Organisations preparing for assurance tend to arrive at the annual return with the same conviction: they have done the work, therefore they have the evidence. The two are not the same thing. What I encounter, consistently, is teams that can tell you what they completed and when, but cannot produce the documentary record that allows a responsible body to stand behind that claim with confidence. A completion log is not evidence. A signed-off action in a spreadsheet is not evidence. Evidence is the artefact that would satisfy an independent reviewer that the right work was done, by a competent person, at the right frequency, and that the responsible body knew about it.
This distinction matters more now than it has at any point in the last decade. The DfE's annual return (submitted through the DfE's annual return portal (MYEE)) asks responsible bodies to self-assess against the Estate Management Standards at one of four maturity levels. The question the annual return is actually posing is not whether you have a statutory compliance programme. It is whether you can demonstrate, in a form that would withstand scrutiny, that you are operating at the maturity level you are claiming. Those are different questions, and the second is considerably harder.
Understanding what good evidence looks like at each level is the starting point. What follows is an assessment of the standard required at each level, grounded in direct assurance preparation work across the full maturity range.
Level 1 (Baseline): demonstrating that the foundations are genuinely in place
At Baseline, the Standards describe the essentials: a statutory compliance register, a health and safety policy, a risk register, fire risk assessment, inspection records for plant and equipment, an asset register, and an estate strategy and asset management plan. The evidence standard at this level is often underestimated. Responsible bodies completing a self-assessment at Level 1 for the first time assume that having these documents in existence is sufficient. In my experience, it is not.
What the annual return requires at Level 1 is that these documents are current, complete, and board-approved. The fire risk assessment must have been carried out by a competent person and reviewed within the required period. The risk register must have been reviewed and approved by the Responsible Body, not just created. The statutory inspection certificates must be held, not merely known about. The asset management plan must link to the estate strategy and reflect realistic budget assumptions. In organisations working at this level, the most common gap is not absence of documents but documents that are present and out of date, or present and never seen by the governing body.
Good evidence at Level 1 demonstrates that the responsible body has been actively engaged with each required document: that documents are current, that they have been formally considered and approved at the appropriate governance level, and that inspection and review records match the frequency the Standards require. The responsible body must be able to produce all of it.
Level 2 (Transitioning): demonstrating active management, not just documented intent
At Transitioning, the Standards build on Level 1 with requirements around board capability, contractor due diligence, planned preventative maintenance, asbestos awareness training, and a detailed continuity plan. The shift in evidence standard between Level 1 and Level 2 is significant, and organisations are regularly caught out by this shift.
Level 1 evidence is largely documentary: does the document exist and is it current? Level 2 evidence requires demonstrating active practice. A claim to Transitioning standard on board capability cannot rest on a policy that says the board has the necessary skills. It requires evidence that the annual governors' or trustees' skills assessment has been completed, that it includes estates management skills specifically, and that the board has used that assessment to identify and address gaps. The document is not the evidence. The practice it records is.
Similarly, a claim to Transitioning standard on planned preventative management requires evidence of a maintenance plan that predates the inspections it covers, together with records showing the plan was followed. Trusts that have reactive maintenance records but no planned inspection schedule cannot claim Level 2 on that dimension, regardless of how good their reactive response has been. The evidence standard requires the plan and the practice.
Good evidence at Level 2 demonstrates a cycle: planning, implementation, review. The responsible body must be able to show all three stages, not just the middle one.
Level 3 (Fully Effective): demonstrating integrated, self-reviewing management
The Fully Effective standard adds requirements around regular strategic reviews, climate adaptation planning, cyber risk management, and digital infrastructure for estate management. At this level, the evidence standard shifts again. What I encounter in organisations working towards Level 3 is often an accurate picture of good operational practice but a poorly articulated governance layer above it.
The annual return at Level 3 is testing whether the responsible body has a managed, self-reviewing system, not a set of individually good practices that happen to exist in the same organisation. Evidence at this level must show that strategic reviews are scheduled and happening, that the outputs of those reviews are informing the asset management plan, and that risk identification (including cyber risk) is connected to board-level decision making. A cyber risk register that sits with the ICT team and has never been presented to trustees does not evidence Level 3 assurance, even if the register itself is well constructed.
Good evidence at Level 3 is systemic: it shows how the parts connect. Board papers, strategy review minutes, risk escalation records, and updated asset management plans that visibly respond to condition data. The responsible body must be able to trace the line from information gathered to decision made to action taken.
Level 4 (Advanced): demonstrating sector leadership and value for money accountability
At Advanced, the Standards describe practices that go beyond effective management: a dedicated board member for estates, full cost-of-occupation modelling, performance challenge against value for money, a climate action plan embedded in the estate strategy with a decarbonisation roadmap. The evidence standard here is the hardest to define precisely, because it is not about whether required tasks have been completed. It is about whether the responsible body is operating the estate as a managed asset.
In the organisations I have worked with that aspire to Level 4, the evidence gap is almost always in the value-for-money and governance dimensions. The Standards require that the responsible body understands the full cost of occupying the estate and uses that understanding to challenge performance. This means budget analysis linked to condition data, procurement decisions that can be shown to represent value for money, and a board member who can speak with informed authority about estate performance. The evidence is the integration of financial, condition, and governance data into a coherent accountability picture.
Good evidence at Level 4 is an accountability narrative: the estate is managed as a strategic asset, performance is measured and challenged, and the board is actively engaged with that challenge, not receiving reports about it. The distinction between receiving reports and receiving assurance is, at this level, the whole point.
Evidence quality is built over twelve months, not in the six weeks before a return is due
The organisations that find the annual return straightforward are not the ones with the most sophisticated systems. They are the ones whose practice has been consistent across the year. Their evidence exists because the work was planned, carried out, reviewed, and reported through a documented cycle. The return asks them to describe what they already do.
The organisations that struggle are the ones that have been doing the work but not recording it in a form that constitutes evidence, or recording it in systems that are not integrated with governance, or operating a compliance cycle that is visible to the estates team but opaque to the board. Their evidence problem is not a return problem. It is a year-round practice problem that surfaces at return time.
What the annual return framework is ultimately asking is whether the responsible body has built the management discipline that the Standards describe. At each maturity level, the answer to that question requires different evidence. At Baseline, it requires documents that are current and board-approved. At Transitioning, it requires records of active practice. At Fully Effective, it requires evidence of integration and self-review. At Advanced, it requires an accountability narrative that connects financial, condition, and governance data in a way the board can speak to.
None of that can be assembled from scratch in the weeks before a return is due. Evidence quality is the product of a year's worth of disciplined practice, and the return is simply the moment it becomes visible.
Julie Lawson is a founding partner of The Estates Strategy Partnership and director of Education Compliance Solutions. She is a Chartered Manager with over twelve years in education sector roles, including Trust Business and Compliance Manager and Chief Operating Officer at named multi-academy trusts.