Inclusion strategy and estate strategy are usually written by different people, approved at different meetings and filed in different places. One is treated as an educational document and the other as a buildings document. For a board, that separation carries a risk: it can approve ambitious inclusion priorities without ever testing whether the physical environment can support them. This article sets out what the inclusion strategy is, what the DfE's guidance says about the estate's part in it, and what a board should ask before it approves one.

What is the inclusion strategy, and when is it due?

The inclusion strategy is a condition of the inclusive mainstream fund. Every state-funded mainstream school in England receiving an allocation must publish one on its website by 31 December 2026, covering the academic year 2026 to 2027. It is not yet a statutory duty. The department has proposed placing a legal duty on schools to produce one in future, and says Ofsted will assess how leaders embed the strategy in practice, but for this year the requirement rests on the conditions of grant.

The DfE's guidance, Developing an inclusion strategy using the inclusive mainstream fund (updated 7 August 2026), provides a template. A school that does not use the template must still cover four areas:

  • the barriers to learning and participation identified across the cohort
  • the activities invested in to alleviate those barriers
  • intended outcomes
  • a review of the previous academic year

Activity funded from the allocation must fall under one of the seven principles of inclusion. Where a multi-academy trust pools the funding, each school must still publish its own strategy.

Where does the board come in?

The department's governance guides are direct about this. For academy trusts, the board should scrutinise the inclusion strategy and discuss with the senior leadership team how the fund and core budget allocations will be used together, how impact will be evaluated and sustained, and the outcomes from the previous year. The Academy Trust Handbook 2026, effective from 1 October, asks trust boards for sufficient assurance over the quality and consistency of inclusive practice and for a designated trustee or committee to support oversight of inclusion, including SEND.

For maintained schools the governing body carries the same expectation under the DfE's maintained schools governance guide; the Handbook does not apply to it.

The strategy guidance adds that developing the document should be a shared responsibility across the whole leadership team, and it names who that includes: the headteacher and senior leaders, the school business manager, the SENCO, governors and trustees, middle leaders and pastoral staff. The school business manager is on that list. The person who holds the premises budget is meant to be in the room.

What does the DfE say about the estate's part?

The seventh principle of inclusion is inclusive environments with continuous improvements to accessibility. The department's companion guidance, Inclusive education estates: supporting inclusive environments in mainstream settings (June 2026), is written for local authorities, responsible bodies and settings and it makes three points that matter to a board.

First, inclusive adaptations should be embedded within the setting's long-term estate strategy, with SEND considerations informing ongoing maintenance, future development and investment. The findings of an accessibility assessment can feed directly into the accessibility plan the responsible body must hold under Schedule 10 of the Equality Act 2010, the SEN information report, premises plans and the wider estate strategy.

Second, the sequence is the same everywhere: identify the needs to be addressed, prioritise the adaptations that maximise impact, then deliver and review them. The guidance recommends recording, for each adaptation, its purpose and expected outcome, who delivered it and when, its cost including time, and its impact on progress and access to learning.

Third, creating an inclusive environment does not always require high-cost adaptations. Well-chosen, affordable changes can remove barriers quickly. The funding routes the guidance names for adaptations are high needs provision capital allocations through the local authority, the inclusive mainstream fund, and trust or school reserves; the strategy guidance is equally clear that the fund should not be treated as the only source of funding for inclusive activity.

Where do the two documents meet?

At three points. The barriers identified in the inclusion strategy should be the same barriers the accessibility plan and the estate's condition and suitability data describe. The adaptations the inclusion strategy funds should appear in the asset management plan, the maintenance programme or the capital priorities, so that a change to one document moves the others. And the evidence that access has improved should be the same evidence in both places.

The test I put to boards is a simple one. If an inclusion priority changed tomorrow, could the board see whether the estate strategy, the accessibility plan and the risk register changed with it?

Who holds which document?

Accountability routes differ by sector and a board should know its own. In an academy trust the trust board is the responsible body for the estate and retains overall accountability whatever it delegates operationally. In a maintained school the governing body is the strategic accountable body, but responsibility for particular estate and Equality Act matters is divided between the governing body and the local authority according to the school's category: the local authority holds the accessibility strategy for the schools it is responsible for, and each responsible body holds an accessibility plan. Foundation and voluntary aided schools sit differently again. The distinction should be recorded, in the scheme of delegation or its maintained equivalent, so that "who holds the estate end of the inclusion strategy" has an answer that can be found.

What should a board ask before it approves an inclusion strategy?

These are the questions I would expect a board to be able to answer, not questions to be put to leaders for effect.

  • Which elements of this strategy depend on the physical environment?
  • What barriers have been identified, and whose experience informed that assessment: pupils, families, staff, the site team?
  • What adaptations are required now, and what longer term, and where are they recorded?
  • How are SEND needs reflected in the maintenance programme and in capital planning?
  • Who holds the estate end of this strategy, and does the estate strategy reflect it?
  • What evidence will show that the changes have improved access to learning?
  • Where is the record the DfE recommends: purpose, delivery, cost and impact for each adaptation?

Common questions

Does the inclusion strategy have to mention buildings? The guidance requires activity under the seven principles and the seventh is inclusive environments. Whether a particular school's strategy includes estate activity depends on the barriers it identifies. What a board should know is whether the estate was considered when the barriers were identified, not whether it appears in the final document.

Can the fund pay for adaptations to the building? The estates guidance lists the fund among the routes a setting may consider for adaptations. The conditions of grant govern what any allocation may be spent on, activity must sit under one of the seven principles, and the strategy guidance says the fund is a supplement to core budgets, not the only source. A board should ask to see that reasoning for any estate spend.

We are a trust that pools the fund. Does each school still need a strategy? Yes. The guidance is explicit that each school must still publish its own inclusion strategy.

Is this a legal duty? Not yet. Publication by 31 December 2026 is a condition of grant. The department has proposed a legal duty for the future.

The governance shift

Boards often ask whether the school has an inclusion strategy. The stronger question is whether the estate supports it, and how the board knows. A board should be able to explain not only that it holds an inclusion strategy and an estate strategy, but how the two work together to remove barriers and let every child participate. If it cannot, the issue is not the buildings. It is governance.