the decision (2.31 and 2.32). From 1 October 2026, a new appointment paying more than £174,000 needs DfE approval before the post is advertised (2.34), and every trust must publish on its website how many employees received benefits over £100,000, in £10,000 bands (2.35).
Are academies profit making?
No. GOV.UK's Types of school: academies page says academy trusts are not-for-profit companies, and the handbook describes their trustees as both charity trustees and company directors (1.8). The handbook also limits what members, trustees and related parties can make from supplying the trust: once a trust's contracts with such a party pass £2,500 in a financial year, the element above £2,500 must be at no more than full cost, which must not include any profit (5.46, 5.51 and 5.56).
What funding do academies get?
Academies receive their funding directly from the government and do not charge fees, according to the same GOV.UK page. For general annual grant (GAG), the handbook sets pooling rules: a trust with several academies can pool GAG into one central fund, but must consider each academy's funding needs and allocations and have an appeals mechanism, with unresolved appeals escalable to the DfE, whose decision is final and can disapply pooling; private finance initiative (PFI) funding must not be pooled (5.30 and 5.31). Pooling and the removal of GAG carry-forward limits are not available to a trust if any of its funding agreements still allows GAG on estimated pupil numbers without requiring a permanent move to census-based funding, and in that case none of its academies can use them (5.29 and 5.57 to 5.61). Multi-academy trusts must also publish a summary of how funds are distributed across their schools by 31 January (5.32).
Official guidance and your next step
The primary source is the Academy Trust Handbook 2026, with its Schedule of Musts, on the handbook's GOV.UK page, which also holds the 2025 edition, the one that applied until the 2026 edition took effect on 1 October 2026. Paragraph numbers and quotations in this guide are from the 2026 edition as published on GOV.UK in September 2026. The handbook points to the DfE's Academy trust governance guide, the Academies accounts direction, and the DfE's guidance on related party transactions, and to the Charity Commission's guidance for trustees.
This guide is a practical starting point for academy trusts in England, not legal or accounting advice about a transaction, a severance payment or a funding agreement. Your external auditor and your governance professional are the right people to check your reading of a specific paragraph.
Then do one thing: have the governance professional take the Schedule of Musts for 2026, mark each new or changed requirement against the policy or record that shows the trust meets it, and bring the gaps to the next board meeting as an agenda item with an owner for each.
We build ComplyChat for the work conversations organisations need to keep. The Academy Trust Handbook asks for decisions to be approved, documented and producible, and in most trusts some of those decisions are first made in a message between meetings. Explore Free personal messaging, or compare the paid plans if your trust needs to meet its retention schedules within its own Microsoft 365 subscription.
Sources
Every document this guide quotes or links to, in the order it first cites them.
- Academy Trust Handbook gov.uk
- 2026 edition gov.uk
- Types of school: academies gov.uk
- Related party transactions gov.uk




