Allergy safety in schools - key takeaways from the DfE’s latest update

The session provided some useful “direction of travel” indications on the proposed allergy safety framework, the Children’s Wellbeing and Schools Bill, and the forthcoming statutory guidance on supporting children and young people with medical conditions and allergies.

While some details are still being worked through, the key message was clear: the DfE expects allergy safety to become a much more formalised and visible part of school compliance, governance and safeguarding from September 2026 onwards.

Children’s Wellbeing and Schools Act: what schools should expect

The DfE confirmed that, from September 2026, maintained schools and academies are expected to:

have an allergy safety policy in place
have regard to the updated statutory guidance
comply with any related regulations introduced under the legislation.

The Children’s Wellbeing and Schools Act also requires the DfE to introduce equivalent arrangements for independent schools and non-maintained special schools (NMSS) through their own regulatory frameworks.

Importantly, the DfE indicated there is a clear commitment from central government that the core allergy safety measures will come into force from September 2026.

However, the duty is not currently expected to extend to post-16 institutions or EYFS settings.

Further regulations are expected after September 2026

The DfE also suggested that more detailed operational requirements are likely to follow through regulations after the initial implementation phase.

Statutory guidance unlikely to change significantly

The consultation on the draft guidance appears to have received a generally positive response.

The DfE indicated that the final guidance is therefore unlikely to change substantially from the current draft, with publication anticipated in the summer term before the end of the academic year.

This means schools should not assume that the proposals are merely aspirational; in practice, the draft guidance is likely to provide a strong indication of future expectations.

Allergy safety policies will be mandatory

One of the clearest messages from the session was that schools will be expected to have an allergy safety policy in place from September 2026.

This reflects the broader shift towards treating allergy safety as a core safeguarding and health and safety issue, rather than simply an aspect of medical needs management.

Inspection focus is likely to increase

The DfE indicated that Ofsted is expected to pay greater attention to how schools support pupils with allergies, particularly in relation to:

inclusion
safeguarding
pupil safety and wellbeing.

This is likely to mean increasing scrutiny not only of whether policies exist, but also whether schools can demonstrate that procedures are understood and implemented effectively in practice.

Training: a culture shift, not just emergency response

The session also provided useful clarification on staff training expectations.

The DfE emphasised that allergy awareness should not be viewed narrowly as akin to first aid training. Instead, it should be approached more like a fire drill culture, ensuring that everyone understands the risks, knows how to respond, and contributes to reducing avoidable exposure to allergens.

Importantly, the DfE suggested that awareness should extend beyond teaching staff and could include:

caretakers
cleaners
school transport staff
minibus drivers
catering teams.

The DfE indicated that what training should cover is likely to become a non-negotiable expectation, although there will probably be flexibility around how training is delivered.

Funding and spare adrenaline devices

The DfE acknowledged concerns about pressure on the supply chain and indicated it is conscious of avoiding shortages of adrenaline devices and so favoured a phased introduction.

The DfE indicated that it is not currently planning to provide additional funding for spare adrenaline auto-injectors.
Current estimates suggest schools may need to budget approximately £300–£600 per school for spare devices.

The Department also stated that it is working with suppliers to explore discounted access to devices.

Further guidance is expected on:

when spare pens should be used
parental consent issues
interaction with MHRA and HSE guidance.

The DfE suggested that the updated guidance should ultimately be treated as the definitive source once finalised.

Home-to-school transport and off-site activities

The DfE confirmed that schools’ responsibilities extend to school-organised activities, although not necessarily to independent third-party use of school premises, such as facility hire arrangements.

Questions around home-to-school transport remain more complex because local authorities are generally responsible for transport arrangements. However, the DfE indicated it is continuing discussions with local authorities on this issue.

The DfE reiterated the importance of pupils with severe allergies carrying their own prescribed adrenaline devices wherever possible.

Individual Healthcare Plans

The DfE also provided further insight into how it views Individual Healthcare Plans (IHPs).

The intention is that IHPs should be used for pupils whose conditions require active management, rather than for every minor condition.

The DfE drew comparisons with the concept of reasonable adjustments, indicating that a highly individualised approach is still intended.

The key principle remains ensuring that staff understand:

the pupil’s needs
what support is required
and how to respond appropriately to keep children safe.

Governance and leadership roles

The DfE indicated that it is still considering whether the final guidance will require a formal Designated Allergy Governor, following feedback received during the consultation.

However, it was clear that the DfE does expect schools to identify a Designated Allergy Lead within the senior leadership team.

This reflects the wider emphasis on ensuring clear accountability and operational oversight of allergy safety arrangements.

What schools should be doing now

Although the final guidance has not yet been published, the session strongly suggests that schools should begin preparing now.
In practical terms, schools may wish to:

review or develop a dedicated allergy safety policy
review Individual Healthcare Plan processes
consider how allergy incidents and near misses are recorded
identify who will lead on allergy safety within the senior leadership team
review staff awareness and training arrangements
assess arrangements for emergency medication and spare adrenaline devices
consider allergy risks in transport and educational visits planning.

The overall direction of travel is clear: allergy safety is moving towards a more formal compliance, safeguarding and governance framework across schools in England.