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Headteachers’ leaders have warned that the new individual support plans being proposed for pupils with special educational needs risk becoming “light EHCPs” and adding to the bureaucracy in the system.

And there are also fears that the scale of change being proposed could be “overwhelming” for an already overstretched teaching profession.

The warnings come in responses to the , which closed yesterday.

The government is proposing the creation of new individual support plans (ISPs) for all pupils with SEND and a new three-tiered approach to support: targeted, targeted plus and specialist levels.

Under the new system, education, health and care plans (EHCPs) would be retained. Only students in the highest tier of support would receive them but all students would have an ISP, which would be maintained by schools.

It will also create new national inclusion standards and expect schools to publish inclusion strategies.

Last week the King’s Speech confirmed that the government plans to introduce SEND reforms in the new parliamentary year through its Education for All Bill.

‘Adding complexity rather than reducing bureaucracy’

In its consultation response, the NAHT school leaders’ union says: “There are concerns that ISPs risk becoming a ‘light EHCP’, adding complexity rather than reducing bureaucracy.

“Past experience of national platforms raise concerns about reliability, permissions and usability - poor system design could undermine implementation.”

The union adds that school leaders have “repeatedly warned against reforms that increase documentation without improving practice”.

The NAHT says: “ISPs must therefore be concise, sharply focused and operational, containing only the information required to support day-to-day provision.

“ISPs should be delivered through nationally standardised, digitised formats, ensuring portability across phases and services. However, standardisation must not override professional judgement or individualisation.”

‘Mainstream for all’ narrative questioned

The union’s response also raises concerns about a “mainstream for all” narrative, which it suggests runs through the government’s reforms.

The government has said it expects mainstream schools to meet the needs of more students with SEND and that it wants an inclusion base in every mainstream secondary school, with equivalent numbers of places being created in primary schools.

The Department for Education has previously questioned the need for the number of special-school places created by the last government.

Addressing this issue in its submission to the consultation, the NAHT says: “A ‘mainstream for all’ narrative risks ideologically driven policy that excludes those whose needs require highly specialist environments - this message needs changing as it is harmful to those children and young people who require this type of provision (and their families), who frequently already feel marginalised.”

The union adds that while inclusion bases have a critical role to play, the NAHT “fundamentally challenges the assumption that inclusion bases can meet the full range of SEND”.

Scale of change could be ‘overwhelming’

The Association of School and College Leaders has raised “serious concerns about the scale of expectation being placed on schools at this time”.

It says that it recognises that the volume of change across the system is “hugely ambitious, but it is also overwhelming”.

The union warns that multiple new frameworks are being introduced in 2026-27, including “enrichment, engagement, ISPs, Year 8 reading, suspensions guidance”, alongside SEND expansion in mainstream without clarity on per-school funding.

In its submission, the ASCL says: “This will increase workload for an already overstretched profession.”

Sendco workload

The NAHT’s submission says that the Sendco role would benefit from a clearer, unified national definition.

And it calls for schools to be sufficiently funded so Sendcos have protected time to influence whole-school practice, particularly where the role is combined with other leadership responsibilities, as it is in smaller settings.

It adds: “Concerns have been raised by school leaders that Sendcos may become the central gatekeepers of information, significantly increasing workload and creating operational bottlenecks.”

In its response, the NEU teaching union has said that across the proposed reforms for targeted plus support, ISPs, inclusion bases, “experts at hand” coordination, new training duties, national inclusion standards and new inclusion strategies, the additional workload will “all land on the same Sendcos, class teachers, teaching assistants and support staff who are already at breaking point”.

It adds: “Without protected, funded time and active national workload management, what is proposed is unsustainable before it has got off the ground.”

Call for SEND funding changes

The NAHT also warns that improved inclusion “can only succeed if core budgets are sufficient, inflation-proofed and protected”.

It says that schools should never be expected to fund national pay awards for staff from existing budgets and that these must always be fully-funded.

The NAHT says that without this guarantee, any additional funding for SEND and inclusion “risks being subsumed by these types of unfunded pressures”.

The union says that the current system, which assumes that mainstream schools pay for the first £6,000 of the cost of provision for pupils with SEND out of a “notional budget”, is flawed.

Its consultation response says this approach “needs to be replaced with a needs-led, fully-funded system that is equitable, based on assessed need. This new approach must be transparent, nationally consistent and leave wider provision in schools uncompromised”.

Need for evidence-based standards

In its response to the consultation, the Confederation of School Trusts “broadly welcomes the development of national inclusion standards”.

However, the sector body for multi-academy trusts adds that the government “must clarify what high-quality universal, targeted and specialist support should look like in practice, while avoiding over-prescriptive or generic statements that do not help leaders make decisions”.

It also says the standards should distinguish clearly between “strong evidence, emerging evidence and approaches that are commonly advocated but not securely evidenced”. The system needs to be explicit about approaches that are ineffective or no longer supported by evidence, otherwise poor practice risks being reproduced under new terminology, the CST adds.

Targeted plus ‘must be genuinely new provision’

Meanwhile, a national charity has raised fears about the targeted plus tier of support being proposed.

In its response to the consultation, Speech and Language UK says the targeted plus layer “must be a genuinely new provision that includes access to specialist, individualised assessment and one-to-one intervention for children who need more than targeted group support but do not yet qualify for an EHCP”.

Jane Harris, the charity’s chief executive, said: “The Education for All Bill must make every classroom communication-supportive, guarantee timely specialist help and recognise that speech, language and communication are not optional extras. They are the foundation of learning, friendship, behaviour and belonging.

“If the bill fails these children, ‘all’ will be just another word doing impossible work.”