Review of school attendance codes: integrated impact assessment

Legislative background

The Welsh Government wants every child to take part in, enjoy learning and have the best education possible to progress and expand their knowledge, skills and experience.

This will support them to become:

• ambitious, capable pupils ready to learn throughout their lives
• enterprising, creative contributors ready to play a full part in life and work
• ethical, informed citizens ready to be citizens of Wales and the world
• healthy, confident individuals ready to lead fulfilling lives as valued members of society

Attendance Codes are used by schools to record attendance information for pupils. They help in tracking attendance data and determining whether a pupil is marked as present or absent. Simply, they are the letters and marks added to an attendance register to indicate the reason why a pupil is absent.

The Welsh Government introduced new school attendance codes in 2010 via The Education (Pupil Registration) (Wales) Regulations (2010). These regulations ensured that pupils were accurately registered and that education settings maintained accurate records of attendance. However, there has been no revision of the attendance codes since this time.

Since the introduction of the current attendance codes in 2010, societal and educational contexts have evolved significantly. In addition, the COVID-19 pandemic resulted in new patterns of absence and highlighted the need for more accurate data so as to develop clearer guidance on remote learning.

Updating the attendance codes will ensure that they:

• remain fit for purpose in a changing educational landscape
• provide local authorities and schools with greater clarity
• will ensure that the Welsh Government’s approach to recording attendance is applied consistently across Wales

Revising the attendance codes will enable a more detailed understanding of the reasons behind pupil absence and support schools and local authorities in implementing targeted strategies to address specific barriers to attendance.

The current proposed changes to the attendance codes have been made in line with the above Regulations and on this basis, no amendment of the Education (Pupil Registration) (Wales) Regulations (2010) is needed. The legislative basis for WG collating data on attendance codes is as identified within the Education Act (1996) (sections 537A and 538).

Practicalities

In order to align attendance codes within a changing educational landscape, revising of the attendance codes is essential at this time. Given the technical nature of the attendance codes, the Welsh Government is asking primarily for responses from partners including maintained and independent schools, Pupil Referral Units (PRUs), Special Schools, local authorities, professional associations and Public Health Wales but all responses will be welcomed and collated. It is intended that this technical consultation will run for six weeks from 3 February 2026 to 17 March 2026.

The aim of the revised attendance codes is to secure an accurate picture of attendance and reasons for absence and to enable schools, local authorities and Welsh Government to have a more detailed understanding of the reasons behind pupil absence and to support any future changes in related policy development.

In short, the draft direction included within the consultation, proposes that the five existing statistical categories be maintained as per below but with variations. More in-depth information can be viewed within the consultation documents.

The proposed changes to the attendance codes do not affect the following, which were requirements of 'The Education (Pupil Registration) (Wales) Regulations (2010)': 

• Schools are still required to put pupils on the Admissions Register on the first day that they expect the pupil to attend from previous agreement or notification and not when they first attend.
• If a pupil does not return to school following a leave of absence, the school and the local authority are still required to ascertain where that pupil is. If both the school and the local authority fail after reasonable enquiry to ascertain where the pupil is and the failure to return to school exceeds 10 days, the school may delete the pupil’s name from the Admissions Register.
• A school is still able to delete a pupil’s name from the Admissions Register on the grounds that:
  • the pupil has an unauthorised absence of at least 20 school days, that the school has no reason to believe that the pupil cannot attend due to sickness or other unavoidable cause and both the school and the local authority have failed, after reasonable enquiry, to ascertain where the pupil is
  • if a pupil has been detained under a court order of custody lasting at least 4 months and the school does not have reasonable grounds to believe that the pupil will return at the end of that period, the school can delete the name of the pupil from the register

Subject to the outcome of the 6-week consultation, which will engage wider audiences, including:

• individual schools
• local authorities
• professional associations
• the Children’s Commissioner for Wales
• Public Health Wales

the Welsh Government will be able to support a smooth transition for schools, local authorities and partners in capturing relevant data to enable to better address reasons behind pupil non-attendance. This timescale will minimise disruption and ensure readiness for the 2026 to 2027 academic year.

