Schools Topical Audit - Governance (People and Structure)

The Department for Education's Maintained Schools Governance Guide (2025) sets out clear expectations for the operation, composition, and conduct of governing boards in maintained schools. Local Authorities are expected to ensure that governing bodies have access to clear and comprehensive governance guidance, including statutory requirements relating to board constitution, roles and responsibilities, training and induction, meeting structures, diversity, and transparency.

In Autumn Term 2025, Norfolk Audit Services carried out an audit of governance arrangements within maintained schools. A sample of 20 schools were assessed via questionnaire, with five schools selected for detailed review, including evidence testing, desktop checks, constitution compliance, and discussions with Headteachers and of Governors.

The following risk was covered as part of this audit:

• Governing bodies may not be operating in full compliance with statutory governance requirements, reducing the effectiveness, transparency and accountability of school governance.

Summary of findings

• Skills audits are inconsistently completed, with fewer than half of schools conducting one in the past 12 months, and limited evidence of follow‑up action. (See Finding 1)
• Governor Codes of Conduct documents are not being consistently reviewed on an annual basis. (See Finding 2)
• Succession planning is not formally documented, schools are following informal and undocumented processes for governor succession planning. (See Finding 3)
• Induction processes and governance training records vary considerably, and several schools do not have a documented induction framework or complete training logs. (See Finding 4)
• Only half of schools have a governor expenses policy. (See Finding 5)
• Website governance pages are often incomplete or out of date, with missing committee information, incorrect term dates or incomplete attendance records. GIAS records are not always being maintained and do not always match the schools constitution. (See Finding 6)
• Chair's actions are generally used sparingly, but documentation, agenda inclusion and reporting processes vary, limiting transparency. (See Finding 7)
• Diversity data is not routinely collected or discussed. (See Finding 8)

Detailed findings

1. Skills Audits and Board Capability

The constitution of governing bodies of maintained school's states,

"Governing bodies should use a skills audit to identify any specific gaps that need to be filled in the skills, knowledge and experience of existing governors"

"A skills audit, such as that produced by the National Governance Association, should be used to identify the skills, knowledge and experience of current governors and any additional specific skills or experience that the governing body ideally requires."

Fewer than half of schools (9 of 20) completed a skills audit in the last 12 months. Two of these schools had not taken action to address identified gaps, and one did not provide evidence. Deep‑dives showed considerable variation: several schools had robust audits and action plans, while others had no recent audit or had not analysed results. Weak skills audit practice limits the board's ability to address capability gaps, plan succession, and ensure effective challenge in areas such as safeguarding, finance and curriculum.

Recommendation

Governing bodies must ensure they:

• Conduct skills audits annually.
• Take appropriate action for any skill gaps identified.

2. Code of Conduct and Review of Core Governance Documents

The Maintained schools: governance guide section 2.1.1 Governor conduct and behaviour states,

"Effective governing bodies create and maintain a code of conduct which is agreed by all governors."

The majority of schools (16 out of 20) review their Code of Conduct annually. However, two schools reviewed it less frequently and two were unsure whether a Code was in place.

Recommendation

Governing bodies must:

• Ensure a current and approved Governor Code of Conduct is in place and accessible to senior members of staff and governors. It is best practice to review the Governor Code of Conduct annually and for governors to acknowledge agreement to the code.

3. Succession Planning

The Maintained schools: governance guide section 1.2 Features of effective governance states,

"use active succession planning to ensure the governing body and the school has the leadership and people it needs to remain effective"

Section 4.5.2 Electing a chair and vice chair from the existing governing body states

"Governing bodies need to have effective succession planning arrangements in place for the position of chair and vice-chair."

Twelve of the 20 schools reported having succession planning arrangements in place, though these varied considerably in maturity with 3 schools confirming that they had no formal process in place.

This was supported by our deep-dive review which found that mentoring for future Chairs was limited, with no formal/documented process in place.

Recommendation

Governing bodies must ensure they:

• Implement a formal succession planning process in line with DFE guidance.

4. Induction and Training

The Maintained schools: governance guide section 4.1.2 Induction, training and development states,

"A governing body is responsible for:

• allocating a governance training and development budget
• providing an induction for new governors, associate members and the governance professional
• identifying specific training such as safeguarding, Prevent, and how to keep pupils safe online, ensuring that all governors and the governance professional have read and follow part 2 of keeping children safe in education guidance"

Induction arrangements differ widely between schools. Six schools had no documented induction process and relied on informal mentoring. Training records were incomplete for several schools, and three deep‑dive schools could not provide governance training evidence despite reporting that training had taken place. Safeguarding and Prevent training were widely delivered, but e‑safety training was not consistently provided. Only eight schools reported having a dedicated governor training budget. Weak induction or incomplete training oversight limits governors' understanding of statutory duties and weakens governance effectiveness.

