Studies of public policy recognise that the implementation of ‘policy in practise’ is part of an iterative process that can lead to change through reinterpretation, recasting or just non-compliance of the intended policies in question (Pressman and Wildavsky, 1973; Sætren, 2024). Early emphasis in policy implementation research focused on the operational practise of the street level bureaucrat in carrying out and delivering policies (Lipsky, 1980). Indeed, rather than viewing implementation as a separate stage of the public policy process, studies found that a more fluid and dynamic understanding is required, stretching the making of policy to the practise level of day to day on the ground actions (Durose, 2011; Sager and Gofen, 2022; Sætren, 2024). Studying the decisions and actions of ground-level policy actors led to identification of local level innovation and policy entrepreneurship, and a shift to understanding the viewpoints of those actors involved in policy implementation practises (Tummers et al., 2015; Boswell and Corbett, 2015; Arnold, 2021).

More recently, improving the design of policy has been an analytical focus to enhance policy implementation in public sector organisations (Hudson et al., 2019; Capano and Lepori, 2024). The range of actors involved in policy delivery has also become more visible in recent decades, beyond public sector organisations, emphasising the operation of public policies from the state as shifting from governing to governance (Moran, 2003). That is, the state directing the implementation of policy through networks of state and non-state actors rather than primarily through line-managed bureaucracies, complementing changes taking place in public administration under the new public management credo of the central state – ‘steering not rowing’. The growth of the contemporary state marked an increase in regulatory policies, away from more costly distributive or redistributive policies (Majone, 1994; Moran, 2003). The conceptualisation of the regulatory state signified the shifting of the burden of action, compliance and, importantly, costs to the private sector and professions. Yet this should not be seen as merely nonstate actor networks interacting. The state and its policies remain a core feature of this governance, but with a wider set of actors enrolled into policy delivery (Bell and Hindmoor, 2009). The reach of the state extended through auditing of compliance to regulation by private companies, public institutions, professions and civil society alike (Power, 1997). Furthermore, such governance occurs at multiple levels (national, regional-local, and in some cases international), again highlighting the dynamic and interactive nature of policy development across these levels. The public policy and governance relationship and multi-level governance approaches were applied as a framework to understand the dynamics of Britain’s food policy (Lang et al., 2001; Lang et al., 2009); and have become more prevalent in local food systems and policy research (Lever et al., 2019; Parsons et al., 2021; Monticone et al., 2023; Yapp, 2023) and in broader cross-national food systems transition literature (van Bers et al., 2019; Béné and Abdulai, 2024).

This research applies a public policy and governance conceptual lens to examine key ‘implementation settings’, the specific contexts in which decisions about school meals and their procurement are made and enacted. It explores how the overall national policy direction and ongoing policy developments at the macro level are interlinked with and related to the actions and inactions occurring within these settings. The term ‘implementation settings’ is introduced to capture both the sites of decision-making and the contextual factors that shape those decisions in the day-to-day governance of procurement practises and school nutrition standards. This conceptualisation parallels Lever et al.’s (2019) rethinking of ‘place’ in local food governance—not merely as a fixed physical location, but as a dynamic and relational space where diverse actors and processes interact. Both ‘place’ and ‘implementation settings’ are conceptual arenas where policy is negotiated, and practise is shaped.

Literature on school food policy implementation in the United Kingdom acknowledges variability in compliance, but this is typically examined in relation to differences between the devolved nations. Scotland, Wales, and Northern Ireland appear to have more effective policies and stronger mechanisms for implementation, monitoring, and compliance. This is partly because school meal provision in these nations is more centralised and adherence to statutory standards is more closely integrated into service delivery. In addition, state-funded schools in these nations remain under local authority control, unlike in England (Adamson et al., 2013; McIntyre et al., 2022; Furey and Woodside, 2022; Lalli et al., 2024). Other UK studies also link policy compliance to health and dietary outcomes (e.g., Pallan et al., 2024a; Pallan et al., 2024b).

The wider literature underscores the global scale of the challenge. Matela et al. (2023), for example, report poor school food policy implementation across Europe and the Western Pacific but show that “hand-holding” schools in the initial years of implementation through capacity building, robust monitoring, and periodic evaluations, significantly improves adherence. Ronto et al.’s (2020) meta-synthesis of 28 studies from various countries identifies barriers and facilitators to effective school food policy implementation. These papers, whilst emphasising the technical challenge of compliance and the implications of poor compliance, focus less on the ideological and structural contexts shaping these policies and their implementation. They also focus less on the innovative role of diverse actors and mechanisms especially in English local authorities, catering companies and schools in driving innovation and improving compliance and therefore, health and dietary outcomes.

