Form

Preview of FMGS questions

Updated 1 September 2025

Applies to England

Introduction

This document provides a list of the questions in the FMGS for trusts to review before accessing the online form.

The FMGS helps new academy trusts ensure compliance with the requirements of the Academy trust handbook (ATH).

The requirements in the FMGS checklist apply from the date on which the funding agreement was signed, so new academy trusts should ideally consider an FMGS before opening their first schools.

Feedback from trusts indicates that the FMGS is a very useful tool providing helpful assurance to the board of trustees that governance arrangements meet the mandatory requirements.

Financial oversight

1. Has the board appointed a senior executive leader? [ATH 2025: 1.28]

2. Has the trust permanently appointed the senior executive leader as the accounting officer? [ATH 2025: 1.29]

3. Does the accounting officer have appropriate oversight of financial transactions? [ATH 2025: 1.34]

4. Has the trust appointed a chief financial officer (CFO) with appropriate qualifications and experience? [ATH 2025: 1.39 and 1.40]

5. Do the trustees apply the highest standards of conduct, and ensure strong governance and effective financial management? [ATH 2025: 1.11 and 1.12]

6. Has the trust appointed a governance professional (clerk to the board) to assist the board of trustees? [ATH 2025: 1.42]

7. Does the board meet at least 3 times each year to ensure strong governance and sound financial management? [ATH 2025: 2.3]

8. Please confirm that the trust has not used funds to purchase alcohol for any purpose other than religious services. [ATH 2025: 2.32]

9. Please confirm that the trust has not used funds to pay any cyber ransomware demands. [ATH 2025: 6.15]

Financial planning and reporting

10. Does the trust prepare management accounts every month? [ATH 2025: 2.18]

11. Are management accounts reviewed at every board meeting and shared with the chair of trustees every month? [ATH 2025: 2.19]

12. Does the trust have processes to meet the deadlines for submitting financial and budgetary returns to DfE[ATH 2025: 2.15, 3.20, 4.4 and 6.6]

13. Has the board approved a balanced budget and minuted its approval? [ATH 2025: 2.10]

Risk management and internal control

14. Does the trust have a risk management process? [ATH 2025: 2.22 and 2.35]

15. Does the trust have a contingency and business continuity plan? [ATH 2025: 2.36]

16. Does the trust have adequate insurance cover? [ATH 2025: 2.37 and 2.38]

17. Has the board approved a written scheme of delegation of financial powers? [ATH 2025: 2.4]

18. Has the trust established a sound internal control framework? [ATH 2025: 2.6]

19. Does the trust have whistleblowing procedures? [ATH 2025: 2.40 to 2.44]

20. Does the trust have controls designed to prevent cybercrime? [ATH 2025: 6.14]

Internal and external assurance

21. Does the trust have an audit and risk committee which meets at least 3 times a year? [ATH 2025: 3.6 to 3.13]

22. Does the trust have an internal scrutiny programme to provide independent assurance to the board that its controls and risk management procedures are operating effectively? [ATH 2025: 3.1 to 3.5, 3.8, 3.15 to 3.17]

23. Does the trust submit an annual summary report of the internal scrutiny work carried out throughout the year? [ATH 2025: 3.20]

24. Has the trust appointed an external auditor? [ATH 2025: 4.5]

25. Does the trust have processes to implement findings, recommendations or actions from the external findings report, internal scrutiny reports and this FMGS return? [ATH 2025: 3.4]

26. If the trust’s annual revenue income is over £50 million, do you have either an in-house internal auditor or a bought-in internal audit service from 1 September 2025? [ATH 2025: 3.16]

Delegated authorities

27. Does the trust have a process to inform the board of trustees when DfE requires prior approval (above the limits stated in the academy trust handbook) for the following?

  • severance, compensation and ex-gratia payments [ATH 2025: 5.6 to 5.17]
  • write-offs, guarantees, letters of comfort and indemnities [ATH 2025: 5.18 to 5.21]
  • acquisition and disposal of fixed assets [ATH 2025: 5.22 and 5.23]
  • finance leases or leaseholds and tenancy agreements on land or buildings [ATH 2025: 5.25]

28. Does the trust have a process to inform the board of trustees when DfE requires prior approval for the following?

  • novel, contentious and repercussive transactions [ATH 2025: 5.5]
  • borrowing [ATH 2025: 5.32]
  • entering into a new electric vehicle salary sacrifice scheme [ATH 2025: 2.31]
  • accepting any further employees onto an existing new electric vehicle salary sacrifice scheme [ATH 2025: 2.31]

29. If the trust pools its general annual grant (GAG) funding, does it have an appeals process for its schools? [ATH 2025: 5.30]

30. Does the trust have procurement controls? [ATH 2025: 2.24]

31. Does the trust have measures to manage conflicts of interest in related party relationships? [ATH 2025: 5.35 to 5.39]

32. Does the trust’s register of interests capture all relevant business and pecuniary interests of members, trustees, local governors and senior employees? [ATH 2025: 1.45 to 1.48]

33. Is the trust aware that they must declare all contracts and agreements with related parties to DfE before the contract or agreement starts? [ATH 2025: 5.40]

34. Is the trust aware that they must get prior approval for contracts and other agreements with related parties in line with the limits outlined in the academy trust handbook? [ATH 2025: 5.41]

35. Is the trust aware that they must pay no more than ‘cost’ for goods or services provided by the related parties (individuals and organisations) outlined in the academy trust handbook? [ATH 2025: 5.44 to 5.54]

Executive pay and transparency

36. Is executive pay (including salary and any other benefits) decided through an evidence-based process? [ATH 2025: 2.27 and 2.28]

37. Do senior employees’ payroll arrangements meet tax obligations fully and comply with HM Treasury’s guidance? [ATH 2025: 2.30]

38. Has the trust published, or does it plan to publish, the following information on its website?

  • the trust’s governance arrangements [ATH 2025: 1.49]
  • the relevant business and pecuniary interests of members, trustees, local governors and accounting officers [ATH 2025: 1.45]
  • audited annual accounts by 31 January [ATH 2025: 4.4]
  • whistleblowing procedures [ATH 2025: 2.40]
  • the number of employees whose benefits exceeded £100,000, in £10,000 bandings, as an extract from the disclosure in its financial statements for the previous year ended 31 August [ATH 2025: 2.29]

39. Is the board aware of the requirement to report to DfE any instances of fraud or theft above £5,000 against the trust, or where fraud is unusual and systematic in nature? [ATH 2025: 6.10]

40. Has the trust notified DfE of changes in governance via the Get information about schools (GIAS) register? [ATH 2025: 2.46 to 2.50]