Appoint an interim or seconded qualified teacher as SENCO immediately. There is no statutory deadline to fill the role, and the NPQ SENCO must only be completed within three years of appointment, not before they start. The duty is to keep a designated SENCO in post, not to recruit a fully qualified one overnight, so a school can put a qualified teacher (or the head teacher) into the role from day one and recruit substantively in its own time.
First action: name a designated SENCO now
Your only legal requirement is that the person you designate is a qualified teacher working as a teacher at the school, or the head or acting head (SEND Regulations 2014, reg 49). The SENCO (special educational needs co-ordinator) does not need the NPQ SENCO to begin. That qualification became mandatory on 1 September 2024, but a SENCO appointed on or after that date has three years from the date they are appointed to complete it, and the clock starts at appointment, not before (DfE transition guidance, 2024). So the qualification panic that drives most leaders into a slow recruitment is misplaced: you can lawfully cover the post today.
Second action: secure interim capacity while you recruit
Designating a name keeps you compliant; it does not, on its own, get the work done. Buy in capacity through one of four common cover routes while you run a substantive recruitment:
- Internal interim or secondment. Move an existing qualified teacher (often an assistant SENCO or a senior leader) into the role on a temporary basis, with protected time and clear backfill.
- Fractional SENCO. Engage an experienced SENCO for a set number of days a week. See what a fractional SENCO is.
- Peripatetic SENCO. A travelling SENCO who works across more than one setting, useful for short, defined cover.
- Outsourced or trust-shared SENCO. Commission a SEND service, or share a SEND lead across schools in your multi-academy trust or cluster.
Then: protect the casework, not just the job title
The real exposure during a gap is not the qualification rule; it is the EHCP statutory deadlines and annual reviews that can slip while no one is driving them. The governing board or academy proprietor must keep a designated SENCO in place (Children and Families Act 2014, section 67), and the SEND Code of Practice expects that person to hold the strategic role with the head and governors (SEND Code 2015, paras 6.84 to 6.87). When you appoint cover, hand over three things at once:
- The live EHCP caseload, with every annual review and statutory response date the school is on the hook for.
- Pupils on SEN support and the graduated approach already running for them.
- Any open casework with the local authority, parents, or outside agencies.
Brief the head and chair of governors that cover is in place and lawful, and record who holds the role and how the duties are covered. If you are sharing a SENCO across a trust, an interim arrangement is an accepted way to maintain cover while you recruit.
Where the law comes from
Related
This page is general information, not clinical or legal advice.