Key information
Decision type: Director
Directorate: Communities and Skills
Reference code: DD2749
Date signed:
Date published:
Decision by: Tunde Olayinka, Executive Director, Communities and Skills
Executive summary
The Mayor believes that all primary school children in state-funded schools, including all-through schools, academies, state-funded special schools, alternative provision (AP), and non-maintained special schools (NMSS) should have access to free school meals. The funding will cover the cost of meals within term time for the September 2025 – July 2026 academic year.
This Director Decision seeks approval for the allocation of the Mayor’s Universal Free School Meals (UFSM) funds (as approved in Mayoral Decision (MD) 3332) and provides a full breakdown of the programme budget for the 2025-26 and 2026-27 financial years. It also provides an update on the current version of the Integrated Impact Assessment (IIA).
The Executive Director of Communities and Skills is asked to approve the total expenditure of up to £141m to deliver on the purpose set out above.
Decision
That the Executive Director of Communities and Skills approves:
1. expenditure of up to £132.5 million which will be allocated to London borough councils (boroughs) as grant funding to continue to deliver UFSM to eligible key stage 2 (KS2) children within London state-funded primary schools (including all-through schools, academies, state-funded special schools, alternative provision (AP), and non-maintained special schools) for the 2025-26 academic year
2. additional expenditure of up to £7.8m to cover meal uptake above 87 per cent
3. additional expenditure of £170.8k to support any costs related to any increased meal requirements beyond those for which funding has already been allocated in state-funded primary schools and non-maintained special schools, and address issues related to delivery in schools and/or access requirements, including specific needs related to protected characteristics, such as pupils with special educational needs and disabilities (SEND) and pupils who may have specific dietary requirements in connection with their religion or belief.
Part 1: Non-confidential facts and advice
1.1. In July 2023, the Mayor approved a £135m emergency funding plan to help families with the spiralling cost of living. This funding ensured that primary school children in London’s state-funded schools received free school meals (FSM) in the 2023-24 academic year (MD3146).
1.2. Due to the ongoing cost-of-living pressures, on 18 January 2024 the Mayor approved expenditure of up to £140m funding to local authorities. This enabled those local authorities (or the schools they fund) to continue delivering UFSM to KS2 children in London state-funded primary schools for the 2024-25 academic year, with a view to continuing to help families financially (MD3224).
1.3. On 6 March 2025, the Mayor approved expenditure of budget for the continuation of the UFSM scheme in the 2025-26 academic year to cover grants of varying amounts to be allocated to the boroughs and delivered to KS2 children in London’s state-funded primary schools (MD3332). This includes all-through schools, academies, state-funded special school, AP and NMSS. The allocation of funding depends on the number of eligible school children in each borough (this includes up to £2.5m to fund an uplift for the additional costs of kosher meals and where exceptional costs arise for children with SEND, as well as programme costs).
1.4. Children are only eligible for national government funded free school meals (FSM) if they are in a state-funded primary school and are either in KS2 (year 3 – 6) and live in households on universal credit earning less than £7,400 a year (after tax and not including benefits), regardless of the number of children in the family, or in key stage 1 (KS1). The Mayor’s UFSM scheme is not intended to displace national government funding for KS2 children who are eligible for FSM. The Mayor’s UFSM scheme extends eligibility for FSM to any KS2 children in state-funded primary schools who are not eligible for FSM under national government funding. The UFSM policy has been developed to replicate national government eligibility criteria for KS1 so that the FSM policy will effectively continue to be extended to incorporate eligible children in KS2 as well.
1.5. MD3332 delegated authority to the Executive Director of Communities and Skills to make programme-level decisions via a director decision (DD) form. This DD confirms the final funding allocations to London boroughs and the detailed breakdown of the approved UFSM budget for 2025 26 and 2026-27. The Deputy Chief of Staff and the Deputy Mayor for Children and Families have been consulted on this decision and are content with the detail included.
1.6. Detailed information on the UFSM scheme, including the approach taken to delivery of the policy in year three is set out in MD3332.
1.7. In 2023, an Integrated Impact Assessment (IIA) and Equality Impact Assessment (EqIA) plus supplementary analysis on independent schools were undertaken to inform the design and implementation of the policy. This identified areas for further work and/or consideration with regard to implementation of the UFSM programme, including aspects such as mitigation and future monitoring.
