Why reserves are under the spotlight — and what creeping CoA timelines mean for this year’s return
Updated: June 2025
If you thought the BFR was finally settling into a rhythm… think again.
Yes, the 31 August submission deadline is now familiar. Most trusts have adapted well: trustee sign-off cycles are clearer, budgeting timelines are more predictable, and with key assumptions like the teacher pay award and associated funding agreed earlier, there’s been less scrambling than in previous years.
But the return itself continues to evolve.
Last year brought significant changes to ICT reporting, with more detailed lines around hardware, software, and digital spend. This year, the focus shifts to reserves transparency — while the DfE’s Chart of Accounts continues to land later and later, making mapping more difficult just when many budgets are already approved.
In short: the deadline might be steady, but the goalposts keep moving.
Reserves: under the spotlight
This year’s most high-profile change? A sharper DfE focus on trusts with high reserves.
In section 5.8 of the BFR guidance, trusts forecasting revenue reserves over 20% of total income are now required to explain:
- Why reserves are being held.
- How they plan to use them.
- How this aligns with strategic priorities.
It’s part of a wider push for transparency — but for many trusts, it also risks fuelling a long-standing narrative that reserves are excessive or being hoarded.
However, our IMP MAT Finance Sector Insight Report 2024 tells a different story.
Based on forecast data from 260+ trusts:
- 27% of MATs expect to fall below 5% reserves by the end of 2024/25.
- 30% in 2025/26.
- 37% in 2026/27.
“The perception that trusts are hoarding reserves is not evident based on the 3-year projection.”
Primary-majority trusts are especially exposed — with over 40% expected to fall below the 5% level by 2026/27.
Whether or not you GAG pool (in which case school-level reserves must still be reported individually), the direction of travel is clear: Expect more attention on how you manage, explain, and plan your reserves.
CoA changes: creeping later, creating complications
Meanwhile, a familiar BFR challenge is getting harder to manage — the timing of the Chart of Accounts (CoA) update.
Even though the BFR submission window opened on 3rd June, and trusts can submit their return now if they want to, the 2025/26 CoA has still not been released.
That’s a problem — because the return includes 2025/26 projections, which should ideally be mapped to the correct version of the CoA.
And this isn’t a one-off. The CoA has been creeping later every year:
| CoA Year | Release Timing |
| 2022/23 | May 2022 |
| 2023/24 | May 2023 |
| 2024/25 | June 2024 |
| 2025/26 | Still pending (early June) |
This creates a dilemma for trusts:
- Submit early using the 2024/25 CoA — and risk needing to remap or resubmit later.
- Wait for the updated CoA — and work to a tighter submission window.
With new codes expected for 2025/26, submitting early could mean extra work later — making it harder to balance speed with accuracy.
One silver lining: the teacher pay award came early
After years of mid-summer scrambles, there’s a rare bit of good news:
This year’s teacher pay award — and the associated funding to support it — have already been agreed, giving trusts time to reflect confirmed figures before submitting their BFR.
While the support staff pay award is still pending, many trusts have already built in reasonable assumptions — meaning there’s less risk of last-minute rework or resubmission once the final numbers land.
It also reduces the need for a familiar September headache: the complete post-BFR budget overhaul. With fewer moving parts, many trusts should be able to enter the new academic year with confidence that their submitted plans still hold up.
How IMP is helping
We’ve adapted our tools and support to help you navigate all this — without adding to your admin load.
In IMP Planner:
- BFR templates will reflect the final 2025/26 CoA, so you’re always submitting against the latest guidance.
- You’ll receive clear guidance on any structural changes to the BFR — and how to use our export template to submit your numbers with confidence.
- Our automated BFR export takes the faff out of the process, pulling everything together in a few clicks.
- And if you need help, you’re backed by a team of experts who’ve submitted the BFR themselves — many times over.
- Our BFR Wizard ensures accurate data entry, consolidation,and budget code mapping, saving time and improving efficiency.
The form might get more complex, but the process doesn’t have to.
See why IMP customers love our BFR Wizard 👇
In summary
While the BFR is now a fixture in the calendar, it continues to test systems, timelines, and processes.
- Reserves over 20%? You’ll need to justify them.
- No GAG/Reserves pooling? School-level balances are still required.
- Budget signed off? The CoA you used might be out of date.
- Pay award agreed? Good — but don’t forget to watch support staff.
So whether you’re waiting on final CoA codes, preparing your reserves narrative, or just aiming to avoid duplication — we’re here to help.
Let’s get through another BFR season — with fewer surprises, and fewer sighs.
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