Tightening up scrutiny isn't just for the big players

Amelia Clark, Head of Internal Scrutiny at School Business Services, on why exacting new internal scrutiny requirements coming in later this year shouldn’t just apply to the largest trusts.

Amelia Clark, Head of Internal Scrutiny, SBS

The internal scrutiny process is set to tighten up for a lot of trusts later this year following the publication of new statutory requirements in the Academy Trust Handbook.

The updated handbook contains new requirements which will affect trusts with an annual revenue of more than £50 million.

From 1 September 2025 these trusts must use either a professional in-house internal auditor or a bought-in professional internal audit service for their internal scrutiny processes.

That emphasis on professionalism is a welcome development which will continue to drive up the quality and rigour of internal scrutiny across the sector, and not just in larger trusts. 

Trusts should already be working towards the 1 September deadline but it is worth stepping back and reviewing your scrutiny processes to see what needs to change ready for September. And if your trust doesn’t have to conform with those requirements, they are still worth considering.

As previously emphasised in the handbook, those performing internal scrutiny or auditing should always have relevant professional qualifications or experience.

For example, auditors carrying out internal scrutiny work should be a member of a relevant professional body including the Institute of Internal Auditors (IIA), and the Institute of Chartered Accountants in England and Wales (ICAEW).

As a member of the Institute of Internal Auditors I feel that increased emphasis on professionalism and appropriate qualifications and skill of those undertaking scrutiny of academy trusts should lead to more effective scrutiny with a broadened financial and non-financial scope.

This will, in turn, lead to more rigorous oversight, more consistent quality of internal scrutiny of larger trusts, and foster an environment of greater accountability, transparency and risk management. 

This fresh emphasis on a professional approach to auditing processes with a focus on risk management isn’t limited to the larger trusts. As each version of the Academy Trust Handbook has evolved, so has internal scrutiny, with the focus now very much on robust internal scrutiny.

All academy trusts are required to have some form of internal scrutiny during the year – that’s roughly three reviews a year. Originally this could be done by someone designated as the responsible officer. Qualifications didn’t matter as much as they were expected to carry out routine, repetitive checking tasks.

That has shifted the internal scrutiny responsibility away from internal appointees towards the use of external expertise.

That external view can be hugely helpful, providing an objective, informed view that trusts of any size are less likely to be able to accommodate. That objective view can assess what the trust’s strategic aims are and provide a thorough audit of the risks that might stop them from achieving those aims, based on the trust’s risk register.

The risks faced by trusts large and small are complex and seem to grow each year. SEND funding is obviously a key pressure point, together with recruitment and retention, forecasting and budget management, and pupil attendance.

Internal scrutiny, when conducted effectively, provides essential assurance to the boards of trusts large and small that systems and controls are robust and operating as intended.

It's a tool that can identify potential issues before they escalate, protect the trust's reputation, and ultimately, improve outcomes for students.

Whether your trust is of a scale that it must comply with those new internal scrutiny requirements from September or not, following the route of professional external scrutiny will only strengthen your trust.

  • Amelia is Head of Internal Scrutiny at School Business Services, which provides finance consultancy and financial planning and forecasting software for more than 2,200 UK schools and academies.

The CST Blog welcomes perspectives from a diverse range of guest contributors. The opinions expressed in blogs are the views of the author(s), and should not be read as CST guidance or CST’s position.

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