National policy governing English school food provision dates to The Education (Provision of Meals) Act, 1906. The current policy framework for school food provision was recast in 1980, when under prime minister, Margaret Thatcher, the Conservative government introduced the Education Act (1980) which removed the obligation to provide school meals, except for pupils from households receiving benefits. The Act also devolved nutrition standards to local authorities and encouraged packed lunches to reduce budgets, prevent wastage and permit parental choice over meal preferences (Finch, 2019). National school food nutrition standards were only re-introduced in 2001. In 1988, the Conservative government opened school food provision to the private sector through compulsory competitive tendering (CCT), whereas it had previously been provided solely by local authorities (Morgan, 2004, 2025). Although the subsequent Labour government replaced CCT with the Best Value regime in 1997, this still retained competition and ‘value for money’ as core principles.

The 2023 Procurement Act, which came into effect in February 2025, however, should modify these guiding principles. This post-Brexit legislation introduces the Most Advantageous Tender model, enabling procurers to consider values beyond cost in contract awards (Cabinet Office, 2023). It also encourages small and medium sized enterprises (SMEs) and voluntary, community, and social enterprises (VCSEs) to engage more fully in public procurement through reserving lower-value contracts and simplifying tendering processes (Cabinet Office, 2024). Covering all public goods, services, and works, including local authority food procurement, the Act now legally permits English public food procurement to align with wider goals of local economic and environmental sustainability (Swensson and Tartanac, 2020). Another core piece of procurement legislation is the Government Buying Standards for Food and Catering (GBSF), introduced in 2011 and overseen by Department for Environment, Food and Rural Affairs (DEFRA) and the Department of Health and Social Care (DHSC). The GBSF sets standards for food production, processing, nutrition, resource efficiency, and socio-economic aspects (Cabinet Office, 2014). Compliance is mandatory across the public sector although not for schools despite the fact that education settings account for around 60 per cent of UK public food procurement, with English schools spending £2.1 billion annually of the £5 billion government food and catering budget (Environment, Food and Rural Affairs Committee (EFRA), 2021; Crown Commercial Service (CCS), 2023; Quince, 2024). The DfE nonetheless encourages schools to comply and to prioritise local, seasonal, and higher-welfare food (Department for Education (DfE), 2025a).

The rapidly accelerating ‘academisation’ of schools begun by the Labour government in 2000 is another political process that affects the governance of English school meal policy implementation. Academies are a type of state-funded school in England that unlike other state schools are independent from local authority oversight, with greater autonomy over their budgets and curricula. These are overseen by charitable trusts that often manage groups of schools in a Multi-Academy Trust (MAT). From only 203 in 2010, by 2025 there were 10,770 academies, out of England’s 22,000 state schools (Pennington et al., 2024; Public Sector Network, 2024). MATs are, therefore, increasingly powerful players in shaping school food provision, especially since they often consolidate catering provision across academies with a single provider for cost efficiency, simplified oversight and alignment to Trust values (Education Policy Institute, 2017; BESA, 2019).

The 2013 School Food Plan, an independent review commissioned by the DfE, has strongly influenced English school food policy in recent years. It led to a revision of the National School Food Standards (SFS) and the introduction of Universal Infant Free School Meals (UIFSM) for pupils in Reception to Year Two (ages four to seven), alongside existing means-tested free school meals (FSM) for older children. These are key aspects of school meals that can be guided by policy: the former updating and simplifying mandatory nutrition standards, with the intention of making them easier to implement and the latter extending access to free school meals to reduce inequalities (Parnham et al., 2022a). These policies are mandatory for all state-funded schools in England, including local authority-maintained schools, academies, free schools, and special schools. In 2025, the Labour government also introduced an SFS-compliant Free School Breakfast initiative in England [Department for Education (DfE), 2025b]. As noted above, English school food procurement is encouraged to follow sustainable procurement guidance as outlined in the GBSF but is not governed by any specific public procurement principles beyond the general public-sector procurement framework, which includes consideration of social value. The School Food Standards (SFS) are thus the only mandatory regulations specific to school food across all four UK countries. However, the devolved nations set their own nutrition standards and have distinct criteria for free school meal pricing and eligibility, public procurement regulation and mechanisms to support local procurement. Given these national differences and the fact that the other devolved nations operate solely public sector school meal provision, this paper focuses primarily on England. See Table 1 for an overview of contemporary English school food policy discussed in this article.

