DD2821 Additional funding for year three of the Universal Free School Meals programme

1.1.    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 (FSM). The Mayor introduced the Universal Free School Meal (UFSM) scheme in September 2023, and has confirmed his intention to fund it until the end of his Mayoral term.

1.2.    On 6 March 2025, via Mayoral Decision (MD) 3332, the Mayor approved expenditure of up to £147.5 million in funding to local authorities to deliver the UFSM scheme during the 2025-26 academic year. This included up to £2.2 million to fund an uplift for the additional costs of Kosher meals, and where exceptional costs arise for children with special educational needs and disabilities (SEND), as well as programme costs. This allowed ongoing delivery of UFSM to Key Stage (KS) 2 children in London state-funded primary schools for the 2025-26 academic year; and ongoing financial help for families.

1.3.    As per MD3332, the £147.5 million budget allocation for UFSM in the 2025-26 academic year is based on uptake of 87 per cent. 

1.4.    Extra payments are allowed for boroughs that can show uptake above 87 per cent (addressed in the 2025-26 budget-setting process, and outlined in paragraphs 2.5-2.8 of MD3332).This extra funding will be delivered through their respective boroughs. It will be reviewed on a borough-by-borough basis (according to uptake of the scheme) and verified by the GLA.

1.5.    State-funded schools can also receive extra funding if they show exceptional costs arising for children with SEND; and/or costs associated with additional pupils. 

1.6.    Appendix A – Table 1 lists the boroughs with uptake higher than 87 per cent.

1.7.    Appendix A – Table 2 lists the boroughs requiring extra funding arising from exceptional costs for children with SEND (special schools).

1.8.    Appendix A – Table 3 lists the boroughs requiring extra funding for additional pupils.

1.9.    Additional expenditure of £1,788,573.86 will be provided to boroughs set out in Appendix A, Tables 1 to 3. This funding covers the shortfall between boroughs' existing allocations and their actual costs, arising from uptake above 87 per cent, exceptional costs for children with SEND, and additional pupils. The purpose is to ensure schools have the right amount of funding to provide universal free school meals to all eligible primary pupils.

1.10.    Delegated authority to the Executive Director of Communities and Skills (the Director) to make programme-level decisions, via a Director Decision form, and in consultation with the Deputy Chief of Staff and the Deputy Mayor for Children and Families. Following consultation, all parties support the provision of additional funding. 
 

2.1.    The programme objectives and expected outcomes are set out in MD3332. 

2.2.    The additional funding aims to: 

•    mitigate the impact of the cost-of-living crisis by: 

o    saving London’s families up to £1,000 per child over the three years of the scheme
o    ensuring primary school children in state-funded schools (including all-through schools, academies, state-funded special schools, AP and NMSS) do not go without at least one nutritious meal a day during term time

•    show the Mayor’s role in, and commitment to, addressing the impact of the cost of living on families (including via other sources of support). 
 

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.    The Mayor recognises that cost-of-living pressures are having an impact on many communities in London. He is committed to supporting families who are struggling financially in London through this difficult time.

3.3.    The Equality Impact Assessment (EqIA) for the UFSM programme was initially produced in July 2023. It was updated in 2024 to reflect the scheme’s extension, and findings from the independent evaluation by Impact on Urban Health. A refreshed EqIA was published in June 2026; this identifies areas for further work or consideration, including mitigation and future monitoring. Recommendations include continuing to address special dietary needs for faith groups (including Kosher food) and needs for pupils with SEND. The EqIA from June 2026 was attached to MD3509.
 

Key risks and issues 

4.1.    As a mitigation, we need to ensure there are no delays in approving the additional funding. Once it is approved, we can proceed with year-four UFSM payments as planned. This ensures there is no impact on payment timelines or boroughs’ ability to submit claims.

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 work is part of the Supporting and Inspiring Young London programme, 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.

4.4.    This programme chiefly seeks to reduce the impact of the cost-of-living pressures on low-income families. 

5.1.    Approval is sought to spend up to £1,788,573.86, to increase existing grant funding for UFSM to certain London boroughs. These boroughs will pass the funding on to state-funded primary schools and NMSS whose UFSM uptake is above 87 per cent for the 2025-26 academic year. The spend includes extra funding for special schools and additional pupils.

5.2.    MD3332 approved spending up to £147.5 million to continue delivering UFSM to KS2 children, at London state-funded primary schools, for the 2025-26 academic year. This budget allocation is based on uptake of 87 per cent pupil; extra payments are allowed for boroughs with uptake above this. 

5.3.    The proposed spending will be funded by GLA resources (as agreed in the 2026-27 budget) and will come from the UFSM programme budget.
 

Power to undertake the requested decisions

6.1.    The decision requested of the Director falls within the general powers of the Mayor, acting on behalf of the GLA, in section 30 of the Greater London Authority Act 1999 (GLA Act) to do anything that it 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 that 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 it considers is best calculated to: 

o    promote improvements in the health of persons in Greater London
o    promote the reduction of health inequalities between persons living in Greater London
o    contribute towards the achievement of sustainable development in the UK
o    contribute towards the mitigation of, or adaptation to, climate change in the UK (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 Director – who is exercising delegated functions on behalf of the Mayor – must comply with the public sector equality duty. Therefore, the Director should have particular regard to section 3 (above) of this decision form. 

Grant funding

6.3    This decision seeks approval of a budget of up to £1,788,573.86 to increase grant funding to state-funded primary schools, in boroughs with UFSM uptake above 87 per cent, for the 2025-26 academic year. This includes extra funding for special schools and additional pupils. To that end, the GLA will be funding boroughs’ extra grant funding for state-funded primary schools, to provide FSM to KS2 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 GLA’s Contracts and Funding Code. Furthermore, before the additional funding is provided, 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 is assessed in accordance with a four-limbed test, to see whether the grant funding amounts to a subsidy within the meaning of the SC Act. As explained above, the grant funding will be provided to boroughs, so they can in turn provide funding to primary schools for FSM. In doing so, the boroughs will be providing a public service. To that end, the proposed grant funding does not meet the first limb of the four-limbed test; and therefore does not amount to a subsidy.
 

7.1.    Schools and boroughs claiming funding for uptake over 90 per cent can follow the process detailed on london.gov.uk’s information page. A copy of the guidance has been issued to borough officers.

Timeline of activity

7.2.    Next steps are as follows: