The organisations I have worked with across the sector tend to have the same experience when the Estate Management Standards land on their desks. They look at the task requirements and feel reasonably confident. Then they look at who is actually accountable for each one, how the governing body receives information about it, and what happens when the named individual leaves. That is where the confidence goes. A Responsible Body's operating model must be designed to make compliance reliable: clear accountability, defined roles, documented processes, and information flows that reach the right people at the right time. The tasks themselves are the easy part. The question is whether the organisation is designed to carry them reliably, year after year, without depending on a single individual.
An operating model, in plain English, is how the organisation is designed to carry out its estate management responsibilities. It is the roles, processes, accountability structures, and information flows that make compliance something the organisation does by design, not by effort. A good operating model means that when any individual moves on, the responsibilities do not move with them.
What Does "Responsible Body" Mean?
The Responsible Body (the trust, governing body, or proprietor accountable for the estate under the Education Estates Strategy) is the organisation that must confirm it is meeting the Estate Management Standards via the DfE's annual return, due from autumn 2026. There are approximately 2,800 Responsible Bodies across England. The annual return does not ask the estates team whether compliance tasks have been completed. It asks the Responsible Body whether its organisation is meeting the Standards. That is a governance question as much as an operational one. If the operating model is not designed to produce reliable, evidenced compliance, the confirmation cannot be made with confidence.
What the Operating Model Needs to Look Like at Level 1
Level 1 is the baseline. The operating model requirement at this level is straightforward: someone is responsible, the board knows about it, and the basic documents exist.
In practice, that means the organisation has a named individual responsible for estate management. It has a governing board or board of trustees with oversight of the estate. Policies and governance arrangements are in place. The estate strategy and asset management plan have been reviewed, approved, and signed off by the governing body. A health and safety policy exists with clearly defined responsibilities.
What I see consistently in organisations at this stage is that most of these things exist in some form. The gap is not the documents. The gap is that no one can point clearly to who is accountable for each area, and the governing body does not have a structured way of receiving information about the estate. The documents have been produced. The operating model has not been designed.
What Changes at Level 2
Level 2 is described in the Standards as transitioning. The shift from Level 1 to Level 2 is not primarily about adding more tasks. It is about the governance layer becoming active rather than passive.
At Level 2, the board moves from having oversight in principle to understanding its role and having the skills to fulfil it. The annual governors' or trustees' skills assessment must include estates management expertise. This is not a formality. It means the board is expected to know what it is responsible for and to have enough collective expertise to scrutinise what it is told. The operating model requirement at Level 2 is that the governance layer is active and informed, not passive.
For a MAT, this means the central team understands which estate responsibilities sit at trust level and which sit at school level, and there are clear lines of reporting between them. For a single school, it means the governing body has the skills to ask the right questions and is doing so at regular intervals.
What the Operating Model Needs to Look Like at Level 3
Level 3 is the fully effective standard. The DfE's Education Estates Strategy describes Level 3 as what every Responsible Body should be working towards. The operating model requirement at this level is that the organisation is running the estate proactively, not reactively.
The clearest indicator of a Level 3 operating model is scheduled strategic review. At Level 3, the organisation does not review its estate strategy when a problem forces it to. Regular strategic reviews are built into the calendar. The governing body signs off the estate strategy and the asset management plan on a defined cycle, not when someone remembers it needs doing.
What this requires in the operating model is a reporting structure that puts the right information in front of the right people at the right time. The estates lead does not just manage tasks. They produce structured information that the board can use to make decisions. The board does not just receive reports. It receives assurance.
What Level 4 Adds
Level 4 is described as advanced. For most Responsible Bodies, it is an aspiration rather than an immediate target. The operating model requirement at Level 4 is that the board has structural accountability for the estate, not just oversight.
The Standards require a dedicated board member for the estate at Level 4. This is not the same as a board member who happens to know something about buildings. It is a specific governance role: someone whose responsibility it is to lead on estate matters at board level. Alongside this, the full cost of occupying the estate must be understood and used to challenge and demonstrate value for money. The board is not receiving information about the estate. It is using that information to hold the organisation to account.
The Estate Management Competency Framework is relevant here. At its strategic level, the framework describes what it means to lead on establishing and overseeing governance rules and procedures, assigning roles and levels of authority, and setting out training plans. The operating model at Level 4 requires someone in the organisation capable of working at that level, not just managing the task schedule.
Frequently Asked Questions
What is the difference between an operating model and a compliance system?
A compliance system records tasks. The operating model is the design of the organisation that determines whether the right tasks are done, by the right people, with the right accountability, and the right information reaching the right decision-makers. One is a tool. The other is how the organisation works. A compliance system that sits inside a poorly designed operating model produces records. It does not produce reliable compliance.
What should a Responsible Body prioritise first?
Establish the named responsible individual, get the governing board into active oversight rather than passive awareness, and document the accountability structure. Those three things are the operating model foundations. They make everything else more reliable because they create clear lines of responsibility before the specific compliance tasks are mapped onto them. Without those foundations, completing the task list does not produce the assurance the annual return requires.
Does the operating model look different for a MAT versus a single school?
Yes. A MAT has a central team and individual headteachers across multiple sites. The operating model must define where accountability sits at each level: what the central team owns, what the head owns, and how information flows between them. A single school has a simpler structure but the same design question: who is accountable, for what, and how does the governing body receive assurance rather than just reports. The question is the same. The architecture that answers it is more complex for a MAT.
How does the annual return test the operating model?
The annual return asks the Responsible Body to confirm it is meeting the Estate Management Standards. That confirmation is only credible if the organisation has the accountability structure and information flows to know whether it is meeting them. The return does not test tasks completed. It tests whether the organisation is designed to manage its estate reliably. An organisation that has done the tasks but cannot produce structured evidence, or cannot trace accountability clearly from the task to the governing body, will find that confirmation much harder to make with confidence.
Richard Bunting is the founder of Compliance Pod and a founding partner of The Estates Strategy Partnership. He leads on Operating Model Design across the partnership.