What Does Level 1 of the Estate Management Standards Actually Require, and Is Your Organisation There?

Level 1 of the Estate Management Standards is described as baseline. In practice, it is the most consequential level in the framework, because it is where every Responsible Body (the trust, governing body, or proprietor legally accountable for the estate) needs to start, and where a significant proportion of the sector will discover it is not. The organisations that make the most confident annual return submissions from autumn 2026 will be those that assessed their Level 1 position honestly, addressed what was missing, and built forward from there. Those that assumed baseline compliance because nothing had gone wrong will find the exercise more uncomfortable than they expected.

This article sets out what Level 1 actually requires across its key areas, and what a Responsible Body needs to be able to demonstrate, not just describe, at that level.

What Level 1 Covers

The Estate Management Standards describe four maturity levels. Level 1 (Baseline) is the starting point. It does not represent minimal acceptable practice in an aspirational sense. It represents the floor of what the framework expects of a Responsible Body that is engaged with its obligations.

Level 1 requirements fall across five broad areas: governance, compliance, planning and strategy, people and competency, and condition and sustainability. A Responsible Body at Level 1 has the structural foundations in place for each. It has not yet built the active management disciplines that Level 2 requires, but it has established the architecture on which those disciplines depend.

Governance Requirements at Level 1

The governing body or board of trustees must be actively engaged with the estate as part of its formal governance responsibilities. This is not assumed from the existence of a board. It is demonstrated through evidence: minutes that record estate matters discussed, a named lead governor or trustee who takes responsibility for estate scrutiny, and a skills assessment that has addressed whether the board has the estate management expertise it needs to discharge its oversight function.

The annual governors' or trustees' skills assessment must include specific consideration of estate management expertise. This is a Level 1 requirement. A skills assessment that covers safeguarding, finance, and HR without including estates has not met the standard.

A named individual must be designated as responsible for estate management. The designation must be explicit and documented. An informal arrangement in which the facilities manager handles everything because everyone knows that is their job is not the same as a formally designated named individual with documented accountability.

Compliance Requirements at Level 1

The Responsible Body is required to have a documented programme of statutory compliance in place. Statutory compliance covers the activities mandated by legislation and regulation: fire safety, water hygiene, electrical testing, gas safety, asbestos management, and the other areas that carry a legal duty. At Level 1, the programme must exist, be documented, and be the basis on which compliance activities are conducted.

The programme being documented is not the same as activities being completed. A compliance schedule that lists tasks but cannot demonstrate that those tasks have been conducted, by whom, and to what standard, is not a compliance programme in the sense the Standards intend. The evidence record is part of the programme, not an optional addition to it.

The Responsible Body must also have arrangements in place for statutory inspections and testing. This includes not only the inspection and testing activity itself but the management of any actions arising from it. A fire risk assessment that identifies remedial actions with no evidence those actions were addressed is a compliance liability, not a compliance record.

Planning and Strategy Requirements at Level 1

The Responsible Body is required to have an estate strategy and an asset management plan in place. Both must be signed off by the board. The estate strategy covers the next 3 to 5 years. The asset management plan sets out how the Responsible Body will manage, maintain, and invest in its estate assets.

The significance of the board sign-off requirement is that these are not documents produced by the estates team for internal reference. They are strategic documents that commit the organisation to a direction, and the board is accountable for that commitment. An estate strategy that has been drafted but never presented to or approved by the board does not meet the Level 1 requirement.

A condition survey or equivalent assessment of the estate's physical condition is also required at Level 1, providing the evidence base on which the asset management plan draws.

People and Competency Requirements at Level 1

The named individual responsible for estate management must have, or be working towards, an appropriate level of competency for the role. The Estate Management Competency Framework describes what competency at each level looks like. At Level 1, the expectation is that the organisation has assessed what the role requires and has a named person in it who is operating at an appropriate level, or has a plan to develop them to that point.

Policies covering the key areas of estate management must be in place and current. This includes health and safety policies, maintenance policies, and the specific statutory area policies (fire, water, asbestos) that the organisation's compliance obligations require.

FAQ

How does a Responsible Body know whether it is at Level 1?

The Standards provide a self-assessment framework, and GEMS provides a complementary self-assessment checklist. Working through these systematically against the requirements listed above gives a Responsible Body a structured basis for assessing its position. The honest challenge is that self-assessment tends to be optimistic: organisations assess what they believe they have rather than what they can demonstrate. An external review of the Level 1 position, against the Standards requirements, gives a more reliable picture.

What counts as evidence at Level 1?

Evidence at Level 1 is documentary and traceable. The named individual designation is a letter of appointment, a job description, or a board minute. The skills assessment is the formal record of the assessment conducted. The estate strategy and asset management plan are signed documents with a board approval record. The compliance programme is a documented schedule with completion records attached. Evidence is not an assertion that something is in place. It is a document that demonstrates it.

Is Level 1 sufficient for the annual return?

The annual return asks the Responsible Body to confirm its maturity level. Confirming Level 1 is a legitimate response if that is an honest assessment of the organisation's position. The Standards are explicit that the expectation is that all Responsible Bodies progress to Level 3 over time. Confirming Level 1 accurately, with an understanding of what is needed to progress, is better than overstating a position the organisation cannot substantiate.

What are the most common Level 1 gaps?

Across the organisations I have worked with, the gaps that surface most consistently at Level 1 are: a skills assessment that does not cover estate management expertise; a named individual who is informally understood but not formally designated; a compliance programme that lists activities but lacks the evidence records that demonstrate those activities occurred; and an estate strategy that has been drafted but never formally approved by the board. None of these is a complex problem to fix. All of them are consequential if left unaddressed when the annual return is submitted.

What should a Responsible Body do first if it has not formally assessed its Level 1 position?

Start with governance. Confirm the named individual designation is documented, the skills assessment has covered estate management, and the board has approved the estate strategy and asset management plan. These are foundational requirements; everything else in the framework depends on them. From there, work through the compliance programme: is it documented, is it current, and does the evidence record demonstrate it is being followed? A structured assessment against the Level 1 requirements, conducted before the return window opens, is significantly better than discovering gaps during the submission process.

Richard Bunting is a founding partner of The Estates Strategy Partnership and co-leads the Operating Model Design domain. He is the founder of Compliance Pod, which has supported schools, multi-academy trusts, and further education providers across England in building the compliance infrastructure the statutory framework requires.