Senior pay controls for academy trusts
Guidance to support academy trusts in applying senior pay controls for academy trust executives.
Applies to England
Introduction
The senior pay controls for academy trust executives in the 2026 Academy Trust Handbook are effective from 1 October 2026. This guidance will support academy trusts in applying those controls and should be read in conjunction with Setting executive salaries: guidance for academy trusts.
This document gives guidance to academy trusts on:
- when and how to seek approval from the Department for Education (DfE) for senior pay
- what academy trusts must consider before submitting an application
- what DfE will consider when an application is received
Who this publication is for
This guidance is primarily for use by academy trusts’:
- chairs of the board of trustees and trustees with responsibility for senior pay oversight
- accounting officers and chief financial officers
- senior leaders responsible for human resources
- governance professionals
Background
From 1 October 2026, DfE approval must be sought:
- before advertising new appointments in academy trusts where proposed executive remuneration exceeds £174,000 (pro-rata for part-time staff) or where performance-related pay goes above £25,000; or
- where, based on clear justification, academy trusts want to increase executive remuneration at a faster rate than that of the trust’s teachers, regardless of the remuneration value
Remuneration covers all elements of base salary, fees, any pension in excess of normal levels available to comparable staff, and allowances. Allowances constitute extra cash or non-cash benefits in kind aimed at supplementing an employee’s or postholder’s fee or remuneration package. Performance related pay is not included within remuneration and is considered separately.
The requirements aim to ensure appropriate transparency and that executive pay is reasonable and represents the best value for taxpayers in the context of the role. This will bring academy trust senior pay controls in line other senior public sector positions, including further education colleges.
DfE recognises the different levels of size, challenge and complexity across academy trust leadership roles. The £174,000 threshold aligns with HM Treasury’s senior pay controls for appointments in central government and further education colleges. This provides a consistent point at which higher levels of remuneration receive additional scrutiny. The approval process is designed to allow an opportunity for academy trusts to set out an evidence-based case for their proposals, which reflect the trust’s circumstances.
Comparing executive pay and teacher pay increases
For the purposes of these controls, academy trusts should compare any proposed increase in executive remuneration against the average percentage remuneration increase across the trust’s teaching workforce over the same period.
Teachers are defined as staff employed in teaching posts whose pay is determined through teacher pay arrangements. Executive leaders are defined as primarily non-teaching staff in leadership roles in which they are held to account for the standards across the academy trust.
Academy trusts are responsible for calculating this percentage increase using the trust’s own pay arrangements. The comparison should reflect the overall year-on-year change in teacher remuneration within the trust, taking account of actual pay changes during the period, such as annual pay awards, pay progression and other relevant changes to remuneration. It should not be based solely on national teacher pay awards. Trusts are not expected to estimate future increases.
Trusts should be able to explain the methodology used and provide supporting evidence if requested.
Our expectation is that executive pay must not increase at a faster rate of teachers. Where there has been a significant change to executives’ roles, for example the responsibilities have increased substantially as a result of a large expansion, our policy allows for an application to be made in exceptional cases.
Where a proposed increase in executive remuneration exceeds the overall increase in teacher remuneration, trusts should be able to demonstrate why this is justified, proportionate and represents the best value for money in the context of the role and the trust’s circumstances.
Trusts remain responsible for complying with employment law and contractual obligations. Where an employment contract provides for pay increases that would result in an executive’s pay increasing at a faster rate than that of teachers, the trust must apply to the department for approval. The department will not make decisions that overrule a trust’s existing contractual arrangements with employees. The application should include evidence that the proposed increase arises for an existing contractual obligation along with any other necessary supporting information.
Making an application for approval on senior pay decisions
Before submitting an application, academy trusts should refer to the Setting executive salaries: guidance for academy trusts, which sets out the principles of determining executive pay and the requirements for an application. Academy trusts must use the relevant application form. An incomplete application may result in delays to the approval process.
The academy trust pay approvals form asks academy trusts to provide justification for the proposed remuneration. DfE’s financial benchmarking and insights tool may help academy trusts to assess whether the proposed pay is appropriate when compared with similar organisations. When making comparisons, academy trusts should consider factors such as role specification, labour market, location context, provider type and organisational size alongside the other considerations set out in the setting executive salaries guidance. Academy trusts are required to submit one single application form for each approval request. Each application is subject to approval by DfE.