1.8. The GLA has kept the IIA, EqIA and supplementary analysis up to date to ensure that any new considerations and recommendations are captured. The EqIA and supplementary analysis were updated and annexed to MD3332. The IIA has been updated and can be found at Appendix A.
1.9. The GLA will continue to implement recommendations as outlined in these documents.
1.10. The UFSM scheme for the 2025-26 academic year proposes to pay £3 per meal (this is the same price per meal as paid for the 2024-25 academic year) – higher than the funding for Universal Infant Free School Meals (UIFSM) which is £2.61. This is the same price per meal as paid for the 2024-25 academic year.
1.11. Polling from YouGov, commissioned by the GLA in December 2023, showed that parents whose children have school dinners overwhelmingly support the Mayor’s UFSM scheme (92 per cent). Parents with more than one child in Years 3 to 6 (in state-funded primary schools) have seen their worry about feeding the family ease since the summer term (before this scheme was implemented); 23 per cent say they are less worried about all family members being able to have three meals a day, and a hot meal at least once a day.
1.12. Qualitative research led by GLA Opinion Research highlighted reduced anxiety levels from parents about feeding their children during term time. Many reported financial savings from not purchasing ingredients for packed lunches. Some are now not using food banks and quantified weekly savings of £15 which they use for food at home instead.
1.13. The independent evaluation of year one of the Mayor’s UFSM scheme, led by Impact on Urban Health (IoUH), highlights how the Mayor’s UFSM policy has significantly improved family finances, with families living on low incomes benefitting the most from the additional financial support. This has freed up money for them to spend on other costs such as healthier food at home, activities for children and school uniforms and reduced the burdens that they can face. 84 per cent of parents surveyed across the income spectrum said the availability of UFSM helped or significantly helped household finances.
1.14. The IoUH report shows UFSM is having a positive impact on the wellbeing of families and children across the capital, with pupils reporting that their school day is more enjoyable and parents describing a marked improvement in their relationships with schools. Many parents felt less of the worry associated with trying to make healthy packed lunches or to find the money for school meals. Parents, pupils and school staff reported children are trying and enjoying new foods. The evaluation found that the policy has alleviated many issues caused by dinner money debt; improved the lunchtime experience in some schools; and contributed to a smoother start to the school day. The policy has improved nutrition and parents, school staff and children have all described positive shifts in behaviour, concentration and energy levels during the school day, with children saying they feel ‘stronger and healthier’. The evaluation found the policy is popular with schools and parents and the vast majority want UFSM to continue.
2.1. The programme objectives are to:
• support delivery of the Mayor’s ambition to make London the best city in the world to grow up in
• help mitigate the impact of the cost-of-living pressures by; saving London’s families up to £500 per child , per year of the scheme; and ensuring primary school children in state-funded schools,
including state-funded special schools and AP as well as NMSS, do not go without at least one nutritious meal a day during term time
• demonstrate the Mayor’s role and commitment to address the impact of the cost of living on families, including other available sources of support
• reduce the stigma of receiving FSM in KS2; and increase the uptake of the Government’s FSM offer among families who need them most.
2.2. The programme outputs will include:
• grants to all boroughs wishing to take up the scheme to fund UFSM to all KS2 children attending state-funded schools, including state-funded special schools, AP and NMSS who are not eligible for the government’s FSM scheme
• a communications campaign to inform schools and raise awareness amongst families, of, among other aspects, the ongoing need for eligible parents to register for the government’s FSM scheme (this is to mitigate against the risk of a drop in income for schools, where such income is linked to the number of children eligible for FSM, such as the pupil premium grant)
• all boroughs to adopt an approach to universal registration as soon as possible in order to protect pupil premium grant income for schools
• further independent evaluations undertaken by external partners, measuring the policy’s impact on families' financial circumstances; changes in mental health, education and overall wellbeing.