The formal framework for English school food policy and procurement spans multiple levels and involves both public and private actors. DEFRA oversees national food and agricultural policy, whilst the Department for Education (DfE) manages school food policy, with additional roles held by the DHSC, the Treasury, and, more recently, Crown Commercial Services (CCS). The DfE also oversees eligibility and funding for free school meals (both UIFSM and means-tested FSM) and sets annual funding rates, although these are not linked to inflation. Schools and Academy Trusts receive funding through two grants, but this is not ringfenced solely for school meals. They may contract with local authority caterers or external private providers, ranging from in-house teams to national catering firms. Where external providers are used, the DfE advises specifying the SFS in contracts and service agreements to ensure compliance and accountability [Department for Education (DfE), 2025a]. However, free school meal funding levels fall short of the real costs of provision and contract prices, requiring local authorities, schools, and MATs to find additional funds. See section 3.3 for more discussion.

Procurement practises differ by provider type. Local authority caterers usually purchase through pre-negotiated frameworks managed by procurement teams often with support from regional professional buying organisations (PBOs), which oversee due diligence and supplier vetting. Private and in-house caterers manage their own supply chains. Whilst local authority caterers remain under local authority oversight, MATs and private caterers operate independently of this control. Catering arrangements also vary: meals may be cooked on-site, in neighbouring schools, or in centralised kitchens, and are either freshly prepared or blast-frozen and reheated (Sabet, 2022).

The SFS are the mandatory set of standards that explicitly seek to promote societal goals through school meals, sitting alongside broader procurement regulations that encourage consideration of social value in public sector spending. They are managed by the DfE, unlike other areas of public food procurement regulation, which fall under the jurisdiction of DEFRA and CCS. The current SFS are food-based standards (specifying foods to be included, restricted, or excluded) introduced through the 2014 Requirements for School Food Regulations and taking effect in 2015 for all state-funded schools. Schools are guided to implement these through an online practical guide available on the DfE website [Department for Education (DfE), 2025a].

The SFS have improved the nutritional quality of school meals, which are now significantly healthier than most packed lunches (Haroun et al., 2011; Stevens and Nelson, 2011; Pearce et al., 2013; Parnham et al., 2022b). However, many school food campaigners argue that the current standards are only a minimal baseline for promoting children’s nutrition. They also require updating in line with the 2015 guidance from the Government’s Scientific Advisory Committee on Nutrition (SACN), which includes recommendations to increase consumption of foods such as pulses to boost dietary fibre intake [Scientific Advisory Committee on Nutrition (SACN), 2015; Food charity policy advisor, 21/04/23; Food charity director, 8/6/23]. The nutrition standards of the Government Buying Standards for Food and Catering (GBSF), which apply public sector food procurement apart from schools, were already revised in 2021 to align with SACN guidance. Despite ongoing calls from NGOs and within government to update the SFS and ensure coherence across dietary policy, this did not happen under the Conservative government (School Food Review, 2023). Interviewees could offer no explanation although speculated that the government was prioritising efforts to improve compliance (Former local authority caterer, 04/10/23; Food charity policy advisor, 21/04/23). In June 2025, the new Labour Government announced that it was “acting quickly with experts across the sector to revise the School Food Standards.” [Department for Education (DfE), 2025e].

