September 28, 2026
Two new guides explain the three kinds of documents a school board runs on, and why the difference matters
Summary
School Board Research has published two companion guides on the difference between a school board policy, an administrative procedure and a required plan. One is written for parents and families; the other, for trustees and board staff, sets out the statutory detail. Both are now available under Resources. This note explains why they were written.
- The Ministry of Education relies on the distinction between a policy and a procedure. Its operational reviews of school boards examined how boards maintain both, and in 2025 the Minister directed one board to make sure its policies and procedures are distinguished from its administrative guidelines.
- As at 25 September 2026, School Board Research had not found a Ministry publication written for parents or the public that explains the distinction.
- The training the Ministry required of trustees and directors of education in 2025 left out the modules on roles, policymaking and planning. The training materials do not define a plan, and none of the modules or webinars covers the bullying prevention and intervention plan, the accessibility plan or the special education plan (School Board Research 2026).
- The label on a board document does not reliably show who approved it, whether it can be changed without a public vote, or whether it is the document the law requires the board to keep. The guides give parents and trustees a way to tell by what a document does rather than what it is called.
1. Introduction
Every Ontario district school board governs through three kinds of documents. A policy states what the board requires and why. A procedure states how staff carry that requirement out. A plan commits money, staff and time to measurable results over a set period. The Education Act assigns each of them to a different office: policy to the board, procedure to the director of education, and the multi-year plan to both, with the board holding the duty to have it and the director responsible for its content and implementation (Education Act, ss. 169.1, 283(2), 283.1).
The two new guides set out that division in plain terms:
- Policy, Procedure and Plan: A Plain-Language Guide, under Parent Resources, explains what each document is, who writes and approves it, and how to tell which one you are reading.
- Policy, Procedure and Plan: A Guide for Boards and Trustees, under Trustee & Board Resources, covers the same ground with the governing law, a table of the plans every board is required to keep, three good-practice checklists and a list of common governance risks.
Both sit in the Resources section of the site, which now separates material written for families from material written for trustees and board staff.
2. Why the guides were needed
The Ministry relies on the distinction between a policy and a procedure. Its operational reviews of school boards, such as its 2010 review of the Toronto District School Board, assessed whether trustees and senior administration had appropriate processes for establishing and maintaining both policies and administrative procedures (Ontario Ministry of Education 2010). In 2025, following a governance review of one board, the Minister directed that board to submit a timeline for a review and update of “its policies and procedures, including ensuring that these are distinguished from the board’s current administrative guidelines” (Ontario Ministry of Education 2025).
School Board Research did not find a Ministry publication written for parents or the public that explains the distinction. The clearest definitions are in the sector’s guide for trustees, which states that a policy “articulates what must be done and the rationale for it, but does not deal with how it is to be done,” while a procedure “provides the details of how policies are to be implemented” (OPSBA and OESC 2022, 46). That guide does not give a matching definition of a plan.
The training the province required does not fill the gap. A companion School Board Research review, Trustee Training and the Governance Gap, found that Essential Governance 2025, which the Ministry required trustees and directors of education to complete by 31 August 2025, included six of the program’s 21 modules and left out the modules on roles and responsibilities, strategic planning and policymaking. It also found that no module defines a plan, and that none of the 21 modules or four webinars covers the bullying prevention and intervention plan, the multi-year accessibility plan, the special education plan, or the Ministry memoranda on codes of conduct, bullying and student mental health (OESC 2025; School Board Research 2026).
The guides were written to fill those gaps: one version a family can read in a few minutes, and one that a trustee or board officer can check against the statute. If a Ministry source explaining the distinction to the public exists, School Board Research will cite it.
3. What the guides cover
Both guides rest on the same division of responsibility, summarised in Table 1.
Table 1. Policy, procedure and plan in an Ontario district school board
| Policy | Procedure | Plan | |
|---|---|---|---|
| Answers | What must happen, and why | How, by whom, when, with what record | What result, by when, with what resources |
| Approved by | The trustees, by board resolution | The director of education (some boards also approve selected procedures) | The trustees, by board resolution (with limited exceptions) |
| Carried out by | The director and staff | Staff | The director and staff, reporting to the board |
| Tested by | Is it in effect, and is it effective? | Was it followed? | Were the targets met? |
Source: Education Act, ss. 169.1, 283(2), 283.1; OPSBA and OESC (2022, 46). Adapted from the guide for boards and trustees.
The parent guide uses two plans that matter to almost every family as worked examples: the board’s multi-year plan, which must cover at least three school years and be discussed with parents at the start and end of each school year, and the bullying prevention and intervention plan, which every board must establish and require its schools to implement (Education Act, ss. 169.1, 303.3). It closes with three questions a reader can ask of any document, and a short list of warning signs.
The trustee guide adds the full statutory basis, a table of six board-level plans that a statute, regulation or Ministry memorandum requires, and three checklists of twelve tests each for a good policy, procedure and plan. The checklists describe good practice. They are not compliance tests, and a document can meet a Ministry memorandum while falling short of them.