2.3. Expected programme outcomes are as follows:
• London’s KS2 children (Years 3 to 6) attending state-funded schools (including state-funded special schools, and AP as well as NMSS) who are not currently entitled to the government’s FSM scheme, will have access to at least one nutritious meal a day during term-time, supporting families during the ongoing cost-of-living pressures
• continued benefits identified through the programme theory of change and year-one independent evaluation, including:
o Reduced pressure on family finances, for households across the income spectrum, with 84 per cent of all parents surveyed claiming the policy has helped or significantly helped their household finances (the biggest impact is seen on those families who have been the most constrained by rising food, energy and housing costs)
o a positive effect on the health and wellbeing of children and their families: more than one in three parents (35 per cent) stated that their child is now less worried about food at school
o contributing to a calmer start to the school day for families across the income spectrum, ensuring children arrive at school more ready to learn
o contributing to resolving the issue of dinner money debt for primary schools and parents who were previously struggling to cover the cost of primary school meals in London
o improving energy levels and ability to concentrate due to having a school lunch, with this again supporting children’s readiness to learn; more than a third of parents surveyed (34 per cent) felt that UFSM means their child can concentrate better on school and lessons
o acting as a leveller, supporting a sense of fairness and happiness at school.
Implementation and budget breakdown
2.4. Up to £141m of the UFSM budget will continue to be allocated to boroughs for delivery and implementation of the UFSM scheme. Final funding allocations for UFSM are based on the number of state-funded and non-maintained special school primary school pupils at KS2 on census day in January 2025 (minus the number of such pupils who were eligible on that date for the national government FSM scheme). The GLA will pay £3.00 as the price per meal, meaning the total expected number of pupils eligible for UFSM in each borough has been multiplied by £3.00 per day in the academic year (190 days) to finalise allocations with an assumed 87 per cent uptake.
2.5. Boroughs will be funded on the basis of an assumed 87 per cent uptake rate. The proposed funding mechanism is that boroughs will receive 50 per cent of their initial allocation within five working days of a signed grant agreement being received by the GLA in quarter 1. Following this, a further 25 per cent will be made available in December 2025 and April 2026 respectively. Funding must be claimed via the GLA Open Project System. This approach replicates the successful funding model used in the first two years of the programme.
2.6. Each school will have the opportunity to secure additional funding if they can evidence that uptake of the scheme has exceeded 87 per cent. Up to £7.8m has been allocated to cover meal uptake above 87 per cent. This is based on previous claims including additional uplift to account for potential high uptake due to the 87 per rate for Year 3. The process for claiming this additional funding will replicate the first and second year of the programme, in that schools will provide boroughs with evidence of meal uptake on a pre-agreed date and then claims for extra funding will be reviewed on a borough-by-borough basis according to uptake of the scheme and verified by the GLA. Any additional payments will follow the final 25 per cent claim in April 2026, and any such funding will be issued via the relevant borough with boroughs responsible for quality-assuring applications.
2.7. Up to £170.8k from the budget has been allocated to support any costs related to any increased meal requirements beyond those for which funding has already been allocated in state-funded primary schools and non-maintained special schools, and address issues related to delivery in schools and/or access requirements, including specific needs related to protected characteristics, such as pupils with special educational needs and disabilities (SEND) and pupils who may have specific dietary requirements in connection with their religion or belief.
2.8. The seven boroughs that include Jewish state funded faith schools will receive a further allocation on top of their substantive UFSM grant funding uplift of £0.85 per kosher meal for KS2 children in Jewish state-funded primary schools. This will be made available alongside their initial allocation and will be funded at an assumed uptake rate of 100 per cent to offer additional funding flexibility to support any wider costs arising for schools when delivering kosher meals.
2.9. The full breakdown of funding allocations to each borough can be found in Appendix B.
2.10. The grant conditions stipulate that the funding must be spent on delivery and implementation of the UFSM scheme, but the GLA will not require detailed evidence of expenditure. As part of the grant conditions, grant recipients will be expected to attend 1-1 meetings with nominated borough leads. These meetings allow for any issues to be raised and worked though. Grant conditions will also require recipients to ensure an approach to universal registration is in place by October 2025. This is to maximise registration of pupils eligible for government FSM. The principles of the grant encourage boroughs to support initiatives to ensure high ethical and quality standards through the scheme, such as adhering to national food standards, paying staff London Living Wage, and considering sustainable catering arrangements.
2.11. Partnership working is vital to the extension of the UFSM scheme for 2025-26. UFSM officers will continue to have regular check ins with the boroughs via the Partnership Advisory Group and one to-one check-ins with each borough.