There is widespread evidence for poor and inconsistent compliance (Parnham et al., 2023; Peirson-Hagger, 2024). The national food charity, The Soil Association Food for Life (FFL), is the only third-party organisation that routinely monitors individual school compliance as part of its own voluntary standards. They estimate that 60 per cent of English schools are non-compliant (Food for Life, 2019). Subsequently, a 2022 Food Foundation report estimated that only 25 per cent of English schools were committed to meeting the standards (Goudie and Hughes, 2022), and a 2024 study of 36 English secondary schools, found that none were fully compliant (Pallan et al., 2024a). There are various reasons for non-compliance, although central is that the SFS were introduced in 2015 without monitoring and accountability mechanisms and no formal programme to support schools and caterers with implementation. This means that the SFS operate, in effect, as just guidance (Parnham et al., 2023; Peirson-Hagger, 2024; Matela et al., 2023). Project workers for FFL (27/01/23; 20/06/23) clarify that non-compliance is usually around more challenging aspects of provision such as serving oily fish once every 3 weeks, which is expensive with low uptake (Peirson-Hagger, 2024). Not all cases of non-compliance are necessarily negative, given certain anomalies in the SFS. For instance, several interviewees highlighted examples of schools adopting entirely vegetarian menus, which technically contravene the requirement to serve a portion of meat or poultry at least three times a week (Local authority caterers, 09/02/23; 02/03/23; 20/06/23).

Non-compliance also often arises from efforts to make meals more ‘child-friendly’—that is, increasing fat, salt, and sugar content to appeal to children’s palates and encourage uptake (Sustainable Food Coordinator, 05/01/23; Food for Life manager, 27/01/23). The reasons for this are complex. For example, caterers reported that post-COVID, children had become more conservative in their food preferences, likely due to increased exposure to processed convenience foods at home—a trend observed in the literature (Gallagher-Squires et al., 2023). This shift has made pupils less familiar with, and more reluctant to try, traditional homemade school meals such as cottage pie (Local authority caterers, 20/02/23; 13/03/23; 20/06/2023). Cooks in several schools reported serving baked beans daily to ensure that some fussy children would at least eat something, despite the SFS permitting them only once a week. This practise was particularly noted in areas of deprivation, where lunch may be a child’s only substantial meal of the day. (School cooks, 16/03/23; 06/05/23; Kantar Public, 2023). The lack of effective oversight has given rise to an ‘implementation quandary’. As one headteacher noted, “I feel torn between the immediate need to ensure children eat, even if it’s not the healthiest, and the long-term goal of promoting healthy eating habits…given the lack of oversight I feel obliged to prioritise the former, but it conflicts with my role as an educator.” (10/03/23).

Several interviewees also expressed concern that some contract catering companies were deliberately serving menus non-compliant with the SFS and higher in fat, salt and sugar to boost meal uptake and maximise profit (Sustainable food coordinator, 05/01/23; public health consultant, 02/03/23; senior local authority catering manager, 13/01/25). A 2022 Food Standards Agency (FSA) report supports anecdotal evidence that school compliance became less consistent after transitioning from local authority to private catering provision (Kantar Public, 2023). Nixon et al. (2025) note the need for urgent and robust research to identify whether there is a link between types of school meals contracts for food procurement with the quality of food provided and health and academic outcomes for school children.

The GBSF was last updated in 2014, with nutrition standards revised in 2021. In 2022, DEFRA launched a consultation to revise the welfare and sustainability standards, including ambitious targets for local and environmentally sustainable sourcing, although no updates have been implemented to date [Department for Environment, Food, and Rural Affairs (DEFRA), 2022]. There is cross-party support for increasing local sourcing in public procurement and regular NGO calls to update and reform the GBSF (FFL Policy Advisor, 21/04/23). In 2024, the Quince Review, an independent review on local food procurement commissioned by DEFRA, called for a single set of procurement standards to become mandatory across the whole public sector including schools (DEFRA local procurement researcher, 10/04/24; Quince, 2024).

Since its introduction in 2011 there has also been no routine monitoring of the GBSF and there is little evidence of its influence on public procurement (Quince, 2024). Given the lack of monitoring and compliance measures, there is also little incentive for caterers to adopt or adhere to the standards where not explicitly introduced into school tenders. This view was supported by interviewees, two local authority catering managers had not heard of it and another senior local authority caterer noted, “I do not use it really, it’s not something that’s routinely used now” (20/02/23; 13/01/25).

Local authorities have a varied approach to oversight of school meals – from active intervention to none (Kantar Public, 2023). They are only directly involved in provision where schools or academies use local authority caterers, in which case they can proactively ensure meals comply with SFS. Leicestershire Traded Services (LTS), the Leicestershire local authority caterer, designs school menus with the local Nutrition and Dietetics Service (LNDS) to ensure compliance, although not every local authority offers a similar service (Public health consultant, 02/03/23).