4. Why the difference matters
The central point of both guides is that a document should be identified by what it does, not by its title. Boards label documents in different ways, and a title does not tell a reader who approved the text or whether it can be relied on.
The difference has practical consequences for families. A policy is adopted by elected trustees in public, and it is the board’s commitment to the community. A procedure is issued by staff. Where the only document on an important subject is a procedure, the rule a parent is relying on may never have been voted on by the trustees, and may be open to change without a public vote. In its ongoing review of board documents, School Board Research has encountered related patterns: a code of conduct published as an administrative procedure, and a bullying prevention and intervention “plan” that is a blank template for each school to complete. The trustee guide lists these and other patterns as governance risks rather than findings about any board.
Plans raise a related problem. The Ministry publishes a model bullying prevention and intervention plan and planning guidance for boards (Ontario Ministry of Education 2026). A model is an aid, not a plan. A board that posts the model’s headings filled with a list of possible programs has published options, not commitments: no targets, owners, dates or route for parents to report.
The line between the board’s decisions and operational matters may also soon carry more weight. The Putting Student Achievement First Act, 2026 allows the Minister to make regulations requiring certain resolutions of English-language district school boards to be confirmed before they take effect, and the Ministry’s proposed regulation would give that role to the director of education, as the board’s chief executive officer (Ontario Regulatory Registry 2026). As at 25 September 2026, the Ontario Regulatory Registry listed the proposal as closed for comments, with no regulation number. If a regulation is made, trustees and the public will need to be clear about which matters are policy and which are administration.
School Board Research’s Board Report Card, covering all 72 boards, is available at schoolboardresearch.ca/board-report-card/.
5. Data, method and limitations
The guides describe Ontario district school boards as at 24 September 2026. The sources quoted in this post were read on 24 and 25 September 2026; the guides record how each of their own sources was read. The guides describe the model set out in the Education Act and the trustee training materials, not the practice of any particular board. Board practice varies, and some boards approve selected procedures or use different names for these documents; French-language boards, for example, use politique and directive administrative. All examples in the guides are invented for illustration. The training modules on policymaking and strategic planning predate the 2023 amendments to the Education Act; where they differ from the Act, the Act governs. The search for a Ministry publication explaining the distinction covered ontario.ca, the Ministry’s policy and program memoranda, its guide for school council members and its school board oversight page; an unpublished or internal source may exist. The patterns described in section 4 come from an ongoing review whose board-by-board results have not yet been published, and no board is named here for that reason. Neither guide is legal advice.
References
Education Act, RSO 1990, c. E.2, ss. 169.1, 218.1, 283, 283.0.3, 283.1, 303.3. e-Laws consolidation period from 22 September 2026. https://www.ontario.ca/laws/statute/90e02
OESC (Ontario Education Services Corporation). 2025. Essential Governance 2025. https://modules.ontarioschooltrustees.org/
Ontario Ministry of Education. 2010. Operational Review Report: Toronto District School Board. April. https://efis.fma.csc.gov.on.ca/faab/SBBSB_Content/1_Operational_Reviews/2_Individual_Board_Reports/63.TorontoDSB_EN.pdf
Ontario Ministry of Education. 2025. “Near North District School Board governance review.” Published 30 October 2025; updated 1 December 2025. https://www.ontario.ca/page/near-north-district-school-board-governance-review
Ontario Ministry of Education. 2026. “Bullying prevention and intervention planning for school boards.” Published 29 June 2022; updated 8 May 2026. https://www.ontario.ca/page/bullying-prevention-and-intervention-planning-resource-school-boards
Ontario Regulatory Registry. 2026. “Proposal for Regulation Under the Education Act to Require Confirmation of School Board Resolutions and Motions in English-Language District School Boards.” Proposal 26-EDU007, posted 7 August. Status at 25 September 2026: closed for comments; regulation number N/A. https://www.regulatoryregistry.gov.on.ca/proposal/54775
OPSBA and OESC. 2022. Good Governance: A Guide for Trustees, School Boards, Directors of Education, and Communities, 2022-2026. https://www.opsba.org/wp-content/uploads/2023/01/EN_Good-Governance-Guide-2022-2026_en_aoda_final.pdf
Putting Student Achievement First Act, 2026, S.O. 2026, c. 4 (Bill 101). https://www.ola.org/en/legislative-business/bills/parliament-44/session-1/bill-101
School Board Research. 2026. “Trustee Training and the Governance Gap.” https://schoolboardresearch.ca/2026/09/25/trustee-training-and-the-governance-gap/
Legal disclaimer. School Board Research is not a law firm, its researchers are not lawyers, and nothing in this article is legal advice. A reader who needs advice about their own situation should consult a lawyer.
School Board Research publishes independent analysis of Ontario school board data and policy. We are not lawyers, and nothing in this publication is legal advice. If you identify an error, please write to info@schoolboardresearch.ca. Corrections are noted on the page where they are made.
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