Serving Up Change: The DfE's Proposed Reform of School Food Standards

These reforms sit within the government’s broader agenda to improve children’s health outcomes. Free school meals have been extended to all children in Universal Credit households from September 2026, and the consultation outlines sweeping changes to menu standards, accountability structures and how schools oversee their food provision.

Who is affected?

The reforms will apply across virtually all state-funded education settings: maintained primary, secondary, special, nursery and boarding schools; pupil referral units; academies and free schools; sixth forms attached to secondary schools; and non-maintained special schools. Few institutions will be untouched.

Key proposed change

The consultation covers substantial ground. Several proposals stand out as particularly relevant for schools and their governing bodies.

1. Nutritional standards

• Introducing requirements for what is permitted within a meal deal.
• Restricting the use of non-sugar sweeteners.
• Restricting the frequency of vegetarian or plant-based products which are marketed as meat alternatives.
• Increasing fibre
• Reducing sugar
• Restricting foods higher in fat, sugar and salt
• Expanding protein options available to schools to meet minimum requirements

2. Free breakfast clubs

Every state-funded primary school will be required to offer free breakfast clubs. For schools without existing breakfast provision, this is no small undertaking and will mean planning around staffing, premises and procurement well in advance.

3. Changes for nurseries and secondary schools

Maintained nurseries will lose their current exemption from full lunch standards, bringing them into line with primary schools. Secondary schools, meanwhile, will face a phased rollout: initial changes from September 2027, with further requirements following in September 2028. This recognises that secondary school catering operations are often more complex to adapt.

4. Governance and accountability

For governing bodies, the governance changes may prove the most demanding. From September 2027, schools will need to appoint a designated lead governor for school food and publish their food policies and menus online.

Governing bodies will also need to receive regular compliance reports and maintain active oversight of catering arrangements. The consultation makes one point especially clear: governors and trustees cannot outsource accountability. Even where an external contractor provides the catering, the governing body remains responsible for ensuring compliance.

“Whilst the nutritional changes are likely to attract the most attention, schools should not overlook the governance implications. The proposed framework introduces enhanced accountability and oversight requirements, meaning governing bodies will need to demonstrate that they are actively monitoring compliance and challenging where appropriate. Schools that begin preparing now will be better placed to manage operational and contractual risks.” comments Sarah Valentine, Partner.

5. Compliance, contracts and catering arrangements

In practice, many schools will find that their compliance position depends heavily on their catering arrangements. Where a local authority or private contractor provides food services, the consultation expects compliance obligations to be written into the contract or service level agreement. Caterers will need to evidence compliance and report regularly on take-up and financial performance.

Schools should not wait for the final regulations. Now is the time to review existing contracts, identify gaps against the proposed standards, and check whether current reporting gives sufficient assurance. Contracts coming up for renewal offer a particular opportunity to embed the necessary provisions.

"Schools should take the opportunity to review contracts, reporting mechanisms and assurance processes to ensure there is clear evidence that providers are meeting the required standards. Early engagement with suppliers and caterers will be key" says Sophie Parkin, Principal Associate.

Practical steps for schools

The regulations remain in draft, but that should not delay preparation. Schools that engage early will avoid a last-minute rush when the rules are finalised.

A sensible starting point is to benchmark current menus against the proposed nutritional standards and work with caterers to identify where adjustments will be needed. Procurement and catering contracts warrant review to flag any gaps or ambiguities around compliance responsibility. On governance, schools should be developing frameworks that demonstrate active engagement with the new requirements. An audit trail of decisions taken now will be valuable evidence later. Planning can also begin for the lead governor appointment, online publication of food policies and regular audit arrangements with caterers.

Implementation timeline

Primary schools face full implementation from September 2027. Secondary schools will see changes from the same date, with additional requirements phased in from September 2028. The governance obligations, including the lead governor appointment, also take effect from September 2027. Schools that act early will be in the strongest position when the deadlines arrive.

How we can help

Our Education team regularly advises schools, academy trusts and governing bodies on regulatory compliance, governance and contractual matters. We can help with contract reviews, governance advice, compliance assessments, procurement support, policy drafting, board training and implementation planning.

Schools would be wise to use the lead-in period constructively. If you would like to discuss how these proposals might affect your organisation, or to explore your compliance strategy, please get in touch.