Enfield SEND Audit: £8.1m Paid Outside Council Rules

Enfield Council’s own internal auditors have given the way the council buys and pays for SEND support a rating of No assurance, the lowest they issue and the only one handed out anywhere in the council last year.

The finding is in the Internal Audit and Counter Fraud Annual Report 2025-26, written by the council’s Head of Internal Audit, Marion Cameron. It was published on 28 August and goes to the Audit Committee on Tuesday 8 September at 7pm. (Enfield Council, Audit Committee agenda, 8 September 2026)

The audit’s own summary is unusually direct. It says the review “identified significant weaknesses in the SEN Procurement and Payments processes which require immediate action especially as the Council is experiencing overspends in this area”.

What the auditors found

The report records three high-risk findings and three medium-risk ones. The high-risk findings are:

• The SEN service’s approach to buying services does not comply with the council’s Contract Procedure Rules, so the council “cannot demonstrate that the appropriate processes have been followed or that best value for money has been achieved”. Testing found suppliers engaged without tendering, quotations or approved waivers “despite substantial levels of expenditure”.
• £8.1m of SEN spending in 2025-26, or 26% of all SEN third-party payments, went through AP1 payments rather than the council’s standard Neptune purchasing process. AP1s are meant for limited use. Auditors also found repeated AP1 payments to multiple providers, payments recorded against a generic vendor, incomplete purchase order records, retrospective purchase orders and an incomplete manual purchase order log.
• The service could not say how much it owed suppliers. It was “unable to confirm the total number or value of overdue and unpaid invoices, despite known instances of suppliers chasing payment and complaints being escalated to senior finance officers”. Corporate Finance did not have a definite figure either.

Two details stand out inside those findings.

The first is that the council tried to stop the AP1 payments and could not. The Strategic Finance Manager asked in July 2025 that AP1s be used on a limited basis only. Between August 2025 and March 2026, a further £5.5m went through them anyway, which is 67% of the year’s AP1 total.

The second is a safeguarding point. The audit found that “due diligence and safeguarding checks for one supplier were completed only after services had commenced”, which it says increases the risk that vulnerable service users are exposed to providers before the required checks are done.

Why the money matters

The audit’s phrase about overspends is not abstract. Enfield’s high needs budget, the part of the Dedicated Schools Grant that pays for SEND provision, overspent by £4.964m in 2025-26: a budget of £79.599m against an outturn of £84.563m.

That pushed the council’s cumulative DSG deficit from £17.418m at 31 March 2025 to an estimated £20.799m at 31 March 2026. The council’s report to its own Schools Forum blames “SEND placements and costs, with ongoing budget pressures including SEND independent and out of borough placements and increased placement costs”. (Enfield Council, Schools Forum pack, 8 July 2026)

The same report expects the deficit to increase significantly again in 2026-27. A government High Needs Stability Grant is expected to cover 90% of the high needs deficit built up to the end of 2025-26, subject to conditions including DfE approval of a local SEND reform plan. Councils are told to plan to meet whatever is left at the end of 2027-28 from their own money.

The EHCP timescales, in context

The audit also looked at 15 Education, Health and Care Plan assessments. In seven of them, the assessment either was not completed inside the 20-week statutory timescale or did not carry enough information to confirm it had been. In one case the referral receipt date had not been recorded at all.

The auditors are fair about what that means nationally. They note that the national average for completing EHCP referrals within 20 weeks is under 40%, “so in this respect Enfield is operating at above average levels”. Their criticism is about monitoring rather than outcome: compliance with the deadline “is not being routinely monitored to identify delays, understand their causes or implement timely improvements”.

Delays were mostly blamed on partner agencies not supplying information on time. One was down to agreeing the proposed plan with parents.

Separately, in two of 15 statutory annual reviews there was no evidence on file to confirm the outcome, the approval of the review, or that the outcome had been communicated to parents or carers.

The report also records something outside its own scope that helps explain the mess. During the move to the Liquid Logic case management system, “a significant amount of data was not transferred to the new system”. Because SEN supplier payments depend on that data, the service and Corporate Finance “have had to put significant workarounds in place to pay the Council’s liabilities”.

How this sits against the rest of the year

Twenty-five audit assignments were completed in 2025-26 and 19 of them were given an assurance rating. The overall opinion for the council is Reasonable assurance, and most individual audits were rated Reasonable.

SEND was the exception. It was the year’s only No assurance opinion. Seven audits were rated Limited:

Across the whole programme, 305 improvement actions were agreed with managers, including 37 addressing high-risk findings. No critical-risk actions were identified during the year.

The auditors also acknowledge that the SEN service “has been working under resourcing pressures, which has contributed to some of the issues identified”.

What it means for you

If your child has an EHC plan in Enfield, or you are waiting for an assessment, none of this changes your rights. The 20-week statutory timescale still applies, and so does the annual review. What the audit says is that the council is not systematically checking whether it is meeting them.

• The meeting is public and it is next week. Audit Committee, Tuesday 8 September, 7pm, Conference Room, Civic Centre, Silver Street, EN1 3XA. The agenda and the full 71-page report are already online on the council’s democratic services site, and the contact for the meeting is Democracy@enfield.gov.uk.
• If you provide services to the SEN team and you are owed money, the audit is your evidence that the council itself does not have a reliable figure for unpaid invoices. Put the request in writing and keep the reference.
• If your annual review outcome was never confirmed to you, ask for it in writing. The audit found two cases in 15 where there was no record that the outcome had been communicated to parents or carers.
• This is a finance report, not a SEND provision report. It does not assess the quality of any placement or any school. It assesses how the council buys and pays for them.
• The Overview and Scrutiny Committee meets the night before, on Monday 7 September, with the draft Council Plan 2026-30 and the Enfield Growth Plan on its agenda. (agenda)

Council finance decisions eventually reach household bills. Our guide to Enfield council tax bands sets out what each band pays this year.

Sources

• Enfield Council, Audit Committee agenda, Tuesday 8 September 2026, for the meeting date, time, venue and item list.
• Internal Audit and Counter Fraud Annual Report 2025-26 (PDF), report of Marion Cameron, Head of Internal Audit, for the No assurance opinion, the £8.1m and £5.5m AP1 figures, the 26% share, the unpaid invoices finding, the safeguarding check finding, the EHCP and annual review testing, the Liquid Logic data point, the list of No and Limited opinions, and the 305 agreed actions.
• Enfield Council, Schools Forum pack, 8 July 2026 (PDF), for the high needs block budget and outturn, the £4.964m overspend, the £17.418m and £20.799m DSG deficit figures and the High Needs Stability Grant.
• Enfield Council, Overview & Scrutiny Committee agenda, Monday 7 September 2026, for that meeting’s date and items.