Long term

The legislation on attendance codes was introduced with the intention of simplifying pupil absence and attendance within education settings but given the changing educational landscape the revisions will provide local authorities and schools with greater clarity and ensure the Welsh Government’s approach to recording attendance is applied consistently across Wales.

However, we continue to listen to feedback through consultations such as this one, to ensure the policy still meets the needs of the professionals, organisations, individuals, and children and young people potentially affected by it.

Prevention

We believe that having uniform attendance codes across all local authorities assists schools to monitor attendance more specifically. This in turn, will enable schools to deal with lack of pupil attendance more comprehensively.

Integration

There is already a duty on teachers and schools to take a register. This will not add to existing duties outlined in The Education (Pupil Registration) (Wales) Regulations (2010), as this is not a new process but an amendment to an existing process. The education workforce will need to become familiar with the new attendance codes, their meaning and how they should be used and the Welsh Government will provide updated guidance which will support longer term benefits of improved clarity consistency and data quality.

Welsh Language

There is no direct impact on the Welsh language and culture, in updating the attendance codes. Furthermore, there is no direct impact on the global responsibility of Wales.

Collaboration and involvement

The Welsh Government co-constructed the revised attendance codes with a small cohort of local authority officers through in-person workshops and further online revisions. The validity of the proposed revised attendance codes was also tested using local authority examples of existing cases where schools have asked for clarification in relation to what attendance codes to use.

Furthermore, in developing the draft revised attendance codes, Welsh Government officials have worked collaboratively with local authorities to ensure that the revised attendance codes reflect technological developments and evolving delivery models.

Impact

We believe that what matters is the impact on pupils, education settings and third-party partners. This is the reasoning behind the original legislation and this consultation.

We recognise that updating attendance codes may feel like an insignificant issue to many people but it can significantly inform policy development and school-based interventions and thus improve pupil attendance. Whilst the proposal does not pretend to fix all of the potential issues, it seeks to make things as simple as possible for those affected.

The consultation gives a meaningful opportunity to hear from interested parties about the interpretation of the attendance codes and any further impacts that may have not been identified through this process.

Costs and savings

We do not anticipate any additional costs to the Welsh Government which are not already funded through normal staffing budgets. Furthermore, there are no additional financial implications associated with: 

• the preparation of the consultation
• the stakeholder engagement or 
• the post consultation activity 

associated with updating and publishing the guidance. These activities will be undertaken by officials from the Welsh Government, as part of their existing roles.

The implementation costs for updating the revised attendance codes on the schools’ DEWI system would be minimal and would fall solely to the Welsh Government, as these would be covered under already existing development processes and therefore would not add any additional significant costs.

Any changes made to schools’ MIS software solutions to enable the recording and storing of the new attendance codes at school, may cause a variation of the software licensing costs for customers but is expected to be very minimal due to the small amount of development work needed to modify the attendance codes in relation to the overall software costs. The contracts between the service provider and the customer are reviewed regularly and customers are free to change supplier(s) using their own discretion as long as they are able to meet their statutory obligation. Therefore, the decision lays with the schools and (or) local authorities to exercise their own consideration in terms of the value for money they are getting from their contracted supplier on an ongoing basis.

There may be a minimal cost in appointing an external analysis company to undertake the review of the consultation responses and prepare the summary report, which is yet to be decided.

Mechanism

Whilst this is beyond the term of this administration, we require agreement of the existing administration, so that we can ensure software suppliers and local authorities take forward the necessary work to implement the new attendance codes in a timely manner. If we wait until a new administration is in place to seek this agreement, we would not be able to achieve the September 2026 deadline, resulting in a 12-month delay to the changes. However, we would seek the agreement of the relevant Minister prior to the final decision on adoption of the new attendance codes.

We have considered all the likely impacts on different groups and on social, economic and cultural well-being whilst making these changes. Having done so, we are confident that the positive impacts of updating the attendance codes outweigh any reasons for not revising the attendance codes. We believe that all stakeholders within the educational environment, will benefit from it.