The government must go further and adopt a national system of auto-enrolment for families eligible for Free School Meals, as new EPI research unveils a postcode lottery

A new report by the Education Policy Institute (EPI), funded by The Nuffield Foundation, shows significant variation in how free school meals (FSM) and free early years meals (FEYM) are accessed across schools and local authorities in England. This means there are differences in who is identified as ‘disadvantaged' and therefore who accesses free school meals and other associated benefits to which they are entitled.

The report calls on the government to eliminate these inequalities by introducing a national auto-enrolment scheme, meaning that all eligible families would automatically be registered by the government for FSM (unless they opt out). This would build on last week's positive announcement that the government will expand entitlement to FSM for all children in households on Universal Credit: boosting support to those in genuine need.

Today's report finds that:

• Where a child lives or goes to school determines how easy or hard it is to register for FSM - Depending on which school and local authority (LA) a child is in, different requirements are put on parents to register. For example, in some LAs parents are required to make their own application while facing significant barriers (described below) and if found ineligible at the time must reapply when circumstances change; other LAs collect information for all parents and periodically check eligibility for those not already registered so they can be signed up as soon as they become entitled. These differences in registration practices are important because they are likely to lead to inequalities in accessing FSM.

• Children under 5 are missing out - Some nursery children do not have access to the free meals to which they are entitled. Children who meet the FSM eligibility criteria and attend maintained nursery settings before and after lunch are entitled to free meals. However, some LAs interpreted this policy as optional rather than a statutory obligation and some were not aware of the policy at all. Furthermore, this entitlement only covers children in maintained nurseries, not those with childminders or in private, voluntary or independent settings, which is where the majority of children attend.

• Similarly, vulnerable families, including those for whom English is an additional language and those with ‘No Recourse to Public Funds', for example, asylum seeking families, face multiple barriers in registering for FSM - Despite increased efforts to maximise registration, issues around language barriers, knowledge and understanding, and digital access are preventing the FSM benefits reaching children that need them. LAs have described how stigma also continues to prevent families from applying for the FSM to which they are entitled.

• The most inclusive approach is in LAs that are using local auto-enrolment to proactively identify entitled children without relying on parents sharing details or making an application. Where local auto-enrolment has been implemented by the LA, some have discovered large numbers of previously unregistered children.

 
The government must use the opportunity of the Children's Wellbeing & Schools Bill to create new legislation that enables an auto-enrolment system for families, including for FEYM, ensuring they have access to the support they are entitled to. The report recommends:

• Introducing a national system of auto-enrolment - This would address many of the barriers to FSM and FEYM registration and reduce the inequalities in access to free meals and additional benefits. A national auto-enrolment system would significantly reduce the time and resources required by local authorities and schools to promote FSMs and maximise registration.

• Clarifying the free early years meals policy and supporting nurseries to provide it for all children who meet FSM eligibility criteria - There needs to be clarity for LAs that this is an obligation rather than optional, and the government should provide funding for settings to provide the meals. Otherwise, the associated increase in children eligible for FEYM will add more financial pressure to the already challenging situation pre-school settings are operating within.

 
Dr Kerris Cooper, Senior Researcher, Early Years and Inequalities at EPI said:

“ Our research shows that while the extension of free school meal eligibility is a very positive step, more needs to be done to ensure that all children entitled to free meals can actually access them.

First, there are still significant barriers for families to register for FSM, and where a child lives plays too big a role in their chances of being registered. Second, the youngest children, who face the highest risk of poverty, will not benefit from this expansion in eligibility unless all children attending early education are also included and settings are supported to deliver this.

Introducing national auto-enrolment and including children in early education would enable this expansion in FSM eligibility to more meaningfully extend access to more children in poverty.”


Ruth Maisey, Education Programme Head, Nuffield Foundation said:

"This timely report highlights that simply extending free school meals isn't enough to guarantee families receive what they're entitled to. Centralised auto-enrolment is key to ensuring every eligible child benefits."


Background
This research explores how and why FSM and FEYM registration practices vary across time and place. This is important because registration processes can have an impact on levels of FSM and FEYM registration and therefore who is identified as ‘disadvantaged' and gains access to free meals and associated benefits. This research is part of a wider project which explores FSM as a measure of disadvantage.

At the time of this research FSM registration practices have been particularly topical. The Education Committee has recommended that FSM auto-enrolment is introduced as part of the Children's Wellbeing and Schools Bill. Transitional protection for FSM was planned to come to an end in March 2025 meaning new applicants to FSM would no longer remain eligible until the end of their phase of education if they did not continue to meet the eligibility criteria. However, as this report was being prepared for publication, in June 2025, the Department for Education announced that protections would now continue until summer 2026, and that from September 2026, all children in families claiming Universal Credit will be entitled to FSM.  The Eligibility Checking System is also being updated and a new child poverty strategy is due to be published.

The findings in this report are based on surveys and interviews with local authorities (LAs) and multi-academy trusts (MATs), as well as a freedom of information request to the Department for Education's FSM Eligibility Checking System. The empirical work took place in 2024 and early 2025, before the government's decision to extend FSM eligibility and transitional protections. Whilst the extension of FSM eligibility is welcome and in-line with these findings, the research reveals there is much more to be done to ensure that children who are entitled to FSM and FEYM can actually access them, including the youngest children who are at greatest risk of poverty.