Before 6 November: the SEND place decision that cannot wait for January

01 / The decision now

The school conversation has to finish before the authority return.

DfE opened the process on 7 October and requires local authorities to submit by 6 November. It tells schools and colleges to contact their provider local authority where the current funded number may not be appropriate. That gives leaders a short period in which to reconcile current occupancy, planned admissions, other authorities' commissioning and provision expected to open, resize or change age range in 2027/28.14

The workbook is not merely a forecast sent to DfE. It records whether the proposed number has been agreed with the provider and how many places the local authority is prepared to fund through DSG deductions. Even an authority with no changes must upload a signed nil return. DfE says commissioning and final-decision evidence should be retained locally to avoid later disputes. A trust should therefore keep the pupil-number basis, commissioning correspondence, governance decision and delivery assumptions together.13

02 / The funding boundary

More funded places do not enlarge the local high-needs settlement.

For academies and colleges, local authorities fund increases through deductions from their dedicated schools grant; maintained provision is funded directly. DfE is explicit that changes to provider-level places do not alter the authority's overall high-needs allocation before those deductions. The process redistributes and aligns funding inside the local settlement rather than creating additional national funding for the decision.17

Place funding is also only one part of the financial model. Top-up funding follows the individual pupil or student and local arrangements. Capital funding for new or improved provision sits on a separate route. A plan that names more places without resolving top-up assumptions, staffing, accommodation, equipment and transport may correct one line in the allocation while leaving the delivery model exposed.167

03 / Who is in scope

Academy and maintained-school routes are not interchangeable.

The DfE return covers mainstream academies and free schools with SEN units, resourced provision or sixth forms; special and AP academies; further-education colleges; independent learning providers; and certain new special post-16 institutions. Maintained schools, maintained special schools and pupil referral units do not normally use this DfE process for their 2027/28 pre-16 and post-16 place changes because their authority funds them directly and reports them through its section 251 return.1

There are exceptions around academy conversion dates, and separate treatment applies to AP free schools and providers funded from census or ILR data. Leaders should identify the provider type and funding route before interpreting a workbook absence as evidence that no change is planned. The public opportunity signal is the underlying capacity change, not simply whether a provider appears in one central return.13

04 / Commissioning evidence

Count all commissioners, not only the provider authority.

DfE expects the proposed total to reflect places commissioned by every local authority, including children and young people travelling across boundaries. Provider authorities should speak to schools and colleges in and outside their area; commissioning authorities should ensure their placements appear in the provider authority's return. This is particularly important where a specialist setting serves a wider region or expects a material change in cross-border demand.1

The evidence pack should distinguish current placements, confirmed commissioning intentions and a reasoned forecast. An aspiration to expand is not the same as demand agreed by commissioners. Equally, a census snapshot can understate a provision that is opening in phases. The decision should reconcile occupancy, enquiries, named commissioning discussions, planned start dates and any dependency on buildings or approval.13

Agreement status changes the outcome rules. If a mainstream or AP academy does not agree an increase or reduction, DfE says the existing number will be published. For special academies, special free schools, 16 to 19 academies, FE colleges and independent learning providers, a not-agreed increase follows the authority request, while a not-agreed reduction must now reach a single 10% threshold before DfE considers it against census or ILR evidence. The revised threshold replaces the previous five-place rule for smaller providers.1

• Current funded places and actual placements by commissioner
• Agreed and developing 2027/28 commissioning intentions
• Admissions profile, leavers and phased opening assumptions
• Capital, staffing, transport and approval dependencies
• Provider agreement status and retained decision evidence

05 / Two clocks are running

Use the earlier 5pm deadline, then protect the 4 December gate.

DfE's published pages currently conflict on the closing time. The principal process guide says returns are due by 11:59pm on Friday 6 November. The digital-form guide says local authorities must submit by 5pm that day. Until DfE aligns the wording, the defensible operational choice is to work to 5pm, retain the confirmation and avoid a same-day submission dependency.12

A second clock applies where an academy needs a new age range, a new SEN unit or resourced provision. The significant-change route and funding agreement must support the change. A signed deed of variation is due by 4 December for it to be reflected in the initial allocation issued by the end of March. A later 9 April route can lead to a revised allocation by the end of August, but that is a different delivery position.135

06 / Places are not provision

Translate the number into an opening-day operating model.

Once a proposed number is agreed, the delivery plan should show where pupils will learn, which needs the environment is designed to meet, who will lead and staff it, what training is required and which services remain dependent on external commissioning. Capital works and accessibility adaptations may be supported through high-needs provision capital allocations, but that route has its own local plan and assurance requirements.6

The same discipline applies to reductions. Fewer funded places may reflect lower commissioning, changed provision or a correction to persistent vacancies. Leaders should test the effect on staffing, curriculum breadth, fixed estate costs and pupils already placed. A numerical adjustment can be accurate for funding purposes and still require a careful transition plan for the organisation.17

07 / The January control

Publication creates a final check, not a fresh planning round.

DfE aims to publish outcomes in January 2027, followed by a two-week enquiry window. Schools, colleges and authorities will need to confirm that agreed changes appear correctly. The window can also capture a number that was included but not agreed in November and has since been resolved.13

It is a weak recovery route for an organisation omitted from the original workbook. DfE warns that requests concerning providers not listed as requiring a change may not be considered. The January control should therefore compare the published outcome with the retained November decision file; it should not be treated as the first moment at which a school raises its 2027/28 requirement.13

Leadership questions

Questions that turn the development into a governing conversation.

School Connection intelligence lens

What the national Observatory can add, and where it must stop.

The strongest public intelligence sequence is provider discussion, local commissioning evidence, submitted change, January outcome, March allocation and delivered capacity. School Connection will keep those states separate. A local-authority plan, schools-forum paper or trust proposal is an early signal; it is not a confirmed funded opening until the relevant decisions align.13

Monitoring should connect the provider-level outcome with significant-change notices, deeds of variation, local high-needs capital plans, planning or building work, recruitment and transport changes. That creates a more complete account of where capacity is genuinely advancing while protecting the distinction between a public development and private commercial intelligence.56

What we are monitoring next

Publication is the beginning of the watch.

• Any DfE correction aligning the 5pm and 11:59pm submission times.
• Local-authority and provider discussions before 6 November, including cross-border commissioning.
• Deeds of variation and significant-change approvals approaching 4 December.
• The January 2027 outcomes and two-week enquiry window, followed by March provider-level allocations.
• Publication of the 2027/28 high-needs operational guide and any changed funding rules.

Continue the evidence trail

How this develops our earlier coverage

• The £6,000 SEND line may start moving by postcode ↗
• SEND reform moves the test into mainstream ↗
• SEND funding announcements do not settle the capacity question ↗