Similarly public health sits within local authority jurisdiction in England, and public health teams can take initiatives that not only ensure SFS compliance but also encourage healthier and sustainably sourced school food provision in local authority schools and through local authority caterers. One route taken by Leicester and Leicestershire public health teams has been to commission the charity, FFL to work with schools and public sector caterers (Public health consultants, 12/02/23; 02/03/23). FFL have their own voluntary standards for schools and caterers that are more ambitious than the SFS. Compliance at lower award levels is monitored through a checklist completed by schools with supporting evidence, whilst external visits and routine verification are carried out for the highest “Gold” award in schools (Food for Life coordinator, 20/06/2023; Food for Life, 2025). However, this approach has not been widely adopted by many English local authorities; only six FFL commissions were recorded in England in 2025. Local authority interviewees explained that it was difficult to demonstrate measurable progress in schools to meet award criteria, making it hard to justify the associated costs to council budgets. This challenge was not limited to the FFL awards but also reflected wider changes in school staffing, where improvements in food culture were often undermined by high turnover. When cooks, headteachers, or teaching assistants left, their expertise and investment in training were lost (Public health consultants,12/02/23; 02/03/23).

In the absence of mandatory national sustainable procurement policy, local authorities themselves have innovated to incorporate local sustainable food procurement into school food. This includes within public sector school catering services, where interviewees noted that sustainability work is usually driven by a committed individual or small team pro-actively seeking local suppliers and working with procurement teams to make tenders accessible (Former local authority caterer, 04/10/23; Love British Food, 2022; Wilkinson et al., 2024).

Interviewees at LTS highlighted the work of one pioneering senior catering manager that had encouraged the service to adopt FFL’s voluntary caterer standards, Food for Life Served Here (FFLSH) which run alongside the individual school awards (Food for Life, 2025; Sustainable food coordinator, 05/01/23; Food charity programme manager, 27/01/23). LTS, which contracts with 240 primary and secondary schools, academies and MATs across Leicestershire, Leicester, Birmingham, Cambridgeshire and Luton, achieved a FFLSH Gold award in 2017. This award requires producing locally sourced, seasonal, and freshly prepared healthy meals incorporating at least 15 per cent organic ingredients and 5 % ingredients sourced to high ethical and environmental standards, alongside food education activities.

More widely, in 2011, Leicester City Council introduced its own sustainable food procurement policy for all council procurement (City Councillor, 07/03/23). Public health teams in both Leicester and Leicestershire have also developed food plans with dedicated officers to better coordinate sustainable food sourcing within the local authority by establishing local food partnerships that map local stakeholders across the food system, including local farmers and growers. This is backed by the national charity funded network, Sustainable Food Places, which provides training, guidance, and its own tiered award scheme (Sustainable Food Places, 2024). The Sustainable Food coordinator within the Leicestershire public health team, has collaborated with both the FFL commission and local authority caterer to encourage local, sustainable procurement within county schools (21/11/23). Within the local authority, other actors that can promote initiatives on public procurement include Sustainability or Climate action teams, although their scope and staffing vary widely depending on local priorities, political leadership, and budget constraints (Local authority environmental education coordinator, 24/01/23; City councillor, 07/03/23).

Local authority caterers nevertheless highlight that there are challenges engaging Council procurement teams, given the bureaucratic complexity and the legacy of the lowest cost-based procurement culture. Several noted that procurement teams did not understand the value of local procurement and that they buy hundreds of items, “for some, buying vegetables is no different from buying office equipment” (Local authority caterers, 09/02/23; 20/02/23). In addition, procurement officers tended to be path-dependent, preferring established procurement routes: “Everyone is so time poor in the Council … You’d have to be pretty enthusiastic to start a new procurement exercise given the long timeframes and limited capacity” (Senior local authority catering manager 24/01/23).

One senior local-authority catering manager (13/01/25) expressed interest in exploring dynamic procurement to work with SMEs and local suppliers, although felt unlikely to use the CCS Buying Better Food online platform, citing the administrative burden for the catering team of running mini-competitions and contracting directly with small suppliers. They were, however, piloting another dynamic procurement mechanism, with software also developed by Equilibrium Markets. The software allows them as caterers to establish sourcing criteria to include small sustainable producers, but with their main wholesaler handling contracts and logistics rather than the local authority itself (AgileChain, 2025). Although dynamic procurement is widely touted as a tool for transforming public procurement, other research highlights similar practical, legal and commercial complexities that must be addressed to fulfil this potential (European Commission, 2021). These include legal issues around regulatory compliance and supplier liability, and commercial aspects such as entrenched practises, limited supplier capacity, and additional costs of integrating digital systems (Wilkinson et al., 2024; Keech et al., 2025).