2.12. A full breakdown of the £140m programme budget is provided below:
3.1. Section 149(1) of the Equality Act 2010 provides that, in the exercise of their functions, public authorities – of which the Mayor is one – must comply with the public sector equality duty by having due regard to the need to:
• eliminate discrimination, harassment, victimisation and any other conduct that is prohibited by or under the Equality Act 2010
• advance equality of opportunity between persons who share a relevant protected characteristic and persons who do not share it
• foster good relations between persons who share a relevant protected characteristic and persons who do not share it.
3.2. To build on the analysis undertaken for previous years of the Mayor of London’s UFSM programme, the IIA and EqIA plus supplementary analysis on independent schools have been kept up to date to ensure that any new considerations that have emerged since the programme launch in September 2023 inform roll-out of the third year of the scheme (see Appendix A).
3.3. MD3332 provides a detailed overview of the EqIA findings.
3.4. Research suggests that children receiving UFSM have improved attendance and are able to concentrate better in the classroom. Children on UFSM make between 4-8 weeks’ more progress in Maths and English than similar pupils in comparison areas. Improvements in attainment were strongest for pupils from less affluent families . Every £1 invested in healthy school meals could deliver £1.71 in increased educational outcomes, better health and longer-term economic benefits .
3.5. The IIA, EqIA and supplementary analysis also identifies and analyses where there are individuals with protected characteristics, who have specific dietary requirements which are associated with higher meal costs. This includes pupils with SEND, and pupils who may have a specific dietary requirement in connection with their religion or belief; and identifies that kosher meals in state funded Jewish schools generally come in at higher costs, and that this is generally related to the higher price of kosher-certified food, including staples such as kosher meat, bread, dairy and eggs.
3.6. It is anticipated that additional costs associated with these specific access needs will continue to be incurred in the third year of the programme. Additional funding will therefore continue to be made available to cover the higher price of providing kosher meals at £3.85 per meal for Jewish state-funded schools, as well as any exceptional costs arising for state-funded special schools to support the higher cost of meals for pupils with SEND where needed. The extent of these additional costs is dependent on local catering contracts and therefore the benefit of this additional offer will vary depending on the price per meal agreed locally. This could depend on a number of factors including the availability of appropriate caterers and the size and scale of contracts.
3.7. The eligibility for the Mayor’s UFSM scheme replicates, and is consistent with, the government’s FSM programme (which covers children within state-funded primary schools who are in KS1 and other children in KS2 where they live in households on universal credit earning less than £7,400 a year). That means that both programmes together cover state-funded primary schools in London, including faith schools, as well as NMSS but not private or independent schools.
3.8. To date, programme monitoring has not identified negative impacts on pupil premium income for state-funded primary schools in London. The GLA will continue to work with partners to monitor any trends in this area.
3.9. Further mitigating actions have been put in place by the GLA, including offering extra funding to all boroughs to support auto-enrolment approaches. An additional condition in the Year 3 grant agreement has been added, asking boroughs to adopt, or otherwise develop, approaches to auto-enrolment or other ways to proactively register eligible children to improve the take-up of FSM. This will help to ensure that income for schools from the pupil premium remains unaffected.
Key risks
4.1. Key risks and issues are highlighted in the table below.
*Red = highly likelihood and/or high impact; amber = medium likelihood and/or impact; green = low likelihood and/or impact.
Conflict of interest
4.2. There are no conflicts of interest to note for any of the officers involved in the drafting or clearance of this decision form.
Links to Mayoral strategies and priorities
4.3. This programme links to the Mayor’s delivery of the Supporting and Investing in Young Londoners mandate which includes the following core objectives:
• children and young Londoners achieve the health and learning outcomes they need to thrive at every stage of development
• children and young Londoners have the positive opportunities needed to be successful
• Londoners have the skills they need to improve their lives.
5.1. This decision seeks approval for the following, totalling £141m, as broken down below:
1. expenditure of up to £132.46m which will be allocated to boroughs to continue to deliver UFSM to KS2 children within London state-funded primary schools as well as NMSS for the 2025-26 academic year
2. expenditure of up to £7.8m to cover meal uptake above 87 per cent
3. expenditure of £170.8k to support any costs related to any increased meal requirements beyond those for which funding has already been allocated in state-funded primary schools and address issues related to delivery in schools and/or access requirements, including specific needs related to protected characteristics, such as pupils with special educational needs and disabilities (SEND) and pupils who may have specific dietary requirements in connection with their religion or belief.
