Audit Wales says the ALN system is under strain. Families in Wales will not be surprised.
A new Audit Wales report, Additional Learning Needs: Do public bodies know if the system is working?, asks whether public bodies in Wales actually know if the Additional Learning Needs system is working.
Its answer is troubling.
Audit Wales says the system is under strain, that public bodies do not have a complete picture of demand, costs and outcomes, and that the system remains adversarial despite some improvement. [1]
For many families, that will not feel like new information. It will feel like official confirmation of what they have already been living.
What matters now is not simply that the report has been published. It is what the report confirms about the pinch points in the ALN system, and what might actually reduce them in practice.
What Audit Wales has found
The report describes a system with serious visibility, consistency and co-ordination problems.
Audit Wales says there is no complete national picture of ALN demand, with important gaps including children below compulsory school age, electively home educated learners, and some post-16 groups. [2] It also says councils interpret ALN differently, apply different thresholds, and do not have a universal understanding of what counts as provision that is “generally available”. [3]
That matters because when definitions vary, support varies too.
The report also finds that some learners have been receiving additional learning provision without an IDP, contrary to the intentions of the Act. [4] And while the ALN Code allows support to be provided before a formal ALN decision, Audit Wales heard that this does not always happen in practice, with different councils taking different approaches and some learners effectively waiting for a decision before getting help. [5]
At the same time, the report says there is no national performance picture on waiting times for ALN decisions, even though many cases depend on input from multiple organisations such as speech and communication services, educational psychology and health services. [5]
On top of that, Audit Wales says workforce data is patchy, cost transparency is poor, and there is still only a limited national picture of outcomes for children and young people with ALN. [1][7]
Why this matters in real life
This is not just a technical data problem.
It is a family pressure problem.
If the system cannot see full demand, it cannot plan well.
If councils apply thresholds differently, families do not enter the system on equal terms.
If support while waiting varies, the burden shifts onto parents.
If children receive provision without proper statutory protection, rights become harder to enforce.
And if outcomes are not being measured properly, it becomes much harder to tell whether support is actually improving children’s lives.
That is why the report matters. It confirms that these are not isolated frustrations or one-off local stories. They are structural weaknesses.
The system remains adversarial
One of the most important findings in the report is that the system remains adversarial.
Audit Wales says its fieldwork suggests that the system continues to be adversarial, and refers to the fraught nature of complaints, disputes and appeals, with strained relationships caused by the gap between what the ALN system promises and what it delivers. [6]
It also warns against assuming that fewer Tribunal appeals automatically mean the system is becoming healthier. Audit Wales explicitly says that appeal numbers are not the only measure of whether the system is becoming less adversarial, and notes that a lack of awareness of appeal rights may be contributing to lower numbers. It highlights survey evidence showing that 54% of parents and carers were not aware of their rights to challenge decisions under the ALN system. [6]
We think that is a crucial point.
A fall in formal appeals does not necessarily mean the system is becoming less conflict-ridden. It may simply mean that some families do not know their rights, do not have the capacity to proceed, or are absorbing the cost of poor decisions in other ways.
For families already in the midst of a cost-of-living crisis, the practical barriers to pursuing Tribunal can also increase in real terms. Specialist reports, time away from work, travel costs, and the difficulty of securing timely expert advice all weigh more heavily when household finances are tight. In our view, that matters when interpreting lower appeal numbers.
Legal aid pressures also matter here. In practice, families can face a tight means test, limited specialist capacity, and real difficulty accessing timely advice and representation. That does not make a case any less valid. It simply makes it harder to pursue.
Early anecdotal evidence we are currently receiving suggests the system may be at risk of becoming more adversarial, not less, as some councils begin to appeal Education Tribunal for Wales decisions. That is new to our own community of 950+ families, which has existed since 2013. We are treating this as an emerging pattern to watch carefully rather than a settled national conclusion. But if it continues, it would point to a system becoming more defensive at the very point families need it to become more collaborative.
Where we agree with Audit Wales
We strongly agree with Audit Wales on several points.
First, the data gaps are serious. If Wales does not have a full picture of need across early years, EHE, post-16 and other settings, then some children and young people will remain partially invisible to planning. [2]
Second, inconsistent interpretation is a real fairness problem. Audit Wales is right to highlight that councils have different thresholds and that there is no universal understanding of what counts as provision that is “generally available”. [3]
Third, support while waiting is a live issue. Audit Wales is clear that support can be provided before a decision, but that this does not always happen, and that waits for wider input can be long. [5]
Fourth, the outcomes picture is too weak. If the system cannot clearly track whether support is leading to better educational and life outcomes, then it is much harder to assess whether current practice offers value or works as intended. [7]
Where we would go a step further
Audit Wales is careful in tone, as public audit reports usually are.
Our own view is a little sharper.
These problems are not only about missing information. They are also about the consequences of late co-ordination.
Too often, different parts of the system still connect with one another after a child is already in serious distress, out of school, at risk of exclusion, or approaching placement breakdown.
By that point:
- the child is under far more pressure
- the parent is often exhausted
- professionals are working reactively rather than preventively
- relationships are more likely to have hardened into conflict
That is one reason the system becomes adversarial.
Not because parents are naturally confrontational, but because people are being connected too late.
We also recognise that many organisations across Wales are already working hard within these constraints, often under significant pressure.
This is also a theme we have already explored in earlier LWL pieces, including Why ALN support often arrives after crisis and When children cannot attend school in Wales.
