For Trustees & Boards
Policy, Procedure and Plan: A Guide for Boards and Trustees
Looking for the short version? The plain-language guide for parents explains the same ideas without the statute detail.
Scope. This guide describes Ontario district school boards as at 24 September 2026. French-language boards use different names for these instruments (for example, politique and directive administrative), but the roles are the same. Board practice varies; the guide describes the model set out in the Education Act and the trustee training materials, not the practice of any particular board. Examples are invented. General information, not legal advice.
The three instruments at a glance
A policy states what the board requires and why; a procedure states how staff carry it out; a plan commits resources to measurable results over a set period. The law assigns responsibility for each, and responsibility is not the same as authorship: staff draft most policies and plans, but the board answers for them.
| Policy | Procedure | Plan | |
|---|---|---|---|
| Answers | What must happen, and why | How, by whom, when, with what record | What result, by when, with what resources |
| Responsible in law | The board (s. 169.1(1)(d)) | The director, within board policy (s. 283(2)) | The board holds the duty to have the plan; the director must ensure its content and implement it (multi-year plan: ss. 169.1(1)(f), 283.1(1)(b) to (d)) |
| Usually drafted by | Senior staff, often through a board committee, often after consultation, which Module 7 recommends | Staff | The director and senior staff, after the consultation the governing law requires |
| Approved by | Board resolution | The director (some boards also approve selected procedures) | Board resolution (energy plan: senior management, O. Reg. 25/23) |
| Carried out by | The director and staff | Staff | The director and staff, reporting to the board |
| Horizon | Standing, until reviewed | Standing, revised as practice changes | Fixed term or review cycle set by the governing law |
| Tested by | Is it in effect, and is it effective? | Was it followed? | Were the targets met? |
The rule that resolves most confusion: identify each document by what it does, not by what it is called.
Why this guide exists
The Ministry of Education relies on the difference between a policy and a procedure. Its operational reviews of boards, which began in 2008, assessed whether “The board of trustees and senior administration have appropriate processes for the establishment and regular maintenance of policies and administrative procedures for the efficient and effective operation of the board” (see, for example, reference 14). In 2025 the Minister’s directions to one board, following a governance review, required it to review “its policies and procedures, including ensuring that these are distinguished from the board’s current administrative guidelines” (reference 13). As at 24 September 2026, we could not find a Ministry publication that explains the difference to parents or the public. The trustee training materials explain it for trustees (Good Governance guide, p. 46; Module 7), but Module 7 was not among the six modules of Essential Governance 2025, the program the Ministry required trustees and directors of education to complete by 31 August 2025 (reference 18). If we have missed a Ministry source, please tell us and we will cite it.
Policy
A policy is the board’s rule: a principle or requirement, adopted by resolution of the elected trustees, stating what must be achieved or must not be done, and why.
What it does. It sets direction and limits. It tells the director, staff and public what the board requires. The sector’s own definition: a policy “articulates what must be done and the rationale for it, but does not deal with how it is to be done” (Good Governance guide, p. 46).
Who is responsible, and who writes it. The board is responsible. The Act requires every board to “develop and maintain policies” and to “monitor and evaluate the effectiveness” of them (s. 169.1(1)(d), (e)). In practice, senior staff usually prepare the draft, often through a board committee and often after consultation, which Module 7 recommends, and the board decides. Because it is adopted in public by elected members, a policy is the board’s commitment to the community and the document a parent is entitled to rely on.
What it is not.
- Not a list of staff steps. Steps belong in a procedure.
- Not a restatement of the statute. Module 7: there is “no need to develop policies to restate mandated actions.” The policy adds the board’s own commitments.
- Not a promise to act later. “The board will develop a strategy” acknowledges an obligation; it does not discharge it.
- Not a staff document. A rule the board has not adopted is not board policy, whatever it is called.
Illustrative example, not taken from any board. “Every student has the right to learn in a school free from bullying. The board requires every report of bullying to be investigated, and the parents of the students involved to be told the outcome. The director shall issue procedures to implement this policy and report annually to the board on its effectiveness.”
