Academy Trust Supply Staffing Procurement Checklist 2026
Before You Drop Your Supply Agency Because of GCA: What Academy Trusts Should Check First
There is a lot of noise in education recruitment at the moment about the Government Commercial Agency Supply Teachers and Education Recruitment framework RM6376.
Some schools are being left with the impression that:
“GCA is mandatory, therefore we can only use recruitment agencies that appear on GCA.”
That is not the full rule.
And the distinction matters.
The Department for Education's own published guidance expressly allows academy trusts to use an alternative compliant agreement rather than the GCA framework, provided the relevant procurement requirements are met and the rates do not exceed those available through GCA.
So if your school has been told:
“You have to stop using your existing agency because they aren't on GCA”
or:
“Academy trusts can only use GCA agencies from now on”
you should check the actual DfE wording before making any decision.
Those statements are far too simplistic.
The Word “Mandated” Is Being Used Without the Full Context
This is where much of the confusion appears to be coming from.
The GCA framework is described as mandated for academy trusts.
Taken on its own, that sounds absolute.
But that is not where the rule ends.
The 2026 Academy Trust Handbook states:
“Trusts must use the Government Commercial Agency, Supply Teachers and Education Recruitment for their supply staffing requirements unless they have an alternative compliant agreement with rates which do not exceed those available through the framework.”
The crucial word is:
Unless.
That exemption is written directly into the requirement.
The Department for Education's own supply staffing guidance then goes further and includes an entire section headed:
“Compliant alternatives”
It explains that academy trusts may secure another framework or contract where it:
is compliant with the Procurement Act 2023;
meets the relevant financial and procedural requirements; and
does not exceed the applicable GCA rates.
So is GCA “mandatory”?
GCA is the default mandated route. It is not the only permitted route.
Those are two very different statements.
If “GCA is mandatory” is being used to mean:
“Your school can only work with recruitment agencies that are directly listed on RM6376”
that interpretation does not reflect the full DfE guidance.
For a detailed breakdown of the actual wording, read:
Why Schools Need to Be Careful With GCA Marketing Claims
There are obvious commercial advantages to being a supplier on a framework.
Agencies that have secured a place on RM6376 will understandably promote that position.
But schools should distinguish between marketing language and the actual procurement requirement.
A recruitment agency saying:
“We are approved on GCA”
is perfectly reasonable.
An agency suggesting:
“You are legally required to use us because we are on GCA and your existing agency isn't”
is a very different claim.
Before accepting that assertion, an academy trust should ask:
Does our existing or proposed supplier have another compliant procurement route?
If the answer is yes, the correct question is not simply whether that agency appears on the GCA supplier list.
The trust should assess whether the alternative arrangement satisfies the requirements set out by DfE.
1. Establish the Procurement Route
Before changing suppliers, establish exactly how your existing or proposed agency can be appointed.
Depending on the circumstances, this could include:
GCA RM6376;
another compliant framework;
a compliant managed procurement arrangement;
an alternative Procurement Act 2023-compliant contract;
or an existing compliant contractual arrangement.
The important issue is procurement compliance, not simply whether an agency's logo appears on the GCA website.
2. Procurement Act 2023 Compliance Matters
DfE guidance specifically recognises alternative routes which comply with the Procurement Act 2023.
That is an important point because procurement law does not revolve around a single commercial framework.
Frameworks are mechanisms through which compliant purchasing can take place.
GCA RM6376 is one such mechanism.
It is not the only possible mechanism recognised in DfE's own guidance.
Where an alternative arrangement is used, the trust should make sure that the procurement process is appropriate for:
anticipated expenditure;
contract duration;
the services being purchased;
applicable procurement thresholds;
award requirements;
and the trust's internal procurement rules.
3. Check Your Total Anticipated Spend
Schools also need to understand the financial value of the proposed agreement.
DfE guidance currently identifies £207,720 including VAT when explaining the threshold above which a Procurement Act 2023-compliant procurement process is required.
Importantly, trusts should consider the estimated overall requirement rather than artificially looking at isolated individual bookings.
For multi-academy trusts, this can involve considering the combined anticipated supply staffing expenditure across schools within the trust.
The procurement route should therefore be considered at the outset rather than after substantial expenditure has already taken place.
4. Alternative Routes Must Meet the Relevant GCA Pricing Requirement
Using an alternative route does not mean ignoring the GCA requirements altogether.
DfE guidance states that academy trusts using an alternative procurement route must ensure that their costs do not exceed the applicable rates available through the GCA framework.
That is why transparent pricing matters.
Schools should be able to understand the composition of their daily charge, including:
worker pay;
employer National Insurance;
pension and statutory costs;
agency or supplier fee;
and total charge rate.
A school should not simply be presented with one unexplained daily figure.
Transparent pricing allows the trust to demonstrate value for money and assess the alternative arrangement properly.
5. Being Outside GCA Does Not Automatically Mean an Agency Cannot Be Used
This is perhaps the most important message for schools.
An education recruitment agency not appearing directly on RM6376 is not automatically prohibited from supplying an academy trust.
DfE's own published rules recognise compliant alternatives.
The question should therefore be:
“What compliant procurement route can we use to appoint this agency?”