Another uncommon but potentially transformative structure for local authority ownership offers a means to sidestep the unwieldy bureaucratic nature of public procurement, whilst maintaining public oversight. This model involves establishing public sector caterers as separate legal entities wholly or partly owned by local authorities, rather than operating as internal council departments. Local Authority Trading Companies (LATCs) or arms-length external organisations (ALEOs) allow greater flexibility in procurement by operating outside standard local authority procedures, whilst still enabling a degree of public accountability. A leading example is CATERed, a co-operative Community Interest Company (CIC) jointly owned by Plymouth City Council and local schools. This structure enables CATERed to simplify local, sustainable food sourcing, reinvest profits into service improvements and remain competitive, with continuing public oversight (Plymouth City Council, 2025).

Local authorities in England, however, have no formal oversight to influence or monitor food provision in schools or academies that choose contract or in-house caterers – as one public health consultant noted, “this leaves a considerable oversight gap because we simply do not know what is going on in those canteens” (02/03/23). One local authority, has nevertheless, found a means to influence this type of school food provision, by attaching conditions to discretionary funding. The London Borough of Southwark has no public sector catering service and so local schools all have contracts with external providers. Before the introduction of nationally funded UIFSM in 2014, Southwark used internal budgets to provide free meals to all primary school children. This enabled them to attach additional requirements for private caterers receiving the funding including: offering only water to drink, ensuring healthy dessert options and paying catering staff the London Living Wage (School food transformation officer, 08/04/25). Southwark has also introduced a ground-breaking School Food Transformation Programme, supported by a dedicated school food team working in schools, to monitor compliance and support improvement (Southwark Council, 2024a). Alongside this, it also introduced in 2025 a £4 million school food procurement framework as a mechanism to steer private caterers towards local sustainable procurement. Private caterers can now access any supplier contracted by Southwark Council and purchase approved goods directly through the council’s system, removing the need to run separate tenders. This framework offers good value for private caterers by reducing administrative overheads, ensuring compliance with the borough’s social value and quality standards, and providing access to a vetted pool of local suppliers offering competitive bulk-purchase rates (Southwark Council, 2024b; Sustain, 2024; School food transformation officer, 08/04/25). This level of influence, oversight and innovation in Southwark is however highly unusual. It is made possible by a combination of a long-term political commitment to school food, access to additional local authority and charitable funds, and small and declining school-age population in the borough (School Food Transformation officer, 08/4/25).

Several interviewees highlighted the proactive approach taken by Scottish local authorities towards monitoring and implementation of Scottish school food standards and procurement regulations (Policy advisor 21/04/23; FFL Scotland, 09/01/23; FSA, 24/03/23; FFL coordinator, 20/06/2023). It is important to note, however, that in contrast to England, Scottish school food provision and governance has not been academised and all catering is provided by local authority caterers often with a single menu across all schools within the local authority, and all state-funded schools are under local authority control. Scotland’s national executive agency, Education Scotland, employs a dedicated team of Health and Nutrition Inspectors to conduct inspections monitoring adherence to nutritional standards (Kenton-Lake et al., 2021). Although Scottish local authorities hold statutory responsibility for compliance, the Health and Nutrition inspectors provide independent oversight – spending several days in schools making observations, reviewing documentation and conducting interviews. They report to the school and catering service, and inspectors follow up, supporting ongoing improvements (Kantar Public, 2023). The 2022 FSA report notes that this approach is time and resource intensive, happens less frequently than routine hygiene inspections and require inspectors to have nutrition training (Kantar Public, 2023). That said, it does follow observed measures for the improving adherence to school food policy with its focus on encouraging capacity building in school settings (Matela et al., 2023).