Procedure
A procedure is the director’s instrument for carrying out a board policy: who acts, in what order, within what time, who is told, and what is recorded.
What it does. It turns the policy into repeatable practice. Module 7 describes administrative procedures as “specific, detailed and focused.” Boards also call them administrative procedures, operating procedures, regulations or protocols.
Who is responsible, and who writes it. The director of education is responsible, and staff write it. The Act directs the chief executive officer, “within policies established by the board,” to develop “the programs required to implement such policies” (s. 283(2)). Module 7: “Procedures are the responsibility of directors and staff, not trustees.” In the model Module 7 describes, procedures are made available to the board rather than approved by it; some boards also approve selected procedures.
What it is not.
- Not a source of new rules. A procedure may add detail; it should not add a requirement, right or limit the board has not adopted.
- Not a substitute for a policy. Where the only document on a subject is a procedure, the board has not made its own policy on it, unless it adopted that procedure.
- Not a substitute for a plan. A procedure that says the board “will establish” a plan leaves a reader unable to tell whether the plan exists.
- Not free-standing. A procedure with no parent policy has no board direction behind it.
- Not a way around discretion. Where the statute gives a principal or official a discretion, the procedure structures it; it should not remove it.
Illustrative example, not taken from any board. “On receiving a bullying report, the principal shall: (1) open a file the same school day; (2) interview the students involved within two school days; (3) notify the parents of each student within three school days; (4) record the outcome on the board’s form and retain it for three years. A parent who is not satisfied may ask the superintendent to review the matter.”
Plan
A plan is a time-bound commitment of priorities, measures and resources to results, with a way of reporting whether they were achieved. A board does not have one plan. It is required to keep several, each under its own authority, with its own content, consultation, publication and review rules. The multi-year plan sits above the others: Module 6 calls the strategic plan “the master of other plans.”
Who is responsible, and who writes it. Three roles need to be kept apart:
| Role | Who | Authority (multi-year plan) |
|---|---|---|
| Holds the duty to have the plan, and approves it | The board, as a corporate body | s. 169.1(1)(f) (“Every board shall … develop a multi-year plan”) |
| Ensures its content, drafts it, implements and monitors it, and reports on it | The director of education, with senior staff | s. 283.1(1)(b) to (d) |
| Consults and engages the community | Each trustee individually (consultation); the board as a body (publication, reporting and parent meetings) | s. 218.1(c); s. 169.1(4) |
The community duty has two layers, and they are different in kind. Section 218.1 sets out the duties of each member of a board, and clause (c) requires every trustee, as an individual, to “consult with parents, students and supporters of the board on the board’s multi-year plan.” Separately, s. 169.1(4) places organizational duties on the board: to publish the plan, bring it to the attention of parents, supporters and employees, report on progress, and meet with parents twice a year. A board that posts its plan for comment has met part of its own duty; posting does not, by itself, discharge each trustee’s individual duty to consult. For the bullying prevention and intervention plan, by contrast, the statute places the consultation duty on the board (s. 303.3(3), (6)).
Worked example 1: the multi-year plan (Education Act ss. 169.1, 169.2)
| Element | Requirement | Authority |
|---|---|---|
| Duty | Every board shall “develop a multi-year plan aimed at achieving the goals referred to in clauses (a) to (c)”: student achievement and well-being, a positive and inclusive school climate, bullying prevention, stewardship of resources, effective programs | s. 169.1(1)(f) |
| Term | “a plan for three or more school years” | s. 169.1(2) |
| Content | Measures allocating resources to outcomes below the level set by regulation; the director must ensure it “establishes the board’s priorities and identifies specific measures and resources” | s. 169.1(3); s. 283.1(1)(b) |
| Alignment | Developed consistently with the Minister’s policies and guidelines, “with the aim of achieving goals related to the provincial priorities in education in the area of student achievement” | s. 169.2 |
| Consultation | Each trustee consults parents, students and supporters | s. 218.1(c) |
| Publication | Published on the board website “in the form required by the Minister”; brought to the attention of parents, supporters and employees | s. 169.1(4)(a), (b) |
| Reporting to parents | Meetings within the first two and last two months of each school year, with information on “planned and actual spending” | s. 169.1(4)(c), (4.1) |
| Review | Annually, by the board with the director | s. 169.1(1)(g); s. 283.1(1)(a) |
Sections 169.1(4), (4.1) and 169.2 came into force on 8 June 2023.
