Government is raising the bar for Multi-Academy Trust governance. Can you evidence what happens after procurement?

For Multi-Academy Trust boards and public sector end-hirers

Multi-Academy Trust governance now turns on a harder question than whether the right policies exist. The Department for Education is raising expectations around procurement, governance and transparency, and the next test for every Multi-Academy Trust (MAT) is whether it can evidence that its controls operate consistently across every supplier, every school and every engagement.

That is where Labour Supply Chain Assurance (LSCA) begins.

The governance responsibilities of Multi-Academy Trusts continue to evolve. Alongside delivering high-quality education, Trusts are expected to demonstrate sound financial stewardship, robust procurement, effective governance and appropriate oversight of increasingly complex labour supply chains.

The publication of the Academy Trust Handbook 2026, together with the Department for Education’s new requirements for the procurement of supply staff, reinforces that direction of travel.

The new Handbook provides the overarching framework for financial governance, management and other controls within academy trusts in England. Compliance with its requirements is a condition of each Trust’s funding agreement with the Secretary of State for Education.

These developments matter because they raise expectations around how Trusts demonstrate that their governance arrangements are operating effectively.

Procurement is only the starting point

Department for Education and UK Government Commercial Agency (formerly Crown Commercial Service) guidance says that, from September 2026, single and Multi-Academy Trusts must use the Supply Teachers and Education Recruitment framework when procuring supply staff, unless an alternative arrangement satisfies the requirements set out by the Department.

The new framework is intended to improve value, visibility and consistency within the supply-staffing market. It is an important procurement control. However, appointing a supplier is only one governance decision. Strong Multi-Academy Trust governance treats that appointment as the first control, not the last.

Multi-Academy Trusts must also be able to demonstrate that appropriate controls continue to operate throughout each engagement.

• Has supplier due diligence been completed and kept current?
• Can worker onboarding be evidenced?
• Are identity, safeguarding and right-to-work requirements being verified consistently?
• Are contractual and commercial obligations being monitored?
• Can exceptions, concerns and corrective actions be identified and followed through?
• Can decisions and supporting evidence be retrieved months or years later?

Procurement creates a controlled route through which a supplier can be selected. Labour Supply Chain Assurance provides the evidence needed to show what happens throughout the resulting relationship.

Multi-Academy Trusts face a particular assurance challenge

A Multi-Academy Trust may bring together schools with different histories, operating practices, local supplier relationships and workforce requirements. Like other end-hirers, a Trust sits at the head of a labour supply chain it does not directly employ.

Its labour supply chain can extend beyond recruitment agencies and temporary teaching staff to include:

• education and classroom support workers;
• specialist provision and intervention services;
• estates and maintenance contractors;
• facilities management providers;
• cleaning and catering services;
• IT and technical support suppliers;
• professional advisers and consultants; and
• other outsourced and contingent workers.

Each relationship can introduce governance responsibilities, contractual obligations and compliance risks. This breadth is what makes Multi-Academy Trust governance harder to evidence than oversight of a single school.

Without a consistent Trust-wide framework, individual schools can naturally develop different processes. Information may be recorded in separate spreadsheets, inboxes, shared drives, supplier portals and local filing systems. That fragmentation makes central visibility and reliable Board assurance harder to achieve.

DfE experience shows why central visibility matters

A June 2026 Department for Education Buying for Schools case study examined how one large academy trust changed its approach to supply staffing.

Before that work began, schools across the Trust were engaging different agencies under different commercial terms. The case study identified limited central oversight of spend, quality and safeguarding, as well as poor visibility of agency margins and potential risks relating to worker status.

The example is important because it illustrates that supplier use can become fragmented even within an established Trust. Approved procurement routes can help improve the starting point. Trust-wide assurance must then provide continued visibility of what suppliers and internal teams are doing in practice.

Multi-Academy Trust governance increasingly depends on evidence

The Academy Trust Handbook requires Trusts to maintain appropriate systems of internal control, risk management and internal scrutiny. The Department for Education’s internal scrutiny guidance for academy trusts is intended to help trustees maintain effective stewardship, oversight and an adequate governance and control environment.

This is not simply a question of whether policies have been written. Trust Boards need assurance that controls are suitable, are being followed and are operating effectively.

Policies explain what should happen. Evidence demonstrates what did happen.

The distinction becomes particularly important when responsibility is distributed across a central Trust team, individual academies, hiring managers, procurement teams, recruitment agencies and other labour suppliers.

The assurance gap between appointment and delivery

Traditional supplier assurance is often concentrated around particular moments:

• the procurement exercise;
• initial supplier onboarding;
• an annual questionnaire;
• a scheduled audit;
• contract renewal; or
• the investigation of a problem.

These checks remain important, but they provide assurance at selected points in time. They may not demonstrate that requirements were met consistently between those points.

When evidence is held across emails, spreadsheets and separate systems, identifying gaps can become a retrospective exercise. Documents are gathered only when a question, audit or incident creates an urgent need for them. Labour Supply Chain Assurance takes a more continuous approach.

What is Labour Supply Chain Assurance?

Labour Supply Chain Assurance (LSCA) is a structured approach to establishing, maintaining and evidencing effective governance throughout a labour supply chain. It connects the requirements placed upon suppliers, workers and internal stakeholders with the evidence needed to demonstrate that those requirements have been met.

