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Academy Trust Handbook 2026: What HR and Trust Leaders Need to do Before October

Written by Finance Team | 28 Sept 2026
The Academy Trust Handbook 2026 comes into effect on 1 October 2026, introducing changes academy trusts need to understand and act on. 

While many of the updates focus on finance and governance, several have important HR and workforce implications – including new requirements and expectations around executive pay, CFO recruitment, pensions, severance payments, inclusion, governance and strategic workforce planning.


So, what has changed – and what should your Trust be doing now?


We've summarised eight key changes from the Academy Trust Handbook 2026, what they could mean for your people strategy and the practical actions to consider.

Academy Trust Handbook 2026: At a glance

1. What has changed for inclusion and SEND oversight?

The Academy Trust Handbook places greater emphasis on inclusion across academy trusts, particularly for pupils with SEND, disadvantaged pupils and those known to social care.

Trusts should establish and implement a clear, trust-wide approach to inclusion, with consistent approaches to identifying and meeting need, deploying expertise and resources and monitoring pupil access, participation and outcomes.

Boards should also have sufficient oversight of the quality and consistency of inclusive practice, with a designated trustee or committee supporting oversight of inclusion, including SEND.

What should trusts consider?

  • Responsibilities: Are leadership responsibilities for inclusion and SEND clearly defined across your trust?
  • Governance: Does your board have the appropriate knowledge and oversight?
  • Workforce: Do staffing structures and workforce plans support your approach to inclusive provision?
  • Development: Are leaders and employees receiving the training and professional development needed to support inclusive practice?

For HR teams, this could bring increased focus on workforce capability, recruitment, professional development and how specialist expertise is deployed across the trust.

 

2. What are the new expectations for trustee financial expertise?

The Handbook strengthens expectations around the financial knowledge and expertise of academy trust boards.

Boards should identify the skills and experience they need to provide effective oversight, including sufficient financial expertise to hold executive leaders to account. This should extend to relevant committees, local committees and governing bodies.

Appropriate financial training should also be available, particularly for finance committee and audit and risk committee members.

What should trusts consider?

  • Undertake or refresh your trustee skills audit.
  • Identify gaps in financial expertise across the board and relevant committees.
  • Review trustee recruitment against identified skills requirements.
  • Consider whether induction and ongoing trustee development need strengthening.

Although principally a governance requirement, this may create implications for trustee recruitment, induction, succession planning and development.

 

3. What are the new CFO qualification requirements for academy trusts?

There are strengthened expectations around Chief Financial Officer (CFO) qualifications in larger academy trusts.

For trusts with more than 3,000 pupils, any CFO recruitment exercise commencing on or after 1 October 2026 should specify that the individual should:

  • be a qualified accountant and a member of a relevant professional accountancy body, such as ICAEW, ACCA, CIMA, CIPFA or equivalent; and/or
  • hold the CIPFA Level 7 qualification.

For recruitment exercises commencing on or after 1 September 2027, this becomes a mandatory requirement.

Where a trust with more than 3,000 pupils plans to appoint a CFO who is not a qualified accountant or does not hold the CIPFA Level 7 qualification, the DfE must be informed in advance, including an explanation of the trust's decision.

What should trusts do now?

  • Review CFO job descriptions and person specifications ahead of future recruitment.
  • Ensure recruitment documentation reflects the new qualification expectations.
  • Consider the requirements as part of CFO succession planning.
  • Review development plans where future internal candidates may not currently meet the expected criteria.

Planning early could help trusts avoid recruitment or succession challenges as the requirements strengthen.

 

4. How are the executive pay rules changing from October 2026?

The Academy Trust Handbook introduces tighter controls around executive remuneration and senior appointments.

From 1 October 2026, trusts must obtain DfE approval before advertising a new appointment where:

  • remuneration exceeds £174,000, or the pro-rata equivalent for part-time employees; or
  • performance-related pay exceeds £25,000.

Executive remuneration must also not increase faster than teachers' pay unless there is clear justification. Where a trust believes there is justification for doing so, DfE approval must be obtained in advance.

Boards must continue to ensure executive pay decisions follow a robust, evidence-based process and represent a reasonable and defensible reflection of the individual's role and responsibilities.

What should trusts do now?

  • Review executive pay and remuneration policies.
  • Ensure decisions can demonstrate proportionality, value for money and appropriate independent scrutiny.
  • Build potential DfE approval into senior recruitment timelines.
  • Maintain clear evidence of the rationale and approval process behind executive remuneration decisions.
  • Ensure remuneration committees understand the new requirements before considering future appointments or pay awards.