Recommendation

Governing bodies should:

• Implement and maintain a comprehensive induction process covering statutory duties, training requirements and key documentation.
• Record induction completion for all new governors.
• Maintain a centralised training log (e.g. via GovernorHub) for all governors.
• Ensure e‑safety training is delivered consistently alongside safeguarding and Prevent training.
• Allocate a governance training and development budget as necessary, we acknowledge that this may be covered via the Governor Hub subscription for most schools.

5. Governor Expenses Policy

The Maintained schools: governance guide section 4.11 Allowances, expenses and other payments states,

"There are other limited, specific circumstances in which individuals serving on governing bodies can receive payments from their school. This should only take place where it is clearly in the best interests of the school."

Only 10 of 20 schools had an expenses policy in place. Several schools believed a policy was unnecessary because governors rarely claim expenses. Our Deep-dive testing identified one school with an up‑to‑date expenses policy that had been ratified through governor minutes. Other schools either had no policy at all or had begun drafting one after the questionnaire prompted them to do so.

The lack of a consistent expenses procedures increases the risk that potential governors may be excluded on financial grounds and may undermine equality of opportunity within governing body recruitment. There is a risk that governor expenses are paid inconsistently and not in line with expenses policy. 

Recommendation

Governing bodies should:

• Adopt a governor expenses policy, regardless of how frequently expenses are claimed.
• Review and approve the policy through the governing board.

6. Publication and recording of Governance Information

The Maintained schools: governance guide section 5.7.3 Get Information About Schools (GIAS) states,

"To ensure transparency on who governs our schools, the Department for Education (DfE) established a national database of governors. This can be accessed through Get Information About Schools (GIAS).

GIAS allows DfE to identify individuals who have a role in governance, and it also helps governing bodies, as well as DfE, to identify where people govern in more than one school or academy trust.

Schools must provide up-to-date information about their chair and governors on GIAS to the Secretary of State for Education as required by section 538 of the Education Act 1996. Portions of this information will be used to populate the GIAS database."

The Maintained schools: governance guide section 5.7.2 The school's website states

"The school should publish information about their governing body and its committees, in line with the constitution of governing bodies of maintained schools.  

The governing body or school should publish up-to-date details of its governance arrangements on its website in an accessible format. For example, the information should be on a webpage without the need to download or open a separate document."

We identified Several schools did not meet the DfE's statutory requirements for publishing governance information. Issues ranged from missing governor attendance data to outdated or incorrect committee structures, incomplete term dates and incorrect governor category information. In one instance, attendance tables were published without any attendance data.

Our deep-dive testing identified multiple cases where there were inconsistencies between the constitution, internal records, questionnaire responses, GIAS entries and school website information.

Recommendation

Governing bodies must:

• Update GIAS immediately following any governor appointment, resignation or term renewal.
• Ensure website data aligns with GIAS and their Constitution.
• Publish information about their governing body and its committees, in line with the constitution of governing bodies of maintained schools.  The 'governors' information and duties' section of what maintained schools must publish online.

7. Chair's Action Governance

The Maintained schools: governance guide section 4.5.1 Chair's action states

"The chair must not act alone in carrying out the functions of the governing body. However, the chair (or if they are unable to act, the vice-chair) can act on behalf of the governing body where they are of the opinion that a delay would likely be seriously detrimental to the interests of the school"

"Decisions taken under chair's action should be reported in writing to the governing body as soon as possible and recorded in governing body minutes."

Chair's action was used appropriately where evidence was available, but documentation and reporting varied significantly. Many schools did not include chair's action as a standing agenda item, and minutes often did not confirm whether chair's action had been taken. This lack of transparency limits assurance that chair's action is only used when genuinely necessary.

Recommendation

Governing bodies should:

• Include "Chair's Action" as a standing item on every FGB agenda.
• Record explicitly whether any chair's action has been taken.
• Ensure that any actions taken are reported and ratified at the next meeting.

8. Diversity Monitoring and Representation

The Maintained schools: governance guide section 4.1.1 Create a diverse governing body states,

"The governing body needs to reflect the diversity of the community the school serves, in line with the Equality Act 2010"

"Governing bodies are encouraged to collect and publish diversity information about themselves, which should be widely accessible to members of the school community and the public. Governors can opt out of sharing their information, including protected characteristics, at any given time, including after publication of diversity data."

Most schools (15 of 20) had not collected diversity data for governors and were unaware of DfE expectations to review diversity annually. Where data was collected, it was rarely published or used to inform recruitment. Failure to monitor diversity reduces transparency and limits the board's ability to evaluate whether its membership reflects the community it serves or whether additional perspectives are needed.

Recommendation

Governing bodies should:

• Collect diversity information annually using an anonymised process.
• Discuss diversity data as part of annual board self‑evaluation.
• Publish collected diversity information, which should be accessible to the school community and public.
• Incorporate diversity considerations into recruitment and succession planning.