Al Kingsley (EdTech SIG Chair) Letter to Permanent Secretary

Subject: School management information systems – proposed framework and the wider direction of education technology procurement

Dear Ms Acland-Hood,

I am writing in a personal capacity about the Department’s proposed procurement framework for school management information systems (MIS), and what it implies for how schools will buy technology more generally.

Some of this follows on from our conversation at Bett in January about data in the education system and the Department’s ambition for a data spine. I said then that I thought the direction on data was right, and I still do. My concern is with the route now being taken to get there.

This is my position: I have chaired the British Educational Suppliers Association’s EdTech Special Interest Group for the past five years and I am writing based on feedback from many members of the sector. I also chair a multi-academy trust, which will place me on the buying side of this transaction. I am not an MIS supplier and have no commercial interest in the outcome of this procurement.

I want to be clear that I am not disputing the premise of making things easier. Choosing an MIS is one of the harder decisions a school or trust makes. The functional differences between platforms are not obvious, the cost of getting it wrong is high, and most schools go through the exercise so rarely that they do not build up institutional knowledge of how to do it. School business leaders have rightly said this for many years.

The framework route adds complexity

Where I part company with the Department is on the execution of the proposed procurement framework.

If the framework admits every supplier that meets a set of criteria, schools will be presented with broadly the same providers they see today, with an additional procurement process in front of them. This does not simplify anything.

If the framework filters providers, then someone is deciding which platforms schools may consider. On what evidence, judged by whom, and with what recourse for a supplier excluded or for a school whose preferred system is not on the list?

The criteria are not yet defined and are expected to be reviewed annually. This means a supplier could meet the standard one year and not the next, or a school could find that the system it implemented at considerable cost is no longer available to renew. None of this gives schools more confidence than they have now.

Such a threshold set without published methodology also shapes who is able to enter this market at all. New entrants are the mechanism by which a market like this improves. If the effect of the framework is that a supplier must satisfy an annually shifting standard before a school may consider it, the Department will have made entry harder at precisely the point it says it wants better choice.

Managing supplier performance

I understand the Department is considering how supplier performance would be measured and managed once the framework is running. I would encourage you to consider the following points.

Judging whether a supplier is performing well is not a simple matter of counting complaints. The schools most likely to complain are often those whose implementation was under-resourced at their end rather than the supplier’s.

If a small number of complaints can affect a supplier’s standing on the framework, the Department will be making commercially serious decisions on a thin evidence base. There is no published threshold, no proportionality test, no route of appeal and no consultation duty, because these belong in a commercial instrument rather than a statutory one.

A department that sets the market’s contractual terms, mandates the route to market and then adjudicates supplier performance is regulating that market. If that is the intention, it should be done openly and with the safeguards that regulation normally carries. If it is not the intention, the framework should say so.

A deadline, but no framework

Paragraph 2.30 of the Academy Trust Handbook 2026, which takes effect on 1 October, requires trusts to align all MIS contracts with the Department’s MIS framework by September 2027. The framework does not yet exist.

Trusts are therefore being asked to plan around an instrument whose lots, award criteria, call-off mechanism and supplier list are all unpublished. As a trust chair, I will be taking one of these decisions myself, and I cannot take it against a document that is not available to read.

I would also note the contrast within the handbook itself. Paragraph 2.28 permits trusts to use an alternative compliant agreement for supply staffing where rates do not exceed those available through the framework. Paragraph 2.29 does the same for energy, where comparable pricing has been sourced. Paragraph 2.30 contains no equivalent provision.

MIS is the only one with no alternative-agreement route, and it is the one where switching costs, migration risk and the consequences of getting it wrong for safeguarding and attendance records are highest.

If there is a reason for treating a pupil records system more tightly than electricity, it has not been published.

Undefined scope boundary

Nothing that has been published so far establishes where the framework stops. That detail determines how much of the education technology sector ends up inside a centrally managed purchasing route.

An MIS does not sit alone. It has finance, HR and payroll, safeguarding, assessment, parental engagement, payments, catering and a long list of other products connecting to it. Many of these are supplied by companies that have nothing to do with MIS.

If the boundary is drawn to include the products that plug into an MIS or the modules an MIS supplier offers alongside it, the framework reaches markets many times larger than the one the notice describes. Moreover, it does so without those markets being consulted.