The Multi-academy trust leadership development: CEO content framework may also be of use. It provides information about good practice when assessing potential senior appointments.
Governance and decision-making
Academy trusts should ensure that appropriate governance arrangements are in place before submitting an application for senior pay approval.
The board of trustees should establish appropriate arrangements for overseeing executive pay and senior appointments. This may include a remuneration, pay or people committee with delegated responsibility for reviewing proposals and overseeing recruitment processes.
Academy trusts must ensure:
- executive pay arrangements are consistent with their pay policy and wider governance arrangements
- any decisions on executive pay are subject to appropriate challenge and independent scrutiny by the board, including identifying and managing conflicts of interest
- decisions regarding executive pay are supported by relevant evidence and benchmarking information demonstrating that pay and benefits are reasonable and represent good value for money in the context of the role and the trust’s circumstances
- there is clearly documented decision making and board approval relating to executive pay recommendations prior to implementation
- that remuneration decisions are consistent with their responsibilities under equality legislation
As part of the application process, trusts may be asked to provide assurance that appropriate governance processes have been followed.
How an application is assessed
Applications will be assessed based on consideration of evidence in 5 key areas (a to e).
The factors set out in these areas are intended to help academy trusts ensure their applications are supported by evidence. However, providing evidence against each factor will not automatically result in approval. DfE will assess the strength of the evidence provided as a whole, and decide whether the trust has made a sufficiently robust case for the proposed pay.
Where satisfactory evidence is not provided in each relevant area, DfE may ask the academy trust to provide further evidence.
Applications will be considered against evidence in the following key areas.
a) complete pay package:
- remuneration: this includes all elements of base salary, fees, pension in excess of normal levels available to comparable staff and allowances. Allowances constitute extra cash or non-cash benefits in kind aimed at supplementing an employee’s or postholder’s fee or remuneration package
- pension contribution information: Any employer pension contributions that are not already captured within remuneration
- performance-related pay
- any additional benefits, such as salary-sacrifice arrangements
b) influence and impact of role:
- the nature and extent of the role, the role’s responsibilities and the expected impact of the individual on the academy trust and children’s outcomes
- the context of the role: details about the academy trust’s organisational and leadership structure, size and associated funding level
- for performance related pay, evidence that:
- the proposed performance-related pay arrangements are proportionate and appropriate
- robust performance objectives and success measures are agreed and reviewed regularly
- risks of unintended incentives have been considered and mitigated, for example where performance measures could encourage behaviours that conflict with securing good educational outcomes for all children, financial sustainability or good governance
c) relevant supporting benchmarking data:
- benchmarking data or information relating to comparable roles at similar trusts
- evidence that the proposed pay is reasonable and represents the best value for money in the context of the role
- the remuneration package provided to the previous relevant post-holder, and to employees who directly report to the proposed post holder or hold other comparable leadership roles at the trust. Trusts should not assume that a new post-holder should be recruited with the same remuneration package as their predecessor
Note benchmarking and wider remuneration information provides a useful indicator only - the previous post may have required different qualifications and experience, and the specific circumstances that may have surrounded that appointment may no longer be relevant (for example, the scope of the role may have changed).
d) trust specific factors:
- size of the trust including pupil numbers and budgets
- Ofsted inspection outcomes of the trust’s academies (for example, if there is need to attract a candidate with a track record of improvement)
- trust complexity, for example, due to planned restructuring or intervention or a context of complex challenge
- financial health of the trust
e) labour market considerations and location of the senior employee’s role:
- factors indicative of above-average living costs where the trust is based (for example London weighting or other regional factors)
- details about whether the trust is based in a competitive or urban location, or a rural area where it is difficult to attract high-calibre candidates
- why the role needs to be based in the proposed location and how that location supports the academy trust’s strategic and operational objectives
Supporting evidence
Academy trusts must provide evidence for areas a) to d). Evidence for area e) should be provided where labour market conditions, recruitment challenges or location-specific factors form part of the justification for the proposal. Examples of evidence academy trusts may choose to provide as part of the application can be found below. This list is not exhaustive, and trusts are not expected to provide every item listed. Existing documents and evidence that support the trust’s other governance or recruitment processes may be used where relevant.