There are, nonetheless, limits to how far local authorities can influence school food provision in England, given the growing dominance of Multi-Academy Trusts (MATs) as autonomous decision-makers with their own priorities, alongside the expansion of contract catering companies offering low-cost tenders, appealing to schools and academies. A major consequence has been the erosion of local authority control over school-related budget streams. One local councillor observed, “As a council we have less interest in school food now because of the academisation agenda. There are new players and we have less money, less opportunity, less oversight, and less ability to make change in this area” (07/03/23). This trend is likely to persist as rising food and staffing costs, and the challenge of remaining competitive, prompts some local authorities to reconsider the viability of maintaining public catering services, given that it is not a statutory responsibility to provide one (Local authority caterers, 20/02/23; Senior local authority catering manager, 13/1/25).

It is ultimately the statutory responsibility of school governors and trustees of Academy Trusts to ensure compliance with the SFS [Department for Education (DfE), 2025a]. However, anecdotal and empirical evidence suggests that many governors are unaware of this responsibility (27/01/23; CEO of a MAT and head teacher, 10/03/23; Pallan et al., 2024b). This may explain why compliance across schools is variable and often shaped by individual school leadership (Parnham et al., 2022a).

One effective strategy at the school level is the adoption of a ‘whole school approach to food,’ an approach first given prominence in the 2013 School Food Plan, which seeks to embed a healthy food culture throughout the school day. This approach aligns with the World Health Organization’s Health Promoting Schools framework, which emphasises a whole-school strategy, integrating health into school policies, the curriculum, the school environment, and engagement with families and the community (Turunen et al., 2017). This includes using mealtimes as teaching opportunities and building connections with local farmers. This approach is endorsed by the DfE’s SFS guidance and the updated Ofsted inspection framework, which also encourages schools to develop voluntary food policies and action plans. Schools and Academies can also independently sign up to the FFL award standards, with FFL recognising where schools may not have direct influence over their catering provider (Food for Life, n.d.) There are also other organisations and academic collaborations that have stepped into the implementation vacuum to offer free guidance to schools for sustainable and healthy food provision (Food charity director, 08/06/23; Food charity coordinator, 20/06/2023). In practise, headteachers often take the lead in driving this agenda, implementing school-specific policies to promote school meal uptake and foster a positive food culture. Examples include extending lunch breaks, restricting packed lunches, and compulsory uptake of FSM (FFL programme manager, 27/01/23; CEO of MAT and headteacher, 10/03/23; School business manager, 12/03/23).

The 2023 Procurement Act includes Academy Trusts under its remit, enabling them to consider quality, sustainability, nutrition, and social value alongside cost when awarding catering contracts. Whether they do in practise, however, is highly variable. Some MATs align catering with their educational and ethical aims, such as promoting sustainability and healthy lifestyles. Others delegate decisions to operations managers, who often prioritise the lowest financial bid (CEO of a MAT and headteacher, 10/03/23). A senior local authority catering manager (13/03/23; 13/01/25) noted that some recent MAT tenders had removed FFL quality standards and explicitly favoured cheaper options. The catering service had previously won contracts based on better quality sourcing but were unable to compete on price alone. One senior local authority manager was particularly disheartened by cases where schools absorbed into MATs were switched from public sector provision to the existing MAT catering service provider, without consultation with headteachers, parents, or pupils (13/01/25).

Interviewees raised concerns that regulation is lagging behind academisation, with little consideration for how policy plays out across diverse catering structures. For example, the Labour Party’s 2024 election pledge to source 50 per cent of public sector food locally and sustainably would also need to apply to Academy Trusts and private contractors, or risk pushing public providers out of the market entirely, given the higher costs of local sustainable sourcing (Senior local authority catering manager, 13/01/25).

Private caterers are not required to provide any public service, beyond meeting the mandatory SFS. There is nevertheless evidence of best practise in local and more sustainable procurement within the private sector, especially from inhouse caterers where they may have greater autonomy in procurement decisions and the ability to create direct long-term relationships with local suppliers (Private school caterer, 30/03/23; Dimbleby and Vincent, 2013). Some private providers have also independently pursued FFL caterer certification and adopted sustainable procurement models. Interviewees highlighted some examples including Food for Thought—a not-for-profit, member-owned school meals provider serving 90 schools in Liverpool – that sources over 50 per cent of its food locally, 30 per cent organically, and uses free-range eggs and farm-assured meat. Similarly, Local Food Links, a community-owned social enterprise based in Dorset, supplies 50 member schools and sources nearly all its ingredients from Dorset-based producers (FFL programme manager 27/01/23; 26/10/23; FFL coordinator, 20/06/23; Local Food Links, 2025; Food for Thought, 2025).