What you have to record
Schools must record each pupil's SEN decision, the extra or different support given and every progress review - on an SEN record and provision map - and, as of 2026, keep the SEN file for 31 years from the pupil's date of birth, longer than the 25-year general pupil record. The SEND Code of Practice does not set a fixed template for an "SEN file"; it sets out what the record has to show. Once a school decides a pupil has special educational needs, that decision must go in the school's records and parents must be formally told (para 6.43). For every pupil on SEN support, you then record the provision and how it is working through the assess, plan, do, review cycle (paras 6.72 to 6.73).
- The SEN decision: that the pupil has been identified as having SEN, with the date, on the SEN record or register.
- The additional or different provision: what you are doing beyond ordinary teaching, usually shown on a provision map.
- Needs, outcomes, progress and reviews: the notes from each assess, plan, do, review round, including the meetings with parents at least three times a year (para 6.65).
How long you keep it, and under what law
This is the point top results blur. What you create is governed by the SEND Code; how long you keep it is governed by data-protection law, not the Code. The standard education-sector schedule from the IRMS toolkit keeps the general pupil record for 25 years from the pupil's date of birth. The SEN file is treated differently: the toolkit gives SEN records, EHC plans and other support-service records a longer period - 31 years from date of birth (some councils advise up to 35) - precisely so the school can still defend a claim that it failed to provide a sufficient education, which an adult can bring years after leaving. Destroy the SEN file on the 25-year clock and you may bin the exact evidence you would need. Because these are personal data, the UK GDPR storage-limitation rule still applies: keep the records accurate, held securely, available to parents on a subject access request, and no longer than you need them.
Separately, every school must publish an SEN information report on its website and keep it up to date (para 6.79; Regulation 51 of the SEND Regulations 2014). That is a published document, not a pupil-level record, and its content is set by regulation.
One change on the horizon
Reform is coming, but not yet. The Schools White Paper Every child achieving and thriving (February 2026) and the Education for All Bill propose a statutory Individual Support Plan for every child with SEND, which would reshape what schools record. No changes take effect before September 2030, and current EHC plan holders are protected to their next phase or to age 16. So for a 2026 audit your duties are unchanged: record under the Code, retain under UK GDPR.
Where the law comes from
Related
This page is general information, not clinical or legal advice.