Your energy supplier may be fine. Your buying route may not be.

An academy trust could be perfectly satisfied with its energy supplier and still have a problem after September. Under the updated governance guide, the first question is no longer whether the deal looks competitive. It is whether the trust bought its energy through a permitted route.

From September 2026, section 6.3.2 of the Academy Trust Governance Guide says trusts must use either:

• the DfE Energy for Schools service; or
• a DfE-approved energy deal listed through Get Help Buying for Schools.

That is the estates-related change from the 15 July update that deserves immediate attention.

Why “must” changes the conversation

The guide is unusually helpful about its choice of words. “Must” means a legal or regulatory requirement or duty that has to be followed. “Should” means minimum good practice, unless the trust can demonstrate that a different approach better suits its circumstances.

The energy-buying route is a must.

This is not an invitation to compare the DfE route with the trust’s usual arrangements and choose whichever it prefers. From September, the trust must be using one of the two routes identified by the DfE.

That matters because energy procurement rarely belongs neatly to one department. Finance may hold the budget, procurement may run the exercise and estates may hold the information about sites, meters and consumption. Whatever the division of labour, someone needs to be able to confirm that the resulting arrangement is permitted.

Asking “Who supplies our energy?” is no longer enough. The better question is: “Which approved route did we use to buy it?”

A familiar supplier, broker or longstanding arrangement does not answer that question by itself. “We’ve always bought it this way” may explain the history. It does not confirm the position from September.

Sustainability is new to the guide, not new to trusts

The 15 July update also added a section on sustainability leadership and climate action plans. It is relevant to estates teams, but it needs describing carefully.

The underlying expectation is not new. The DfE’s separate sustainability leadership and climate action plan guidance was first published in May 2023 and set an expectation that education settings would have a nominated sustainability lead and climate action plan by 2025.

What changed on 15 July was its position within the governance guide.

New section 7.14 says boards should make sure trusts and schools are taking credible, measurable climate action that reduces carbon emissions, improves the resilience of the trust estate and embeds sustainability into operational and educational practice. It also says every trust and school should have a sustainability lead and climate action plan.

This is relevant to estates because estate resilience is named explicitly. However, it is not a second new September duty and should not be presented as one.

The more useful point is that an existing sustainability expectation now sits directly in the board’s governance guide. That may change the questions estates teams receive. A named lead and a document establish that something exists; they do not, by themselves, demonstrate credible or measurable action.

If a climate action plan covers the estate, the board should be able to see how it connects with emissions, resilience and operational practice. Otherwise, the trust may have the right document but struggle with the questions the new section encourages boards to ask.

Two questions for estates teams

The estates implications of the July update can be reduced to two checks:

1. Can the trust confirm that its energy-buying route is one of the two permitted by the DfE from September 2026?
2. If the board asks about section 7.14, can the trust easily identify its sustainability lead and show how its climate action plan addresses estate resilience?

The first is a new mandatory procurement rule. The second is an existing expectation that has been given greater visibility at board level.

Keeping that distinction clear avoids both mistakes: overlooking the energy requirement because it is buried in a governance guide, and presenting sustainability as a brand-new duty when it is not.

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