Worked example 2: the bullying prevention and intervention plan (Education Act ss. 303.2, 303.3; PPM 144)
| Element | Requirement | Authority |
|---|---|---|
| Duty | “Every board shall establish a bullying prevention and intervention plan for the schools of the board and require its schools to implement the plan” | s. 303.3(1) |
| Content | “shall address any matter specified in the policies or guidelines made under clause 301 (7.1) (i)”; PPM 144 describes a plan “that integrates all the board’s requirements and guidelines regarding bullying prevention and intervention into a comprehensive and achievable plan” | s. 303.3(2); PPM 144 |
| Consultation | The board “shall solicit the views of the pupils, teachers and staff of the board, the volunteers working in the schools, the parents and guardians of the pupils, school councils and the public” | s. 303.3(3) |
| Publication | Posted on the board website; each principal makes the board’s plan available, on the school website where there is one | s. 303.3(4), (5) |
| Review | “A board shall periodically review its bullying prevention and intervention plan and shall solicit the views of those listed in subsection (3)”; PPM 144 gives, as an example, at least once every two years | s. 303.3(6); PPM 144 |
| Relationship to policy | Separate from the board’s bullying prevention and intervention policies and guidelines. The policy states the rules; the plan integrates them into what every school will do | s. 302(3.4) |
Both provisions have been in force since 1 September 2012.
These two plans show the pattern that applies to every required plan: a named duty, required content, a consultation rule, a publication rule and a review cycle. A document that meets none of these is unlikely to be the plan the law requires, whatever it is called.
What a plan is not.
- Not a vision statement. Mission and values belong in a plan, but without targets, dates, resources and reporting the document is a policy statement under the wrong title.
- Not a menu. A list of possible programs and activities, with no commitments, owners, indicators or dates, describes options rather than a plan.
- Not a procedure. A list of steps with no outcomes or targets is not a plan.
- Not a set of school plans alone. Where the law requires a board plan, school plans written without a published board plan are unlikely to meet the duty the law places on the board.
Illustrative example of a plan goal, not taken from any board. “Priority 2: safe and accepting schools. Goal: by June 2029, reduce the share of students reporting they were bullied from 28 per cent to 18 per cent (school climate survey). Measures: two added student support workers per region; annual staff training. Resources: $600,000 a year. Lead: Superintendent, Student Well-Being. Reporting: to the board each November; to parents each October and June.”
The required board plans
The table lists the board-level plans that a statute, regulation or Ministry memorandum requires of every Ontario district school board, as at 24 September 2026. Ministry memoranda (PPMs) are directions the Minister issues under the Education Act; they are not regulations. Individual student plans (for example, Individual Education Plans and plans of care) are outside this table because they are made for a pupil, not by the board.
| Plan | Authority | Core duty | Cycle | Publication |
|---|---|---|---|---|
| Multi-year plan | Education Act ss. 169.1(1)(f), (2) to (4.1), 169.2 | Plan for student achievement, well-being, climate, bullying prevention, stewardship and programs, aimed at the provincial priorities | Three or more school years; reviewed annually with the director | Website, in the Minister’s form; parent meetings at start and end of each school year |
| Bullying prevention and intervention plan | Education Act s. 303.3; PPM 144 | Plan for the board’s schools, which every school must implement | Periodic review, with the same consultation (s. 303.3(6)); PPM 144 example: at least once every two years | Board website; each school, through the principal |
| Multi-year accessibility plan | O. Reg. 191/11, s. 4 (Integrated Accessibility Standards) | “establish, implement, maintain and document a multi-year accessibility plan, which outlines the organization’s strategy to prevent and remove barriers” | Reviewed and updated at least once every five years; annual status report | Website; accessible format on request |
| Special education plan | R.R.O. 1990, Reg. 306, s. 2 | Maintain the plan and amend it “to meet the current needs of the exceptional pupils of the board” | Reviewed by the board annually, before July 31; amendments submitted to the Minister | Set by Ministry standards (not covered here) |
| Mental health and addictions strategy and action plan | PPM 169 (issued 17 June 2024, effective 1 September 2024) | “develop and implement a three-year mental health and addictions strategy and one-year action plan” | Three-year strategy; one-year action plan | Website by June 30 of the prior school year |
| Energy conservation and demand management plan | O. Reg. 25/23 (Electricity Act, 1998), ss. 2, 3 | Every school board, as a public agency, “shall prepare an energy conservation and demand management plan” | Set by the regulation (not covered here) | Website and printed copy at head office, after approval by senior management |
Ministry models and templates
The province supplies models for some of these plans. They are aids, not plans. For bullying, the Act requires the Minister to “develop a model bullying prevention and intervention plan to assist boards in establishing bullying prevention and intervention plans” and to make it available to every board (s. 303.2(1), (2)). The Ministry of Education’s current web resource, Bullying prevention and intervention planning for school boards (published 29 June 2022, updated 8 May 2026), describes itself as providing “a model plan” and guidelines. It sets out the components a plan must include (education, awareness and outreach; assessment, monitoring and evaluation; policies and procedures; prevention; intervention and support), with lists of things a board should consider under each, and it points boards to Student Achievement Plan indicators. It does not set targets, timelines or a parent reporting route; those are the board’s to write. Separately, the Ministry for Seniors and Accessibility publishes a sample multi-year accessibility plan template.
The risk is that a model is posted in place of a plan. A board that copies the model’s headings and fills them with lists of possible programs has a menu, not a plan: it states no requirements schools must meet, no owners, no dates, no indicators and no route for parents. The test is the one in the worked examples: does the document carry the board’s own requirements, content, consultation record, publication and review date?
Three notes on the table. First, the accessibility plan quotations are taken from the e-Laws consolidation of the regulation current to 29 July 2026; the other quotations were read on e-Laws or ontario.ca on 24 September 2026. Second, the energy plan is approved by senior management under the regulation, not necessarily by the board; it is included because the duty falls on the board as an organization. Third, other Ministry frameworks may call for further plans (for example, the Student Achievement Plan framework the Ministry’s bullying resource refers to, or plans in Indigenous or French-language education); they are not listed because their authority was not confirmed for this guide.
How the three connect, and how to classify a document
The instruments form a chain, and every link should be traceable: each procedure names the policy it implements; each policy names the law it rests on and delegates implementation to the director; each subject plan and school plan names the multi-year priority it serves.
| Layer | Points up to | Points down to |
|---|---|---|
| Statute, regulation, Ministry memorandum | Board policies; required plans | |
| Multi-year plan | Statute; provincial priorities (s. 169.2) | Policies; subject plans; operational and school plans; budget |
| Subject plans (bullying, accessibility, special education, mental health, energy) | Their own authority; the multi-year plan | Procedures; school implementation |
| Board policy | Statute or memorandum; multi-year plan | Administrative procedures |
| Administrative procedure | Its parent policy, by number | Practice in schools |
Classifying by function
Titles are recorded but play no part in classification. Where one document does more than one job, classify each part separately.
- Does the text commit priorities, measures and resources to results within a stated period? It is functioning as a plan. Then ask: which required plan is it, and does it meet that plan’s own duty, content, consultation and publication rules?
- Does it state what must be achieved or avoided, and why, without prescribing staff steps? It is functioning as a policy. Then ask: did the board adopt it? If not, note that policy content sits in a staff document.
- Does it state who acts, in what order, within what time, with what notice and record? It is functioning as a procedure. Then ask: does it stay within its parent policy?
- Where title and function disagree, record both. The mismatch tells the board which office should own the document, and tells the reader where the governing rule actually sits.
What good looks like: three checklists
Each test is applied to the published document itself, not to what the board intends or does in practice. The checklists describe good practice; they are not compliance tests.