Depending on the nature of the engagement, this evidence can include:

• supplier selection and onboarding;
• worker onboarding;
• due-diligence records;
• identity and right-to-work verification;
• safeguarding-related evidence;
• contract and statement-of-work governance;
• employment-status considerations where relevant;
• payroll controls, including payslip, BACs payment and Real Time Information (RTI) verification;
• VAT due diligence and labour supply chain VAT checks;
• policy acceptance and compliance;
• ongoing monitoring;
• identified exceptions and corrective actions;
• management and Board reporting; and
• records required for internal scrutiny or audit.

Instead of relying on declarations or trying to recreate events retrospectively, the Trust develops a living evidence base as activity takes place.

Payroll and VAT checks belong in the same evidence base

Two areas deserve particular attention in an education supply chain: how workers are paid, and how VAT is handled by the suppliers behind them. Both sit within Labour Supply Chain Assurance, and both are far easier to evidence when the checks are recorded as they happen rather than reconstructed later.

Payroll controls give a Trust confidence that the people working in its schools are paid correctly and through legitimate routes. Three checks matter in particular:

• Payslip verification confirms that workers receive compliant, itemised payslips.
• BACs payment verification confirms that pay reaches the worker’s own account through a recognised payment run rather than an irregular route.
• Real Time Information (RTI) verification confirms that PAYE has been reported to HMRC in line with the payments actually made.

VAT due diligence sits alongside these payroll checks. Where a Trust engages agencies and other labour providers, HMRC’s supply chain due diligence guidance asks end-hirers to understand and check the supply chains behind their suppliers. OPRaaS reads that guidance as expecting reasonable checks that suppliers are correctly VAT registered, that VAT is charged and accounted for properly, and that the chain shows no signs of the missing-trader or mini-umbrella arrangements associated with labour supply fraud.

The point matters commercially as well as ethically. HMRC’s guidance is clear that an organisation which knew, or should have known, that its supply chain was connected with fraud can face additional cost and lose the right to recover input VAT. Recording those VAT checks turns a point-in-time review into part of the continuous evidence base that Labour Supply Chain Assurance maintains.

One Trust, multiple schools, one assurance standard

Labour Supply Chain Assurance is particularly relevant to Multi-Academy Trusts because it can establish a consistent governance standard without removing the ability of individual schools to meet local operational needs.

A Trust-wide LSCA framework can help central teams understand:

• which suppliers and labour arrangements are being used;
• which assurance activities have been completed;
• where required evidence is outstanding;
• where processes differ between schools;
• which risks or exceptions require intervention;
• whether remedial actions have been completed; and
• what evidence supports reports presented to senior leaders and trustees.

This creates a clearer connection between policy, operational activity and Board-level assurance. It is also how Multi-Academy Trust governance stays consistent as a Trust grows.

The role of the OPRaaS Virtual Compliance Director

The OPRaaS Virtual Compliance Director helps organisations embed Labour Supply Chain Assurance within everyday governance. The service combines an operational assurance framework with the OPRaaS VCD platform, helping organisations establish responsibilities, record evidence, identify gaps and maintain visibility throughout their labour supply chains.

For a Multi-Academy Trust, this can support:

• consistent supplier and worker assurance across multiple schools;
• clear ownership of governance activities;
• central oversight without dependence on fragmented spreadsheets;
• earlier identification of missing or incomplete evidence;
• structured management of exceptions and corrective actions;
• evidence-based reporting to executive teams and trustees;
• support for procurement, internal scrutiny and risk management; and
• a continuously maintained record that can be handed over when required.

It moves compliance away from periodic document collection and towards continuous, demonstrable assurance. For boards, that is what turns Multi-Academy Trust governance from a paperwork exercise into an operating discipline.

Evidence builds confidence

The direction of travel for Multi-Academy Trust governance is clear. The Department for Education is raising expectations around procurement, governance and transparency.

New supply-staff procurement requirements will create a more controlled starting point for many engagements. But the responsibility to oversee suppliers, monitor delivery and demonstrate that governance controls are operating does not end when a framework or agency is selected.

For Multi-Academy Trusts, the question is no longer simply whether the correct policies and procurement routes exist. It is whether the Trust can produce reliable evidence that its controls operated consistently across every supplier, every school and every engagement. Multi-Academy Trust governance is becoming an evidence discipline.

That is the purpose of Labour Supply Chain Assurance. As a public sector organisation, a Multi-Academy Trust can turn that assurance into a genuine governance asset rather than a periodic scramble for paperwork.

At OPRaaS, we believe compliance should become an organisational asset. If your Trust cannot yet hand over a single, current evidence file for its labour supply chain, that is where the work begins. To discuss how the OPRaaS Virtual Compliance Director can help, arrange an OPRaaS VCD discussion.

Because confidence is built through evidence, not assumptions.

Compliance is your asset. Evidenced daily.

Drawing on the Department for Education Academy Trust Handbook 2026; the DfE internal scrutiny guidance for academy trusts; the UK Government Commercial Agency Supply Teachers and Education Recruitment framework (RM6376); HMRC’s supply chain due diligence guidance for labour supply chains; and the DfE Buying for Schools case study on trust-wide supply staffing.

Sources and further reading

• Department for Education: Academy Trust Handbook 2026
• Department for Education: Internal scrutiny in academy trusts
• UK Government Commercial Agency: Supply Teachers and Education Recruitment framework (RM6376)
• HMRC: Advice on applying supply chain due diligence principles to assure your labour supply chains
• Department for Education, Buying for Schools: A better deal on agency supply staff
• Department for Education, Buying for Schools: How Shaw Education Trust took control of supply staffing

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