# Assessing AI tools before the DfE certification scheme arrives: a free framework for UK schools

Author: John Wright
Published: 2026-11-14
Updated: 2026-11-14
Source: https://schoolleadershiphq.com/articles/ai-application-approval-framework-uk-schools

> The DfE has proposed independent safety certification for EdTech and AI products, but it is likely to be some time before a scheme is running. In the meantime, schools still have to decide which tools are safe to use. Here is the framework I built to help, free for members as a Word document and PDF.

On 10 November 2026 the Department for Education opened a [consultation on independent safety certification for EdTech and AI products](https://www.gov.uk/government/consultations/introducing-an-edtech-and-ai-product-safety-certification-scheme). It is a welcome step. Pupil-facing generative AI, personalised learning tools, filtering products and anything carrying out high-risk processing of children's data would all be in scope.

But the consultation does not close until February 2027, and a working scheme will take longer still. Even then, certification would assess safety, not whether a product actually helps pupils learn, and it would not remove a school's own safeguarding and data protection duties.

Meanwhile, AI is turning up in our schools every week: in platforms we already pay for and in free tools staff discover (or pay for) for themselves. Someone still has to decide whether each one is safe to use, for which pupils and for what purpose. So I built a framework to help our school, if it looks useful for you please feel free to download it for your team.

## What the framework does

The framework separates two questions that often get blurred: is this product safe in itself, and can *our* school use it safely, for *this* purpose, with *these* pupils? A tool might be fine for a supervised Year 10 lesson but not for unrestricted use in Year 4. Another might be ideal for generating teaching resources but quite wrong for analysing identifiable pupil records.

It comes in two parts.

**Part 1 is a short approval checklist.** A staff member proposing a tool completes a screening form covering purpose, users, age range, personal data, type of AI, connections to other systems and use in assessment. That sets a low, medium or high risk tier. Certain features, such as pupils chatting directly with generative AI or the tool handling safeguarding or SEND data, escalate automatically to high. A teacher using AI to make differentiated worksheets with no pupil data should not face the same paperwork as a pupil-facing chatbot, and with this approach they don't.

**Part 2 is an assurance library** of around 130 checks, grouped into modules: safeguarding, data protection, cyber security, teaching and learning, inclusion, intellectual property, contracts, implementation, connected and agentic AI, and academic integrity. Schools complete only the modules their tier requires. Every check shows:

- who it applies to (pupil-facing, staff-facing, personal data, generative or connected AI)
- its basis, so you can see what is a legal duty, what is statutory guidance, what is a DfE expectation and what is simply good practice
- space for evidence and a date, so decisions can be defended and revisited

Critical checks are starred. If one of them is not met, or simply cannot be verified, the product is not approved, and a pilot cannot be used to get round it.

## Using current guidance

The checks draw on the DfE generative AI product safety standards, the filtering and monitoring standards, Keeping children safe in education 2026, the DfE guidance on procuring EdTech, the ICO Children's code and JCQ guidance on AI in assessments.

It is written for any UK school. An annex covers the different emphasis for primary and secondary, and another points schools in Wales, Scotland and Northern Ireland to their own equivalent guidance.

## Let me know what you think...

This is draft version 2. A fellow school leader critiqued the first version, and their challenge about proportionality reshaped it into the tiered approach above. I would welcome the same scrutiny from you, particularly from DSLs, DPOs and colleagues outside England.

The framework is free to download for logged-in members as an editable Word document and a PDF. Use it, adapt it for your setting, and tell me what would make it better. When the DfE scheme does arrive, I will update it so the two work side by side or delete my version if the DFE's approach is demonstrably better.

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