The UK government’s latest changes for independent schools, and why they’re a Governance, Risk, Compliance & Assurance issue (not just a finance one)

• by Olivia Lawlor-Blackburn
• Advent IM Blog

Independent schools in the UK have always had to juggle competing pressures: educational outcomes, safeguarding responsibilities, parental expectations, and the realities of running a complex organisation with a large physical estate and a large digital footprint.

What’s changed over the last 12–18 months is the direction of travel. Policy shifts are increasing cost, tightening accountability, and raising expectations around evidence. That combination turns “governance, risk and compliance” from a back-office function into the thing that stops your leadership team being surprised at the worst possible moment.

This isn’t about panic. It’s about understanding how apparently “non-security” policy changes create very security-shaped risks.

1) VAT on private school fees: revenue shock meets control shock

From 1 January 2025, many independent schools have had to charge VAT on education and boarding supplied for a fee. For some schools, that’s been a simple pricing headline. For many, it’s been a structural change in cashflow, forecasting, affordability, and parent relationships.

The GRC implication is that financial pressure changes behaviour. Under pressure, organisations introduce well-intentioned exceptions: a rushed workaround to keep admissions moving, a “temporary” concession in payment terms, a hurried change to invoicing systems, or a procurement decision based on speed rather than due diligence. Over time, those exceptions become the new normal, and the control environment quietly degrades.

What “good” looks like here is not just accurate VAT processing. It’s board-level visibility of the knock-on effects: enrolment risk, fee sensitivity, bursary demand, and the resilience of the school’s operating model if pupil numbers shift. If a school is forced to reduce discretionary spend, you want a documented rationale that protects critical controls (safeguarding, IT patching, identity and access, incident response capability) from being starved.

In plain terms: cost pressure can become cyber pressure if you don’t explicitly protect the controls that keep the lights on.

2) Business rates relief changes: estates pressure expands your risk surface

In England, charitable business rates relief for private schools changed from 1 April 2025. Regardless of your view on the policy, the operational effect is simple: estates costs get sharper teeth.

When estates costs rise, schools often respond by sweating assets harder. More lettings. More community use. More events. More contractors. More third parties on site. More payment flows. More access badges. More “can we just…” requests.

This is where GRC becomes the connective tissue. A busier estate increases physical security risks, safeguarding exposure (who is on site, when, and why), and information security risk (guest Wi-Fi, temporary access, unmanaged devices, shared spaces, CCTV data handling). Each additional third party is a supplier risk question. Each additional payment stream is a fraud risk question. Each additional visitor is a safeguarding and privacy risk question.

The schools that cope best don’t rely on heroic individuals remembering what to do. They make the secure way the easy way: clear onboarding for contractors, consistent ID and access processes, supplier assurance proportionate to risk, and documented “stop points” for anything that touches safeguarding or personal data.

3) Safeguarding and online safety: evidence beats intention

Safeguarding expectations keep tightening, and the operational reality is that you will be judged not only on what you intend, but on what you can evidence: training completion, safer recruitment, reporting routes, record quality, follow-up actions, and clarity of ownership.

Online safety controls sit right in the overlap of safeguarding, IT, privacy, and governance. Filtering and monitoring may be implemented by IT, but accountability sits with leadership. That means decision trails matter: why a solution was chosen, what it logs, who can access the logs, how long they’re retained, and how concerns are escalated.

There’s a subtle GRC trap here. “Monitoring” without governance becomes a liability: excessive access to sensitive logs, unclear retention, inconsistent response processes, and accidental overreach. Conversely, governance without operational capability becomes theatre: beautiful policies, no enforcement.

The mature posture is balanced: clear lawful basis, proportionate controls, role-based access, tested processes, and an audit trail you can stand behind when scrutiny arrives.

4) Inspections and scrutiny: treat inspection readiness like audit readiness

Inspection frameworks and operating guidance evolve, and for independent schools the practical message is that scrutiny is becoming more structured and evidence-driven. In that environment, inspection readiness is not a last-minute scramble; it’s an ongoing assurance rhythm.

The “GRC move” is to treat inspection preparation like an internal audit programme. You keep a living evidence pack. You test a small selection of controls each term. You track actions, owners, and dates. You run tabletop exercises for high-stakes scenarios (serious safeguarding incident, data breach, ransomware disruption, allegations management, sudden staffing gaps). You can show governance, not just state it.

This isn’t bureaucracy for its own sake. It is what prevents a school from being caught trying to reconstruct decisions and actions from memory.

5) In-flight legislation and future guidance: horizon scanning is a control

The Children’s Wellbeing and Schools Bill (in flight) and statutory guidance changes (including RSHE implementation from September 2026) are reminders that compliance is not a one-off project. It’s a moving landscape.

Schools with strong GRC don’t wait for the final wording before thinking. They run horizon scanning: what might change, what policies and processes would be affected, what resources would be needed, and what “no regret” improvements can be made now.

That’s particularly important for schools with complex operating models: multiple sites, international pupils, boarding, specialist provision, extensive third-party services, or significant extracurricular programming. Complexity is not a flaw. It just needs to be governed.

What should leaders do next?

The quickest way to make this practical is to translate policy changes into risk register entries with named owners. Then do a short control impact assessment across four areas:

First, financial governance: VAT/rates impacts, cashflow sensitivity, and protection of critical controls under budget pressure.

Second, safeguarding assurance: training, records, reporting routes, and the governance of online safety controls.

Third, third-party and estates: contractors, lettings, access management, and supplier assurance.

Fourth, operational resilience: backup readiness, incident response, communications plans, and tabletop testing.

The theme is simple. External changes are increasing cost and scrutiny at the same time. That’s exactly when weak governance creates expensive surprises. Good GRC doesn’t make schools slower; it makes them harder to knock off balance.