Compliance rails

Compliance rails around UK school capital: CDC2 succession, Procurement Act 2023, ESFA fee caps, NAO January 2025 backlog.

Why each matters in the business case

PA23: governs how CF25 mini-competitions and direct awards must be advertised, awarded and reported[PA23].
ESFA fee cap: 10% of works on CIF cases[CIF]. Cases above need justification.
CDC2 succession: from March 2026 the DfE's in-house condition data programme has succession arrangements. Trusts commission private condition surveys to evidence CIF / SRP cases[NAO].
NAO Jan 2025: framed the £13.8bn estate maintenance backlog; sets the political context for SRP / CIF priorities[NAO].

Tightening in 2026-27

The fee cap is tightening as ESFA enforces compliance more rigorously. PA23 reporting obligations are now fully in force. Trusts should expect more documentation requirements on condition-survey evidence.