A good policy
| # | Test |
|---|---|
| P1 | Adopted by board resolution, with the date recorded |
| P2 | Cites the statute, regulation or Ministry memorandum it rests on |
| P3 | States its purpose and scope in a sentence or two |
| P4 | States requirements, outcomes and limits, not staff steps |
| P5 | Uses “shall”, “must” or “will” for obligations; “may” only where discretion is intended |
| P6 | Contains every requirement the law assigns to it, rather than pointing to another document |
| P7 | States rights and routes owed to parents and students in words they can act on |
| P8 | Names who implements it and directs the director to issue procedures |
| P9 | Says how its effectiveness will be evaluated, and when |
| P10 | Carries a number, approval date, revision dates and next review date |
| P11 | Two or three pages, in plain language |
| P12 | Posted on the board website as accessible text |
A good procedure
| # | Test |
|---|---|
| R1 | Names, by number, the board policy it implements |
| R2 | Adds no rule, right or limit the policy does not contain, and contradicts nothing in it |
| R3 | Issued under the director’s authority, dated, with the responsible office named |
| R4 | Names the role that acts at each step |
| R5 | Numbered steps, in order, with conditional branches stated |
| R6 | Time limits on every step that affects a student or parent |
| R7 | Says who is told at each step, including parents |
| R8 | States the outcome and the options available at the end |
| R9 | Requires a record of each step, with retention |
| R10 | States the route to review or appeal |
| R11 | Preserves any discretion the statute gives |
| R12 | Public, where it governs how parents and students are dealt with |
A good plan
| # | Test |
|---|---|
| L1 | Names the authority that requires it (statute, regulation or memorandum) |
| L2 | Carries an approval date and a start and end, or review date, matching the cycle that authority sets |
| L3 | Contains the content that authority requires, written as the board’s own requirements rather than a list of options |
| L4 | Records the consultation that authority requires, with whom and when |
| L5 | A small number of priorities (three to five for the multi-year plan), each traceable to the board’s goals |
| L6 | At least one SMART goal per priority, with a baseline and target in numbers where numbers exist |
| L7 | Specific measures (actions), not only intentions |
| L8 | Money, staff and time committed to each priority, tied to the budget |
| L9 | A named office accountable for each goal |
| L10 | A reporting schedule to the board and to the public, with the data to be used |
| L11 | Published where the authority requires (website, school sites, accessible format) |
| L12 | Aligned to the multi-year plan and to the board’s policies on the same subject |
Governance risks to watch for
The patterns below are governance risks. They are not compliance findings: a document can meet a Ministry memorandum while still carrying one of these risks. Module 7 names their common root: “a lack of shared clarity about the respective roles of the board of trustees and the director of education.”
| Pattern | Why it matters | Better practice |
|---|---|---|
| The code of conduct is published only as an administrative procedure | Unless the board adopted it by resolution, the standards binding the school community carry no board approval and can be changed without a board vote | A board policy containing the standards, with a procedure beneath it |
| The board “policy” is a list of staff steps | The board is doing the director’s work; every change to the steps needs a board vote | A short policy stating requirements; the steps moved to a procedure |
| The procedure carries rights or rules the policy does not | Unless the board adopted them, rules reach parents without board approval | Rights and commitments moved up into the policy |
| A procedure says the board “will establish” a required plan | The procedure reads as though the plan does not exist, and a parent cannot tell whether it does | The plan published, and cited in the procedure by title and date |
| The bullying “plan” is a blank school template, or a direction that schools write their own | No board requirements are written down for schools to implement | A board plan with its requirements written in, which schools implement |
| The plan copies a Ministry model’s headings and fills them with lists of possible programs | Options are not commitments; no owners, dates, indicators or parent route | Board requirements, owners, indicators and dates under each heading |
| A Ministry model plan or memorandum is linked in place of the board’s own | Readers cannot see the board’s own commitments | The board’s instrument, citing the Ministry source |
| A required plan is a vision statement | No measures, targets, resources or reporting | Priorities with SMART goals, measures, resources and a reporting schedule |
| Subject plans do not refer to the multi-year plan, or to each other | Priorities and resources pull in different directions | Each subject plan names the multi-year priority it serves |
| Consultation on the multi-year plan is left to a website posting | Each trustee’s own duty to consult (s. 218.1(c)) is not visibly met | A record of how trustees consulted, alongside the board’s publication and parent meetings |
