Read the requirement accurately

From 1 October 2026, paragraph 2.29 of the Academy Trust Handbook requires trusts to use DfE Energy for Schools or a DfE-approved energy deal unless they source an alternative agreement of equivalent value for money. It applies when energy contracts are renewed. The exception does not remove procurement obligations.

The practical question is therefore whether your proposed alternative is both lawfully procured and supported by a defensible value assessment. Treat those as two separate tests. A satisfactory price does not cure the wrong procurement process; a compliant process does not automatically establish the value of the deal.

Plan the comparison before the quotations arrive

DfE recommends planning and benchmarking at least 12 months before expiry. It does not expect trusts to exit existing contracts. Identify current obligations first, then work backwards from the notice deadline, procurement timetable and approval dates.

Our recommendation is to agree a comparison protocol with the CFO or procurement lead. Record which sites, consumption period, contract dates and service requirements the exercise covers. Specify how you will treat differences in fees, charge exclusions and risk. This prevents the eventual recommendation being shaped around whichever offer happens to look most attractive on a single day.

Make the benchmark meaningful

DfE offers benchmarking using actual bills from the previous financial year. Energy for Schools uses variable pricing, so exact future prices cannot be confirmed in advance. Explain this limitation rather than presenting an indicative benchmark as a guaranteed future bill.

Ask the adviser to prepare a comparison in two layers. First show the delivered-cost calculation and the assumptions behind it. Then explain differences that cannot be reduced to one number: uncertainty over charges, flexibility, service commitments and exposure to volume changes. Date the evidence and identify when prices were obtained. Do not compare an expired offer with a live one without making that limitation explicit.

• Use the same consumption assumptions and clearly identify the period being priced.
• Show unit charges, standing charges, fees and material exclusions together.
• Explain the treatment of tax and any difference in recoverable or irrecoverable costs.
• Value additional services using specified deliverables rather than unsupported savings claims.
• Show a reasonable adverse scenario alongside the central estimate where risks differ.

Produce the four-part decision pack

DfE identifies four outputs when considering a deal outside the approved arrangements: comparison with at least one approved deal; written evaluation of price, terms, service and risk; a recommendation and local governance decision; and the SRMSAC declaration with supporting evidence.

Build these as working documents throughout the exercise. The recommendation should explain why the proposed contract meets the trust's needs, what alternatives were considered, the uncertainties that remain and who accepts the residual risk. Include unsuccessful options fairly. If the comparison cannot establish equivalent value, record that result and revisit the proposal rather than trying to manufacture a justification after signature.

Keep the adviser accountable after award

A capable TPI should help assemble the evidence and explain the recommendation in language governors can challenge. Ask it to identify its supplier coverage, remuneration and conflicts, then state which tasks remain with the trust. Agree how a proposed contract change will be assessed and who can authorise it.

Our recommendation is a short post-award handover: signed documents, notice calendar, agreed charges, service contacts, opening meter evidence and the date for checking the first bill. The trust should retain its own accessible copy. Review whether the additional services used to justify the choice actually arrive. Use the agreed service commitments to monitor value throughout the contract. Guidance checked on 2 November 2026.