Not simply:
“Are they on GCA?”
Where another route is being proposed, the trust should establish:
what the procurement arrangement is;
who operates it;
whether the trust can access it;
whether it complies with the Procurement Act 2023;
what award or call-off process applies;
whether the relevant pricing requirements are met; and
what documentation must be retained.
Uniform Education has established alternative procurement routes for precisely this reason.
6. Do Not Cancel an Existing Agency Agreement Without Checking It
Another area where schools should be cautious is existing recruitment arrangements.
DfE guidance expressly states that it will not force a trust to exit an existing contract provided that contract is compliant with the Procurement Act 2023.
That is significant.
A school should therefore not automatically terminate a successful existing staffing relationship because somebody has told them:
“GCA means you can't use that agency anymore.”
First establish:
whether an existing agreement is in place;
whether it is compliant;
its duration;
anticipated expenditure;
what procurement route was used;
and whether any further action is actually required.
Unnecessarily changing supplier can have operational consequences too.
For SEND schools, alternative provisions and specialist settings in particular, continuity matters.
A Learning Support Assistant, behaviour mentor or SEND teacher who already understands a pupil, class or school can be extremely difficult to replace simply because somebody has misunderstood a procurement rule.
7. Procurement Compliance and Recruitment Quality Are Different Things
Framework status should never be confused with recruitment quality.
A framework can establish:
commercial terms;
procurement rules;
pricing structures;
supplier requirements;
and contractual protections.
It cannot guarantee that the person answering the telephone understands your school.
It cannot guarantee that an agency understands:
SEND;
SEMH;
autism;
PMLD;
alternative provision;
PRUs;
challenging behaviour;
outreach tuition;
or the needs of an individual child.
Schools should continue assessing agencies on the things that actually affect pupils:
candidate quality;
safeguarding;
reliability;
retention;
speed of response;
knowledge of the setting;
local candidate coverage;
pricing;
and service.
Procurement should enable good recruitment.
It should not remove good suppliers simply because somebody has incorrectly interpreted a framework requirement.
8. Ask Your Agency to Prove Its Procurement Position
Schools should absolutely challenge recruitment agencies.
If an agency says it can continue supplying your trust outside GCA, ask it to demonstrate how.
Questions should include:
What compliant procurement route are you using?
How does it comply with the Procurement Act 2023?
Are we eligible to access it?
What award or call-off process must we complete?
Can you provide the relevant procurement documentation?
How do your rates compare with the applicable GCA rates?
Can you provide a transparent breakdown of your daily charge?
A credible agency should welcome those questions.
9. Read the DfE Guidance — Not Just Recruitment Agency Marketing
Ultimately, this issue does not need to become complicated.
The Department for Education has published the position itself.
The 2026 Academy Trust Handbook contains the alternative.
The Department's supply staffing guidance contains a dedicated section called “Compliant alternatives.”
Schools should rely on those primary sources when making procurement decisions.
Not rumours.
Not sales presentations.
And not a competitor telling you that you suddenly have no choice but to use them.
So, Do Academy Trusts Have to Use GCA?
Not exclusively.
That is the point that frequently gets lost.
The DfE has made GCA RM6376 its default mandated framework for academy trust supply staffing.
But the DfE has also expressly provided for alternative compliant agreements.
Therefore:
“GCA is mandated” does not mean “only GCA-listed agencies can ever be used.”
An academy trust can use another route where the relevant DfE and Procurement Act 2023 requirements are satisfied.
Any suggestion that there is no alternative route at all should be checked carefully against the DfE's own published guidance.
For the complete explanation of the GCA wording, including links to the official Government sources, read:
Uniform Education is not currently a direct supplier on GCA RM6376.
We do not pretend otherwise.
What we do have are established alternative procurement routes designed to allow eligible schools and academy trusts to appoint Uniform Education through an appropriate compliant process.
Our primary route is through Value Match, with additional procurement routes available where appropriate.
Schools continue dealing directly with Uniform Education for:
vacancies;
candidate selection;
safeguarding and vetting;
bookings;
timesheets;
ongoing consultant support;
and day-to-day recruitment.
The procurement structure sits behind that relationship and provides the appropriate commercial and governance mechanism.
Our pricing is transparent, and where the DfE's GCA pricing requirement applies, we can provide schools and trusts with the information required to benchmark the relevant supplier fees.
About Uniform Education
Uniform Education is a specialist SEND and education recruitment agency supporting schools, academy trusts, local authorities and education settings across London and the Home Counties.
Established in 2015, we provide:
SEND Learning Support Assistants;
Teaching Assistants;
Teachers;
HLTAs;
SEMH and behaviour support staff;
outreach tutors;
1:1 SEND tutors;
alternative provision staff;
and permanent education recruitment.
We believe schools should be able to choose excellent recruitment partners while meeting their procurement obligations properly.
And that starts with understanding what the rules actually say rather than what somebody benefits commercially from telling you they say.
Uniform Education
Recruitment to Shape Future Generations.
This article provides general information and does not constitute legal or procurement advice. Academy trusts remain responsible for confirming the suitability of their procurement arrangements, complying with applicable legislation and DfE requirements, and obtaining professional advice where appropriate.