| The policy promises what it should contain | Acknowledging an obligation is not the same as meeting it | The content written into the policy now |
| A requirement appears only by reference to an unpublished document | A parent cannot rely on what they cannot read | The requirement written into the published instrument |
| Policy and procedure contradict each other | Parents face two rules, and the procedure sits uneasily with s. 283(2), which places procedures within board policy | One reconciled text |
| No approval, revision or review date | Currency cannot be shown | Controlled-document metadata on every instrument |
| “May” or “should” where a firm requirement is intended | A firm requirement is not stated | “Shall”, “must” or “will”, preserving only statutory discretion |
| Published as an image scan | Not readable by screen-reader users | Tagged text or HTML |
Three board-level practices address most of these: a meta-policy on policy development that defines the three layers and their owners (Module 7 recommends one); a register of every policy, procedure and required plan with its owner, parent instrument, authority and review date; and a scheduled check of each instrument against the checklists above.
The legal basis
The Education Act gives policy to the board and procedure to the director, and it divides the plan between them. The trustee training materials say the same. Statutory quotations are from the e-Laws consolidation of the Education Act (consolidation period from 22 September 2026), read 24 September 2026. The authorities for the other required plans are in the required plans table.
1. The Education Act
| Provision | What it says | Duty-holder | Instrument |
|---|---|---|---|
| s. 169.1(1)(d) | Every board shall “develop and maintain policies and organizational structures” that promote its goals | Board | Policy |
| s. 169.1(1)(e) | Every board shall “monitor and evaluate the effectiveness of policies developed by the board … and the efficiency of the implementation of those policies” | Board | Policy |
| s. 169.1(1)(f), (2), (3) | Every board shall “develop a multi-year plan”; it is “a plan for three or more school years”; it must include measures allocating resources to outcomes below the level set by regulation | Board | Plan |
| s. 169.1(4), (4.1) | Publish the plan in the form the Minister requires; bring it to the attention of parents, supporters and employees; report on progress; meet with parents at the start and end of each school year, with “planned and actual spending” (in force 8 June 2023) | Board | Plan |
| s. 169.2 | The multi-year plan must be developed consistently with the Minister’s policies and guidelines, aiming at the provincial priorities in student achievement (in force 8 June 2023) | Board | Plan |
| s. 218.1(c) | “consult with parents, students and supporters of the board on the board’s multi-year plan under clause 169.1 (1) (f)” | Each trustee | Plan |
| s. 218.1(e), (f) | “uphold the implementation of any board resolution after it is passed by the board”; “entrust the day to day management of the board to its staff through the board’s director of education” | Each trustee | All three |
| s. 283(2) | The chief executive officer “shall, within policies established by the board, develop and maintain an effective organization and the programs required to implement such policies” | Director | Procedure |
| s. 283.1(1)(a) to (d) | Review the multi-year plan annually with the board; ensure it “establishes the board’s priorities and identifies specific measures and resources”; implement and monitor it; report on it | Director | Plan |
| s. 283.1(1)(f), (g) | Bring to the board any act or omission that may contravene the Act or “any policy, guideline or regulation”; advise the Deputy Minister if the board does not respond satisfactorily | Director | All three |
| s. 302(3.4) | Every board shall establish policies and guidelines on bullying prevention and intervention | Board | Policy |
| s. 303.2(1), (2) | The Minister “shall develop a model bullying prevention and intervention plan to assist boards” and make it available to every board | Minister | Model (aid) |
| s. 303.3(1) to (6) | Every board shall establish a bullying prevention and intervention plan, require its schools to implement it, consult on it, publish it and review it periodically; principals make it available at the school | Board; principals (s. 303.3(5)) | Plan |
The 2026 amendments. The Putting Student Achievement First Act, 2026 (Bill 101, S.O. 2026, c. 4) received Royal Assent on 7 May 2026 and added s. 283.0.3, in force the same day. It lets the Minister make regulations setting when a resolution or motion of an English-language district school board must be confirmed by the chair, the director or another prescribed official; where a regulation requires confirmation, the resolution “is not effective unless the confirmation has been made in accordance with the regulation” (s. 283.0.3(2)). The Ministry’s proposed regulation (Ontario Regulatory Registry proposal 26-EDU007, posted 7 August 2026, comments closed 12 August 2026) would require the director of education to confirm board resolutions and motions. As at 24 September 2026 the Registry lists the proposal as closed for comments, with no regulation number and no decision posted. If a regulation is made, the line between a board’s policy decisions and operational matters will carry direct legal consequences.