A notice advertising £800 million for MIS does not put the wider sector on notice that its categories are in play.

There is a related question of fairness. If an ancillary product is inside the framework when bought from one supplier and outside it when bought from another, the Department will have created a distinction that rests on the identity of the seller rather than on the product, the school or value for money.

I do not believe that is anyone’s intention, but a lack of definition such as this could have ramifications further down the line.

I would ask that the scope boundary is published and consulted on before the tender notice, and that the Department states explicitly whether products which integrate with an MIS fall inside or outside it.

Interoperability

If data moves cleanly and predictably between systems, switching costs fall, comparison becomes easier, competition improves and schools’ choices get simpler without a framework doing that work at all.

This is the fix for the problem the Department has identified, and it is the part of the programme I would put first.

It has instead been deferred. The data spine has no published specification, while the information standards power under the Children’s Wellbeing and Schools Act 2026 commences on 30 September.

Suppliers are being asked to commit to framework terms before knowing what “interoperable” and “API-enabled” officially mean, and they will then have little practical choice but to accept whatever specification follows.

Taking these steps the other way around would cost the Department less and deliver more.

Cost, price and value for money

Frameworks like this are not cheap to run. They require people with real commercial and technical understanding of this market to define criteria, assess suppliers, manage performance, handle disputes and carry out annual reviews.

That capability either has to be built inside the Department or bought in. On any realistic estimate, the cost of doing it properly is substantial.

I would want to be confident that it has been costed honestly against the expected savings for two reasons:

1. If the framework is administered thinly, it will make poor decisions.
2. If it is administered well, it may cost more than it saves.

On price, I would note that value for money under section 12 of the Procurement Act 2023 is not the same thing as lowest price.

On every previous occasion, the Government has compressed prices in this market and supplier investment has followed the price down.

MIS is one of the areas where automation could meaningfully reduce administrative workload in schools over the next few years, and that investment will not be made in a market squeezed to margin.

I would also record a concern about the evidence underneath all of this. The Department’s June 2026 assessment of the education technology market put the sector at £5.93 billion. That figure does not match what those of us who work within it recognise.

If central capability is being built against an overstated figure, the case for building it has not really been made.

I would ask that the methodology is revisited and published before it is relied on further.

The precedent

None of this would have me writing to you if it stopped at MIS.

The reasoning that produced this framework applies equally to every other category schools buy in, and the EdTech testbed programme has evaluation and purchasing built into its later stages.

If the direction is that schools should buy their technology through arrangements that the Department designs, prices and polices, then that is a significant change in how the sector works.

It deserves to be argued for openly rather than assembled one framework at a time.

Discussion points

I would greatly welcome the opportunity to discuss some of the issues at this early stage.

For example, it would be helpful for the EdTech sector to learn how the Department intends to define suppliers’ entry criteria to the procurement framework, whether (or how) it intends to filter or rank suppliers and assess performance, and what that would mean for suppliers in terms of consequences or routes of appeal.

In addition, I feel that it would be beneficial to talk about interoperability and the costs of establishing and running the framework, along with a projection of the savings it expects to make.

May I also ask the Department to urgently review the September 2027 obligation for schools to align all MIS contracts with the Department’s MIS framework, since it does not yet exist, and also revisit the Academy Trust Handbook 2026 alternative-agreement provisions, providing clarity should there be a continued absence of one for MIS.

Simplification should be simple

The Department has correctly identified a real problem and has a good answer to it already in hand that does not add complexity, cost or uncertainty.

Specifying what core MIS functionality should include is a good idea. So is publishing proper buying guidance.

Best-practice guidance of that kind would raise the standard of purchasing decisions across the sector, would cost very little and would benefit schools immediately.

I would urge the Department to publish this guidance as soon as possible. I would support this without reservation, and the BESA EdTech Special Interest Group would be happy to help produce it.

I would be grateful for a response, and I would welcome a meeting with your officials if that would be useful. The BESA Special Interest Group would far rather help the Department get this right than spend the next two years contesting it.

Yours sincerely,

Al Kingsley MBE
Chair, EdTech Special Interest Group, British Educational Suppliers Association
Chair, Hampton Academies Trust
CEO, NetSupport Limited

This letter was sent on the 17th August 2026