What’s actually changed in the Independent School Standards (April 2026)?

Written by Ellen Mukwewa, Director & School Improvement Consultant at Marell Consulting Limited and Founder & Director of NAISA.

On the 2nd of April, the DfE published a revised version of Independent School Standards – Guidance for Independent Schools. Originally published in April 2019, the document was produced “…to support school proprietors, school staff and governing bodies of independent schools in understanding their obligations under the Independent School Standards (ISS) …”

This is a critically important document. All independent schools must meet all of the standards at all times as a condition of registration, and this guidance helps to interpret requirements that are not always obvious from reading the legislation alone.

It’s also worth remembering that this document has never covered everything and that’s by design. When the original guidance was published in April 2019, there were already separate pieces of guidance in place for areas such as first aid, fire safety and school premises. So even now, this updated document needs to be read alongside those, rather than as a single, standalone source.

“Have the standards actually changed?” (Short answer: yes… but also no… but also yes)

If you’re wondering whether the standards themselves have been revised - they have.

It may not be immediately obvious if you visit the legislation page (as I did yesterday on 7 April 2026). The timeline of revisions at the top of the page suggests the last update was August 2024. What you might miss - and what I did miss at first - is the red-bordered section just below it, which explains that further changes have been made but not yet fully incorporated into the published version.

I’ll admit, I did reach out to someone who had posted about the changes to say they might not be correct… only to realise shortly afterwards that they were. Slightly embarrassing, but also a useful reminder that the legislation pages don’t always tell the full story at first glance.

So, what’s actually changed?

The updated guidance sets out six substantive changes, all helpfully highlighted in the Document history section on page 3. What I’ve tried to do here is group them in a way that makes sense in practice:

1.        Changes driven by new standards

2.        Changes reflecting standards introduced since 2019 (but only now explained)

3.        Changes reflecting updated guidance linked to existing standards

1. Updates due to new standards

Two genuinely new standards have been introduced:

Standard 16A – Recording the use of forceThis standard focuses on the recording of restraint and seclusion. The guidance is helpful in distinguishing between what is statutory (for example, making a written record as soon as possible after an incident) and what is intended to support schools in reducing the need for restrictive interventions in the first place. It also provides clearer definitions of key terms such as restraint and seclusion.

There is separate DfE guidance on this which goes into more detail - definitely worth a read once you’ve worked through the ISS update.

Standard 32A – Reporting the use of forceThis standard links directly to 16A. It focuses on communication with parents, making clear that incidents of restraint or seclusion should be shared as soon as practicable, ideally on the same day, unless there is a clear reason not to (for example, risk of harm to the pupil or where the pupil is over 20).

Together, 16A and 32A create a much clearer expectation around both recording and transparency.

What about the other changes mentioned in the legislation?

• Paragraph 32(1) – words substituted

  
  

   There are also amendments to paragraph 32(1), although these are not yet visible on the legislation page or clearly reflected in the guidance. Based on the introduction of 32A, it is reasonable to expect that these changes strengthen expectations around how information - particularly relating to restraint and safeguarding - is shared. For now, this is one to be aware of rather than rely on.

• Paragraph 31A – new standard (not yet visible)

  
  

   A further new standard, 31A, is referenced in the amending regulations but has not yet appeared in the guidance or the legislation page. It sits within Part 5 (Premises), immediately after paragraph 31, which defines what is meant by “suitable” provision and “special requirements”. Its positioning suggests it may build on this, potentially strengthening expectations around how premises meet the needs of different pupils. Again, one to watch.

2. Updates reflecting standards introduced since 2019

One of the more interesting aspects of this update is that some of what feels “new” actually isn’t new at all - it’s just newly visible.

Since 2019, there have been changes to the standards (for example around attendance and RSHE), but the main guidance document wasn’t updated to reflect them at the time. Instead, schools have needed to draw on separate, more specific guidance in those areas alongside the ISS.

For example:

• Attendance (Standard 15)The guidance now aligns more clearly with updated expectations around monitoring and responding to absence, introduced in August 2024 and expanded in Working Together to Improve School Attendance.

• RSHE (Standard 2A)The inclusion of this reflects statutory expectations that have been in place since September 2020 and expanded through Relationships and Sex Education (RSE) and Health Education but are now more clearly embedded within the ISS framework.

In both cases, the expectations aren’t new, but they are now brought into the core ISS guidance.

3. Updates linked to wider guidance and policy changes

The final group of updates reflects changes in the wider policy landscape.

These include:

• Mobile phone use in schoolsNow referenced within the guidance, linking to behaviour and safeguarding expectations set out in the DfE’s Mobile phones in schools guidance (2024).

• Fundamental British ValuesExpanded references and examples, drawing more directly on existing non-statutory guidance, including Promoting fundamental British values as part of SMSC in schools (2014, updated), to support schools in understanding how this can be demonstrated in practice.

• Data protection complaints (linked to Standard 33)Reflecting changes in data protection legislation coming into force from June 2026, alongside expectations set out by the Information Commissioner’s Office (ICO), including guidance on handling complaints and individuals’ rights.

What this group of updates highlights is that, even where the standards themselves have not changed, the expectations that sit alongside them continue to develop and are now being drawn more clearly into the core ISS guidance.

Final thoughts

For a number of years, schools have been working across a range of separate guidance documents often detailed and well-established in their own right rather than a single, central source. The first version of this core guidance was published only in 2019! That’s not necessarily a weakness; it reflects how expectations have evolved in response to different areas of policy and practice. What this updated version does is begin to draw some of those strands more clearly into the core ISS guidance, without replacing the need for the more detailed documents that sit alongside it.

There are still some loose ends - particularly where amendments have been made but not yet fully published - so this is very much a “watch this space” moment.

But overall, the direction of travel is clear:greater clarity, greater consistency… and in some areas, greater accountability.

And if nothing else, it’s a good reminder for all of us to scroll just a little bit further down the legislation page before confidently telling someone they’re wrong.

Marell Consulting Limited provides specialist support exclusively for non-association independent schools, including independent school registration , regulatory compliance, school improvement consultancy and training.

Contact enquiries@marellconsulting.co.uk or visit www.marellconsulting.co.uk.