a) proposed complete pay package:
- the trust’s pay policy, showing how the proposed remuneration package and any increase are consistent with the trust’s agreed approach to pay
- analysis of executive pay increases against staff pay awards
- evidence of the trust’s approach to managing pay differentials
- justification for any increase that exceeds the rate applied to trust teaching staff
- performance-related pay arrangements
- pension contribution information and payments in lieu of pension contributions
- any sums paid under any pension scheme in relation to the employment with the trust. Where a trust proposes pension arrangements that differ from the Teachers’ Pension Scheme (TPS) or Local Government Pension Scheme (LGPS), it should explain the proposed arrangements and provide evidence of any discussions with DfE where approval is required
- salary sacrifice arrangements
- compensation for loss of office
- other taxable benefits
- non-taxable benefits that are available only to senior members of staff
- other remuneration and cost to the trusts, for example car allowance
b) influence and impact of the senior employees role:
- job description and person specification
- organisational structure
- statement of role impact
- information about proposed objectives and key performance indicators (KPIs)
c) relevant supporting benchmarking data:
- benchmarking information
- comparator role information
- previous post-holder information
- total reward analysis
d) trust specific factors:
- size and budget of the academy trust
- Ofsted outcomes for the trust’s academies, where available
- trust development plans
- evidence of complexity
- trust’s financial information
- explanation of how these factors increase the challenge of the role
e) labour market considerations and location of the senior employee’s role:
- location based cost indicators
- evidence of previous recruitment campaign challenges (where relevant)
- salary comparisons in the area where the role will be based
- regional comparator analysis
- assessment of regional pay variation
- location strategy
- evidence of wider market conditions and local recruitment challenges affecting the role
- evidence that the proposed pay is appropriate for the local context
Application and approval process
Where DfE approval is required, the academy trust must complete the relevant Approval for senior pay and reward packages in academy trusts: application form.
We recommend academy trusts submit their application at the earliest opportunity. Where DfE approval is required, academy trusts should ensure that any appointment remains subject to the necessary approval being obtained. Academy trusts may wish to seek employment advice to ensure adverts are carefully drafted to avoid creating any contractual entitlement. Obtaining DfE approval before advertising reduces the risk of delays in the recruitment process.
After submission:
- After submitting an application form, academy trusts will get an automated acknowledgement.
- On receipt by DfE, the application will be allocated to the relevant regional team for assessment. The regional team may contact the academy trust if further information is required.
- Once the application has been considered, we will notify the academy trust of the outcome via the Regional Director’s office. If the application has been unsuccessful, feedback will be provided.
DfE will seek to process applications as quickly as possible. Academy trusts should allow a minimum of 20 working days for a decision when planning recruitment and pay processes.
Reconsideration process
Where an academy trust wishes to request reconsideration of DfE’s decision, a request must be submitted via email within two-calendar months of notice of the decision being given.
If a request is submitted after two-calendar months, reconsideration will be at the Regional Director’s discretion. Information on how to request a reconsideration will be included in the decision response.
A reconsideration can only be requested where:
- the trust can provide additional supporting evidence that was not available at the time of the original application (for example a failed round of recruitment or other material changes in circumstances), or
- the trust wishes to revise its proposal following DfE’s decision, that is for lower remuneration, performance-related pay or a percentage increase above that paid to teachers at the trust.
This information must be clearly documented in the email. Requests that do not meet either of these circumstances are unlikely to be reconsidered.
If you are unhappy with the way your application has been handled or want to make a complaint about a Regional Director’s decision, email RegionsGroup.COMPLAINTS@education.gov.uk.
Provide as much detail as you can to help us investigate your complaint:
- say which regional director you’re referring to
- say what the problem is
- say what you want to happen
- provide information on any relevant communication with us on the subject, including, for example, any reference numbers on letters or emails, and the times and dates of any conversations
All formal complaints will be investigated in line with the Department for Education’s complaints procedure.
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