Reviewing executive remuneration?

Explore our Executive Pay Policy Statement and latest guidance on education sector pay.

 

5. What are the new rules on alternative pension arrangements?

From 1 October 2026, academy trusts considering offering an alternative to the Teachers' Pension Scheme (TPS) or Local Government Pension Scheme (LGPS) must approach the DfE for approval early in the planning process.

Crucially, trusts should do this before any proposed changes are communicated to employees, and any alternative arrangement must receive DfE approval before changes are made.

What should trusts do now?

If your trust is considering pension changes:

  • involve HR and appropriate advisers at an early stage;
  • seek DfE approval before communicating proposed alternative arrangements to employees;
  • consider the employee relations, contractual and consultation implications alongside the financial case; and
  • allow sufficient time for governance, approval and any subsequent workforce processes.

This is particularly important where pension arrangements are being considered as part of wider cost-saving or workforce restructuring activity.

 

6. What has changed for severance and settlement payments?

The Academy Trust Handbook provides more detailed requirements around staff severance and special severance payments, including how decisions should be assessed, documented and approved.

Where a proposed severance payment includes a non-statutory or non-contractual element of £50,000 or more, prior DfE approval must be obtained before making an offer to the employee.

Additional circumstances can also trigger prior DfE approval, including certain exit packages of £100,000 or more, payments involving employees earning over £174,000 and payments considered novel, contentious or repercussive.

Trusts are also expected to demonstrate appropriate scrutiny and value for money when considering payments below the £50,000 threshold.

What should trusts do now?

  • Review your settlement agreement and severance approval processes.
  • Check whether DfE approval is required before making an offer or binding commitment.
  • Ensure decisions are supported by an appropriate business case and legal assessment.
  • Maintain clear records of the decision, supporting evidence and relevant advice.
  • Demonstrate how value for money has been considered.

Early advice is particularly important when dealing with complex exits, settlement agreements or situations where there may be potential Employment Tribunal proceedings.

Considering a settlement agreement or severance payment?

Speak to your designated EPM HR Adviser at an early stage. We can help you understand your options, approval requirements and next steps.

 

7. What do the new MAT funding transparency requirements mean for HR?

Multi-academy trusts will be required to publish information explaining how funds are distributed across their schools.

Although primarily a financial requirement, greater transparency could lead to questions from employees and trade unions about differences between academies, including:

  • staffing levels and structures;
  • leadership arrangements;
  • pay-related expenditure;
  • investment in school improvement; and
  • central and local support services.

What should trusts consider?

Trust leaders should be prepared to clearly explain the rationale behind workforce deployment and resource allocation decisions, particularly where approaches differ significantly between schools.

HR, finance and leadership teams may therefore benefit from working together to ensure that workforce decisions are evidence-based, appropriately documented and clearly communicated.

 

8. How does the Handbook affect workforce and curriculum planning?

The Handbook strengthens expectations around integrated curriculum and financial planning.

For trust leaders, this reinforces the importance of considering workforce decisions alongside educational priorities, pupil needs and long-term financial sustainability.

What should trusts consider?

Trusts should be able to demonstrate how decisions about:

  • staffing structures;
  • curriculum delivery;
  • leadership capacity;
  • recruitment;
  • workforce deployment; and
  • organisational change

have been considered alongside affordability and the trust's wider strategic priorities.

Rather than treating workforce and financial planning as separate exercises, HR, finance and curriculum leaders should work collaboratively to understand both the people and financial impact of future decisions.

 

Academy Trust Handbook 2026: HR checklist for academy trusts

With 1 October 2026 approaching, now is the time to identify any gaps in your current arrangements.

Consider whether your trust has:

☐ Reviewed inclusion and SEND leadership responsibilities and governance oversight

☐ Assessed trustee financial skills and development requirements

☐ Reviewed CFO recruitment documentation and succession plans, particularly for trusts with more than 3,000 pupils

☐ Checked executive pay policies and senior remuneration approval processes

☐ Reviewed governance arrangements for any proposed alternative pension provision

☐ Checked severance and settlement agreement approval processes

☐ Integrated workforce planning with curriculum and financial planning

☐ Prepared for greater transparency and scrutiny around how resources are allocated across academies

 

If you’re looking for support or advice to ensure you remain compliant with this year’s Handbook, or would like to learn more about our Finance services, please talk to us.