The ISI complaints policy in review: How can association independent schools best approach making a complaint?

ISI's annual report 2024 - 2025 provides that of the 622 inspections completed across all remits in the 2024 - 2025 academic year, ISI received 80 formal complaints, 68% of which were not upheld, 24% were partially upheld and 8% were wholly upheld. Of those complaints, 44 related to inspector conduct, 52 to inspection process and 78 to evaluations reached - the three grounds available to schools and where any individual ground or combination may be submitted. For wider context, in 2023 - 2024, the ISI received 36 formal complaints, in 2022 - 2023, 20 formal complaints, and in 2021 - 2022, 11 formal complaints. 

So, how best can independent schools prepare to make their complaint as effective as possible?

The ISI Inspection complaints policy, first issued in September 2024, is clear that ISI expects school leaders to speak to the reporting inspector about any issues or concerns about the inspection as soon as possible whilst the inspection is ongoing, and where schools have serious concerns they feel unable to raise directly with the reporting inspector, to call the ISI's head office to request a call back from a senior member of ISI staff. 

However, where an independent school is informed at the final review meeting by the reporting inspector that Standards have not been met, school leaders need to quickly prepare for a stage one (informal) complaint. 

Preparing for stage one (informal complaint) - a phone call with ISI

After taking the decision to submit a stage one complaint via the online form ISI provides within four term-time working days of the end of the onsite inspection and citing any one or more of the three available grounds for complaint, it is vital to prepare the detail of the grounds of complaint as thoroughly as possible for the phone call with the quality assurance team at ISI. 

Whilst we recommend that the grounds for complaint be made clearly and concisely as to the issue(s) at hand with evidence, there is no prescribed time limit for the telephone call. Having a prepared and rehearsed script to hand for the Head and/or Chair of Governors to speak through can help maintain focus as to the complaint and the proposed resolution. In addition, being prepared to clarify or explain certain matters further is also advisable. 

At this stage, the school will not have received the draft inspection report to know any purported unmet Standards in detail and it is therefore vital at the final review meeting of the onsite inspection that the school is clear as to what the issue(s) is/are. 

Whilst ISI choosing to invoke its Protocol for gathering additional evidence is rare, where a school feels that additional evidence should be gathered in order to securely report inspection evaluations, it may choose to raise this at this stage one.

Escalation to stage two (formal complaint) - written submissions

It is important to note that schools can submit a stage two complaint even if it has not previously requested informal resolution at stage one. However, as stage two is the submission of a complaint in writing, we recommend that independent schools at least conduct an assessment of the benefits of raising a stage one complaint first. 

Submissions at stage two may be made only on the ISI's online form where no supporting documentation may be submitted and where there is a character limit for each element of the submission. Submissions must therefore be concise and should provide clarity as to the reason(s) for the complaint and the resolution sought. 

Failure to have made the grounds for complaint at stage one verbally may mean that stage two complaints in writing are less clear and less likely to achieve the resolution an independent school is seeking. 

Are there merits in raising a stage three (referral to an independent adjudicator) complaint?

An independent adjudicator will consider whether ISI followed its complaints policy properly in handling the complaint and/or whether ISI reached a reasonable decision in response to the complaint. A referral to an independent adjudicator is made via another online form with no further submissions or cost other than to confirm that the school wishes to proceed to stage three. 

Independent schools may therefore take the view that where a stage two response does not uphold the complaint or only upholds the complaint in part, that referral to an independent adjudicator has merit. 

Final thoughts

The trend for independent schools raising complaints with ISI post-inspection is notable. When making a complaint, independent schools are advised to make their case as early as possible in the complaints process, from the onsite dialogue with the reporting inspector to a carefully planned stage one telephone call. 

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For support or advice in navigating the ISI complaints process, please contact Michael Gledhill or Kris Robbetts in our Regulatory Compliance team.