2. The trustee training materials
- Good Governance guide, 2022–2026, p. 46: “A policy is a principle or rule that guides decisions that will achieve the organization’s goals. It articulates what must be done and the rationale for it, but does not deal with how it is to be done. A procedure, or a protocol, is usually administrative, and provides the details of how policies are to be implemented.”
- Same guide, p. 21: the board should “determine, through policy, which matters are operational and therefore addressed by the director of education, and which matters are policy and, therefore, decided on by the board.”
- Same guide, p. 39: the Multi-Year Strategic Plan is “a visioning and policy document that sets the direction for the board,” and “The operational and improvement plans created by the director of education and senior administration are based on the strategic plan and map out how it will be implemented.”
- Module 7 (policymaking, 2019): “Procedures are the responsibility of directors and staff, not trustees”; unclear roles have produced “an excessive number of policy statements about matters which are, in fact, administrative procedures”; and a good policy “should be no more than two or three pages in length and use plain language.” Module 7 also supplies the policy checklist behind P1 to P12.
- Module 6 (strategic planning, 2017): the plan is “the master of other plans”; it should carry three to five priorities, SMART goals, targets, accountabilities, aligned resources and a monitoring strategy.
Modules 6 and 7 predate the 2023 amendments. Where they differ from the Act, the Act governs. Neither was among the modules of Essential Governance 2025, the training the Ministry required in 2025 (reference 18).
3. Administrative law
Board policies, procedures and plans are not statutes, but they shape how the board exercises its powers and they create expectations. Four Supreme Court of Canada decisions, each checked against the judgment on 24 September 2026, set out the principles:
- Policy guidelines may structure a discretion but cannot remove it: “The discretion is given by the Statute and the formulation and adoption of general policy guidelines cannot confine it” (Maple Lodge Farms Ltd. v. Government of Canada, [1982] 2 SCR 2).
- A decision-maker’s own guidelines help show what a reasonable decision looks like: “The guidelines are a useful indicator of what constitutes a reasonable interpretation of the power conferred by the section” (Baker v. Canada (Minister of Citizenship and Immigration), [1999] 2 SCR 817, at para 72).
- Established procedures can ground a legitimate expectation that they will be followed, where the practice is “clear, unambiguous and unqualified” (Agraira v. Canada (Public Safety and Emergency Preparedness), 2013 SCC 36, at para 95, adopting Brown and Evans).
- Internal guidelines and templates are permissible “provided that these methods do not operate to fetter decision making,” and a decision-maker that departs from “longstanding practices or established internal authority” “bears the justificatory burden of explaining that departure” (Canada (Minister of Citizenship and Immigration) v. Vavilov, 2019 SCC 65, at paras 130 to 131).
For boards, the practical consequence is that published policies, procedures and plans are the standard a parent, a tribunal or a court will measure the board against.
4. Other governance practice
Carver’s Policy Governance model (board policies on ends, executive limitations, governance process and delegation, with operating methods left to the chief executive), public-sector policy hierarchies that separate policies from directives, standards and guidelines, and quality-management document control under ISO 9001 (approval, identification, version and review of controlled documents) all reach the same three-layer structure. None binds a school board; each is offered for comparison only.
