We welcome the DfE’s release of two key reporting documents, the Academies Accounts Direction (AAD) 2025-26 and the Academies Model Accounts 2025-26, which set the tone for how trusts must prepare their year‑end accounts for 31 August 2026.
Below, we have broken down the key changes and what they mean in practice for academy trusts.
Trade union facility time
- This disclosure requirement has been removed.
Streamlined Energy and Carbon Reporting (SECR) wording
- The required-to-report criteria is no longer framed as “if the academy trust is a large company” and rather by “If an academy trust meets the qualifying conditions in The Companies (Directors’ Report) and Limited Liability Partnerships (Energy and Carbon Report) Regulations 2018” – in practice this is important because large company thresholds as defined by the Companies Act increased from 6 April 2025, whereas the qualifying conditions for SECR reporting remain unchanged.
- If a Trust meets two of the three following criteria, they must report:
– Turnover > £36m
– Balance sheet total (gross assets) > £18m
– Employees > 250
Internal scrutiny wording
- Simple clarification that trusts with over £50m of annual revenue (based on their last audited accounts) must deliver internal scrutiny through either an employed in-house internal auditor, or by buying in an internal audit service from a specialist provider.
This reiterates that trustee checks and peer review are not allowable options for these entities, given their size.
Higher paid staff disclosures
- Confirming that part-time staff who, if full-time, would earn at least £60,000, must be included in the relevant full-time banding.
(Example: £45,000 gross salary on a 0.7 FTE) - Also, for staff who worked part of the year, but who would have earned at least £60,000 had they worked the whole year, should too be disclosed in the relevant £10,000 band.
(Example: £16,000 total gross salary earned over the months June, July and August 2026 only = £64,000 annual equivalent)
Definition of key management personnel
- Clarifying the definition of key management personnel as being “those persons having authority and
responsibility for planning, directing and controlling the activities of the academy trust, directly or
indirectly.”
In practice, this may result in differences between the staff whose benefits are included in the key management personnel disclosure, and those that are listed in the senior leadership team within the reference and administrative section of the annual report, depending on their duties. - Confirming that senior staff who stay on at a Trust in a consultancy or similar capacity, must be included within this note.
Staff restructuring costs
- In last year’s Direction, trusts were instructed to exclude payments in lieu of notice (whether contractual or non-contractual) from total staff costs.
- The Direction for 2025-26 requires inclusion of PILON within total staff costs.
Disclosure of principal and staff-trustee remuneration
- DfE: “We have clarified that disclosure requirements for related party transactions apply where the principal/chief executive is a trustee” – in practice, the existing “Related party transactions – trustees’ remuneration and expenses” (see note 12 in the model accounts 2025-26) covers this requirement; there are no corresponding changes within the model accounts. This update clarifies that such remuneration to the principal is to be disclosed in this note and treated as a related party transaction.
- Any remuneration paid to a trustee for the trustee role specifically, which remains very rare, must be clearly and separately disclosed.
Church Academy Trusts – Land and buildings income and expenditure
- A Church trust may incur site improvement costs relating to land and buildings which are occupied under a Church Supplemental Agreement and which are not recognised on the balance sheet. The Direction clarifies that Church trusts may recognise a separate site improvement asset in relation to these costs, provided that asset recognition criteria under FRS102 are met.
Once again, the updates lean more toward incremental change than wholesale reinvention, with a continued push towards transparency and consistency across academy trust reporting.
If you would appreciate more information, or to understand how the above changes may impact your trust specifically, please reach out to Ben Burch or Ryan Moore by email or call 01242 776000.


