Inclusion strategies: a new requirement for academies and maintained schools

Where has the requirement come from?

The new requirement is linked to the Inclusive Mainstream Fund, through which the Government is providing £400 million a year to schools for three years to support earlier intervention and strengthen inclusive mainstream provision.

For 2026/27, the IMF is being paid as a separate grant. The grant is made by the Secretary of State under section 14 of the Education Act 2002, with conditions imposed under section 16.

For 2026/27, publishing the strategy is a condition of the IMF grant. Separately, the Government has proposed introducing a legal duty requiring schools to produce a more comprehensive inclusion strategy as part of its wider SEND reforms.

The DfE describes the strategy required this year as an "initial inclusion strategy", intended to help schools prepare for the proposed future system.

Key points for schools

The requirement applies to mainstream maintained schools, academies and free schools receiving school-level IMF funding.
A multi-year strategy is permissible, providing it is reviewed annually with a note of this on the cover page of the document.
The strategy should address the school's overall approach to inclusion, rather than simply explaining how its IMF allocation will be spent.
Schools should identify commonly occurring and predictable needs and barriers to learning and participation across their cohort.
The strategy should cover both universal inclusive provision and targeted support, where appropriate.
Governors and trustees should scrutinise the strategy and the use of IMF funding.
For multi-academy trusts, each academy must publish its own strategy, even where funding is pooled or activity coordinated across the trust.
The DfE has published guidance and a template to help schools prepare their strategy.

What is an inclusion strategy?

The strategy is intended to explain how the school identifies and responds to the needs and barriers experienced by its pupils and how its resources are being used to build an inclusive core offer.

The DfE expects schools to consider the commonly occurring and predictable needs within their cohort, including needs which may not yet have resulted in a diagnosis or formal identification of SEND.

Schools should therefore look beyond their SEN register and EHC plans. Relevant information might include classroom observations and assessments, attendance and behaviour data, attainment information and engagement with pupils, families and external professionals.

The aim is to identify themes and barriers across the school population and consider what can be done through high-quality universal provision and, where necessary, targeted intervention.

What should the strategy include?

The DfE has produced an Inclusion Strategy Template which schools can use when preparing their statement.

The template suggests keeping the published strategy to 500 words or fewer, written in an accessible way so that pupils and parents can understand the school's overarching aims.

It prompts schools to address four key areas.

Statement of intent: detailing the school's objectives for whole-school inclusion, how the strategy will help achieve them, how the DfE's seven principles of inclusion (see below) are reflected and how families and the wider school community have been involved in developing the approach.
Barriers to learning and participation within their cohort, including any notable trends or increasing complexity.
Activities being prioritised during the academic year to address those barriers, whether the activity is universal or targeted, the evidence supporting it and the budget allocated. The DfE makes clear that "activity" is simply a reporting term and does not mean that funding should be restricted to targeted interventions: activity can include improvements to the school's universal offer.
Outcomes the school intends to achieve and the success criteria that will be used to measure them. From the second year onwards, the strategy should also review the previous year's progress and impact, including the effect on pupils' participation, attendance, engagement, sense of belonging and attainment.

It is not just about the new funding

The inclusion strategy should not be treated simply as a statement explaining how the new IMF allocation has been spent.

The DfE template describes the strategy as covering inclusive practice funded through the school's core school budget, including the notional SEN budget, as well as the IMF.

The strategy should tell a coherent story about the school's overall approach to inclusion: what needs and barriers it has identified, what it is already doing, what it intends to strengthen or change and what impact it expects those measures to have.

That also reflects the way the IMF itself operates. The funding is allocated at school rather than individual-pupil level. It is not a personal budget attached to particular pupils, nor does a pupil need a diagnosis or EHC plan before the school can use the funding to meet their needs.

What are the seven principles of inclusion?

Activities funded through the IMF must align with at least one of the DfE's seven principles of inclusion. Broadly, these cover:

Ambitious leadership and governance which embeds inclusion;
Evidence-based support and early intervention;
High-quality adaptive teaching and curriculum design;
Inclusive enrichment and opportunities beyond the classroom;
A safe and respectful culture which supports belonging and attendance;
Strong partnerships with families and wider services; and
Inclusive and accessible environments.

Schools do not need to devise activity under every heading. The DfE encourages schools, particularly in the first year, to focus on a small number of impactful activities based on the barriers they have actually identified.

What is the role of governors and trustees?

Governance should form part of the process rather than being an afterthought before publication.

Governors and trustees are expected to scrutinise the inclusion strategy, including the school's planned and actual use of IMF funding and the outcomes achieved. Schools should therefore build sufficient time into their autumn-term timetable for appropriate governing body or trustee oversight before the strategy is published.

The DfE may also review published strategies to assess compliance with the conditions of grant, and inclusion strategies will be available to Ofsted inspectors when evaluating inclusion.

As compliance with the publication requirement forms part of the conditions attached to the IMF, failure to comply can also have financial consequences, including potential recovery of grant funding.

Multi-academy trusts

MATs may pool their schools' IMF allocations where appropriate financial governance arrangements are in place, which may make sense where a trust is developing shared approaches or commissioning support across a number of academies.

However, pooling funding does not remove the school-level reporting requirement.

Each academy must publish its own inclusion strategy statement. Trusts will therefore need to ensure that, even where there is a common trust-wide approach to inclusion, each academy's strategy reflects the particular needs and barriers identified within its own cohort.

What should schools do now?

With a 31 December 2026 publication deadline, schools should use the autumn term to develop their strategy.

A sensible starting point is to bring together those responsible for SEND, curriculum and teaching and learning, attendance, behaviour, pastoral support, finance and governance. Schools can then:

Identify the key needs and barriers evident within their cohort;
Consider the evidence about what is likely to address them;
Select a manageable number of priorities for the year;
Map the core, notional SEN and IMF funding supporting those priorities;
Establish clear and measurable intended outcomes; and
Arrange appropriate governor or trustee scrutiny before publication.

The DfE has published detailed guidance on developing an inclusion strategy using the Inclusive Mainstream Fund, together with an Inclusion Strategy Template for schools to use.

Developing a meaningful strategy now, rather than viewing it simply as another statement to publish, should therefore put schools in a stronger position as the Government's wider SEND reforms develop.

If you would like support with developing your inclusion strategy or understanding what the new requirements mean for your school, please get in touch with Rosie Browne or Natalie Wargent in our Regulatory, Risk and Resolution team.