5.2. The table at paragraph 2.12 above provides a full financial breakdown.
5.3. The expenditure of £140.5m will be funded from the UFSM programme budget over 2025-26 and 2026 27 financial years and is subject to the outcome of the normal budget setting process for future financial years.
5.4. The expenditure of £99.4m. in 2025-26 financial year is affordable and confirmed in the 2025-26 approved UFSM budget. The expenditure of £41.2mm from the UFSM programme budget in 2026-27 financial year is agreed in principle and is subject to the outcome of the normal budget setting process for future financial years.
5.5. Any contracts that commit the GLA in future years are subject to appropriate break clauses.
Power to undertake the requested decisions
6.1. Section 30 of the Greater London Authority Act 1999 (GLA Act) provides that the Mayor, acting on behalf of the GLA, has the power to do anything which he considers will further any one or more of the GLA’s principal purposes. Those principal purposes include furthering the promotion of social development in Greater London. Section 34 of the GLA Act also allows the Mayor to do anything which is calculated to facilitate, or is conducive or incidental to, the exercise of any functions of the GLA exercisable by the Mayor. These powers are sufficiently broad to cover the proposed use of the funds in this decision for which approval is sought. In formulating the proposals in respect of which a decision is sought, officers have complied with the GLA’s related statutory duties to:
• pay due regard to the principle that there should be equality of opportunity for all people (section 33(1) of GLA Act)
• exercise the power in section 30 of the GLA Act in the way which it considers is best calculated to promote improvements in the health of persons in Greater London, promote the reduction of health inequalities between persons living in Greater London, contribute towards the achievement of sustainable development in the United Kingdom and contribute towards the mitigation of, or adaptation to, climate change in the United Kingdom (section 30(5) of the GLA Act)
• Consult with such bodies or persons as considered appropriate in this particular case (section 32(1) of the GLA Act).
6.2 In taking the requested decisions, the Executive Director of Communities and Skills (the Director) who is exercising delegated functions on behalf of the Mayor, must comply with the public sector equality duty and therefore the Director should have particular regard to section 3 (above) of this decision form.
Grant funding
6.3 Decisions 1, 2 and 3, above, seek approval of budgets of £132.46m, £7.8m and £170.8k, respectively, which will be allocated to boroughs as funding. The funding will allow the boroughs to continue to deliver UFSM to KS2 children within London state-funded primary schools for the 2025-26 academic year. To that end, the GLA will be funding the provision of UFSM by the boroughs to school children. Accordingly, there is no direct benefit to the GLA and the funding may be viewed as a grant rather than a contract. Officers are reminded to comply with section 12 of the Contracts and Funding Code. Furthermore, prior to the provision of the additional funding, officers must put in place either deeds of variation of existing funding agreements or new funding agreements between the GLA and the recipient boroughs.
Subsidy control
6.4 The Subsidy Control Act 2022 (the SC Act) requires that grant funding be assessed in accordance with a four-limbed test in order to see whether the grant funding amounts to a subsidy within the meaning of the SC Act. As explained in decision 1 above, the grant funding will be provided to local boroughs to provide UFSM. In providing the UFSM, the boroughs will be providing a public service. This also applies to the budgets for funding set out in decisions 2 and 3, above. To that end, the proposed grant funding does not meet the second limb of the four-limbed test and, therefore, does not amount to a subsidy.
7.1. In the majority of cases, the boroughs will be acting as responsible bodies for the GLA’s grant funding and then providing on-grants to the eligible schools in their area. In turn, those schools will then use the on-granted funds to procure catering services. However, in a limited number of cases, some boroughs will use the GLA’s grant funding themselves to procure catering services on behalf of the eligible schools in their area.
Appendix A – UFSM Integrated Impact Assessment: Policy
Appendix B – UFSM Funding Allocations 2025-26 academic year (by borough)
Signed decision document
DD2749 - UFSM Programme Budget 2025-26
Supporting documents
DD2749 - Appendices