Over recent months, one question has dominated my conversations with multi-academy trust leaders: how do we become compliant with the new supply staffing requirements?

It is an entirely reasonable place to start. From September 2026, the Department for Education says single and multi-academy trusts must procure supply staff through the Government Commercial Agency’s Supply Teachers and Education Recruitment framework, RM6376, unless they have an alternative arrangement that complies with the Procurement Act 2023 and does not exceed the rates available through the GCA framework. Existing contracts can continue where they meet those conditions.

For CEOs, CFOs, COOs and procurement leaders already balancing constrained budgets, audit requirements and operational pressure, the immediate temptation is to treat this as another implementation exercise: identify approved agencies, put the right order forms in place and demonstrate compliance.

But I believe that would miss the more important opportunity. The question trusts should now be asking is not simply, ‘How do we become compliant?’ It is, ‘What is the right long-term supply staffing model for our trust?’

That distinction matters. Compliance can tell a trust whether it is buying through an acceptable route. It cannot, on its own, tell leaders whether they have the right level of control, whether schools are receiving a consistent quality service, whether expenditure is visible across the trust or whether temporary staffing decisions support the trust’s wider workforce strategy.

The mandate is a catalyst, not the beginning of the story

The move towards framework procurement did not begin with the 2026 mandate. The sector has been moving in this direction for some time. Many trusts have accumulated relationships with multiple education recruitment agencies, creating understandable concerns about inconsistent fees, fragmented purchasing, and the difficulty of demonstrating value for money across schools.

What the mandate does is accelerate that change. The DfE reports that schools in England spend approximately £1.4 billion a year on agency supply staff. RM6376 introduces capped supplier fees, transparent cost breakdowns, pre-approved education specialists and common protections. The policy intent is clear: more of the money committed to supply should support education, rather than being lost through opaque or excessive charges.

This also sits within a wider change in public procurement. The Procurement Act 2023 places renewed emphasis on transparency, governance and effective contract management. The Academy Trust Handbook is explicit that trusts must protect public money and demonstrate value. Importantly, the handbook encourages continuous improvement, not compliance for its own sake.

That is why I see the current change as bigger than a framework launch. It is forcing trusts to examine an area of workforce expenditure that has often grown school by school, relationship by relationship and booking by booking. What worked for a trust of five schools may not remain appropriate at 15, 25 or 50. A model designed around local responsiveness can become difficult to govern as the trust grows.

What trust leaders are really wrestling with

In conversations with trust leaders, including through our work across Teaching Personnel, Protocol Education and SupplyBank, I rarely hear concern about the principle of stronger governance. The challenge is how to achieve it without losing the responsiveness, local knowledge and access to educators that schools value from their teaching recruitment agencies.

The questions are practical. Can schools continue working with several agencies? What happens if a trusted supplier is not on the framework? How should existing agreements be treated? Who owns the relationship at trust level? What information should central teams receive, and how often? How can a trust standardise procurement without slowing down an urgent 7am staffing decision?

The volume and specificity of questions raised during a recent DfE and GCA webinar reinforced the point. Leaders asked about short order forms, multiple suppliers, pricing, safeguarding evidence, temp-to-perm arrangements, procurement notices and trust-wide agreements. They were not resisting change. They were trying to reconcile compliance, quality, flexibility and operational reality whilst also minimising further disruption.

This tension is especially acute in decentralised trusts. Individual schools may use different school recruitment agencies for particular phases, subjects or local labour markets. Those relationships can be highly effective, particularly where an agency understands a school’s culture and staffing needs. Yet the central team may still lack a consolidated view of spend, rates, fulfilment, safeguarding assurance and recurring workforce gaps. Both perspectives can be valid. The problem is that school-level satisfaction does not automatically add up to trust-level control.

The strongest trusts will therefore treat implementation as a governance and workforce design exercise, not merely a contracting task. They will ask what decisions should remain local, what information must be central and where common standards are non-negotiable.  How can they also use this to save their already stretched current workforce, time.