References
All sources below were read on 24 September 2026 unless marked otherwise.
Legislation, regulations and Ministry materials
- Education Act, RSO 1990, c. E.2, ss. 169.1, 169.2, 218.1, 283(1.1), (2), 283.0.3, 283.1, 302(3.4), 303.2, 303.3. e-Laws consolidation period from 22 September 2026. Sections 303.2 and 303.3 in force 1 September 2012 (S.O. 2012, c. 5, s. 13).
- Putting Student Achievement First Act, 2026 (Bill 101), S.O. 2026, c. 4. Royal Assent and in force (Sched. 2, s. 26) 7 May 2026.
- S.O. 2023, c. 11, Sched. 2, ss. 13, 14 (ss. 169.1(4), (4.1) and 169.2), in force 8 June 2023.
- O. Reg. 191/11, Integrated Accessibility Standards, s. 4. e-Laws consolidation current to 29 July 2026.
- R.R.O. 1990, Reg. 306, Special Education Programs and Services, s. 2. Consolidation period from 1 January 2025.
- O. Reg. 25/23, Broader Public Sector: Energy Reporting and Conservation and Demand Management Plans (Electricity Act, 1998), ss. 2, 3.
- Ontario Ministry of Education. PPM 169: Student Mental Health. Issued 17 June 2024; effective 1 September 2024.
- Ontario Ministry of Education. PPM 128: The Provincial Code of Conduct and School Board Codes of Conduct (2024).
- Ontario Ministry of Education. PPM 144: Bullying Prevention and Intervention (2021). Read 23 September 2026; archived 3 October 2026 at https://web.archive.org/web/20261003210008/https://www.ontario.ca/document/education-ontario-policy-and-program-direction/policyprogram-memorandum-144.
- Ontario Ministry of Education. Bullying prevention and intervention planning for school boards. Published 29 June 2022; updated 8 May 2026. Read 23 September 2026.
- Ontario Ministry for Seniors and Accessibility. Multi-year accessibility plan: sample template (2022), form ON00091, French-language edition (Exemple de gabarit de plan pluriannuel), Central Forms Repository.
- Ontario Regulatory Registry. Proposal 26-EDU007, “Proposal for Regulation Under the Education Act to Require Confirmation of School Board Resolutions and Motions in English-Language District School Boards”. Posted 7 August 2026; comments closed 12 August 2026; status closed for comments, regulation number N/A.
- Ontario Ministry of Education. Near North District School Board governance review, including the Minister’s directions to the board. Published 30 October 2025; updated 1 December 2025.
- Ontario Ministry of Education. Operational Review Report: Toronto District School Board (April 2010), section 2, leading practices for governance and school board administration.
Sector materials
- OPSBA and OESC. Good Governance: A Guide for Trustees, School Boards, Directors of Education, and Communities, 2022–2026, pp. 21, 39, 46.
- Good Governance for School Boards. Module 7, “Exercising Authentic Governance: The School Board’s Role as Policymaker” (last updated September 2019).
- Good Governance for School Boards. Module 6, “The Strategic Role and Multi-year Strategic Planning” (last updated 2017).
- OESC. Essential Governance 2025, described as “a Ministry of Education-mandated professional development training program” of six modules (5, 8, 9, 13, 17 and 19), with a completion deadline of 31 August 2025.
Case law (checked against the judgments)
- Maple Lodge Farms Ltd. v. Government of Canada, [1982] 2 SCR 2.
- Baker v. Canada (Minister of Citizenship and Immigration), [1999] 2 SCR 817, para 72.
- Agraira v. Canada (Public Safety and Emergency Preparedness), 2013 SCC 36, para 95.
- Canada (Minister of Citizenship and Immigration) v. Vavilov, 2019 SCC 65, paras 130 to 131.
Comparative governance practice (not read for this guide)
- Carver, J. Boards That Make a Difference (3rd ed., 2006).
- Campbell, D. and Fullan, M. The Governance Core (2019). Cited in reference 16.
- ISO 9001, Quality management systems: Requirements (document control).
General information, not legal advice.