Waiting times and the late clarification problem
Audit Wales notes that there is no national picture of waiting-time performance, even though statutory timescales exist and many cases depend on wider professional input. [5]
It is also worth noting that Welsh Government only clarified ALN decision-making timescales in operational guidance at the end of March 2026. That clarification came late. For many families, trying to understand what should happen, by when, has meant piecing things together from multiple documents and local interpretations.
We summarised that clarification here: ALN decision-making timescales in Wales.
For readers who want the underlying official guidance, Welsh Government’s operational page is here: Additional learning needs (ALN): decision making and communication.
That update matters because even where the law already existed, practical clarity for families and practitioners was still arriving very late.
Why the Prevent, Bridge, Progress model matters here
Audit Wales highlights a system under strain, with inconsistent practice, variable support while children wait, and an adversarial culture that has not been fully resolved. [1][5][6]
We strongly believe the Prevent, Bridge, Progress model offers something the current system often lacks: a practical structure for earlier collaboration.
Instead of waiting until a child is already in distress, out of school, or at the point of placement breakdown, the model is designed to connect parents, schools and other critical professionals, including the school nurse service, disability social care teams, and NHS therapy and assessment services, when educational risk is first starting to emerge.
That earlier point of connection matters. It gives professionals more chance to work together before positions harden, before support fragments, and before the strain on parents becomes even more severe. In our view, that is one of the clearest ways to reduce escalation and make the system less adversarial in practice.
We set out that model in more detail here: Prevention, Bridging, Progression in the ALN System.
How the LWL model would reduce the pinch points Audit Wales identifies
We do not claim that Learn Without Limits CIC would solve every structural weakness in the ALN system.
It would not eliminate NHS waiting lists.
It would not replace council duties.
It would not fix national data architecture on its own.
But it would reduce some of the pressure those weaknesses currently place on families.
1. Hidden demand would be surfaced earlier
Audit Wales says the system does not yet have a complete picture of need, especially across early years, EHE and some post-16 groups. [2]
The LWL model helps address that by creating a parent-facing intelligence layer through the blog, community and app. That means emerging needs, repeated barriers and hidden demand become visible earlier, rather than only after a child has already fallen into crisis.
2. Inconsistent interpretation would be countered by clearer family knowledge
Audit Wales highlights different thresholds and different interpretations of ALN and ALP across councils. [3]
LWL cannot make every council behave consistently. But it can help families understand the system more consistently, ask better questions, and identify when support is drifting or being interpreted too narrowly.
3. Informal support without legal protection would be easier to spot
Audit Wales found that some learners were receiving ALP without an IDP. [4]
LWL can help parents understand the difference between support happening informally and statutory rights being properly secured. That matters because many families do not realise there is a gap until much later.
4. Waiting would still exist, but the damage caused by waiting could be reduced
Audit Wales says support while waiting varies and that many cases depend on input from other services. [5]
LWL helps by giving parents earlier navigation support, practical next steps, and clearer information about what can still be requested while wider assessments or professional input are pending.
5. Adversarial pressure could be reduced through earlier co-ordination
Audit Wales says the system remains adversarial. [1][6]
The LWL model aims to intervene upstream, before confusion hardens into conflict. If parents, schools and linked professionals are brought together earlier, there is a better chance of preventing escalation rather than merely managing it once relationships have already broken down.
The bigger point
This is why we see Learn Without Limits CIC not as “just information”, but as infrastructure.
Audit Wales has effectively described a system with weak visibility, uneven interpretation, variable support and limited outcome tracking. [1][7]
Our model is designed to reduce exactly those pressures by improving early navigation, making unmet need more visible, supporting earlier collaboration, reducing avoidable escalation, and generating a clearer picture of where families are getting stuck.
That thinking also sits alongside our earlier pieces on From Facebook community to knowledge infrastructure and When communities design the solution.
Both explain why parent-facing knowledge infrastructure matters when systems are fragmented.
At this stage, our model should be understood as an emerging delivery framework with a clear logic, growing real-world resonance, and increasing published articulation, rather than a fully funded national intervention already operating at scale.
That is not the whole answer to Wales’ ALN challenges.
But it is a serious part of the answer.
Learn Without Limits CIC is currently pursuing funding applications to increase our capacity to refine, deliver and evaluate this model at greater depth. That includes developing the practical delivery capability, cross-sector collaboration infrastructure and impact measurement needed to test whether earlier parent-facing intervention can reduce escalation, improve navigation, and support more timely co-ordination around children at emerging educational risk.
Over time, we would want to track practical indicators such as repeated parent query themes, common friction points in system navigation, time-to-guidance, escalation patterns, and whether earlier access to clear information appears to reduce breakdown, delay or formal dispute.
We do not assume this impact. We want to build the capacity to test and evidence it properly.
Final thought
Audit Wales has confirmed that the ALN system is under strain.
What it has also shown, perhaps unintentionally, is where that strain is landing most heavily: on children, on families, and on the relationships that should be holding support together.
If you are living this now, you are not imagining it, and you are not alone.
If Wales wants a system that is genuinely person-centred, then earlier co-ordination matters.
Better visibility matters.
Consistency matters.
And preventing crisis before it hardens into conflict matters.
That is where we believe the strongest opportunity now lies.
References
[1] Audit Wales, Additional Learning Needs: Do public bodies know if the system is working?, April 2026.
[2] Audit Wales, Additional Learning Needs: Do public bodies know if the system is working?, April 2026. Findings on incomplete national demand data, including gaps relating to children below compulsory school age, electively home educated learners, and learners above compulsory school age.
[3] Audit Wales, Additional Learning Needs: Do public bodies know if the system is working?, April 2026. Findings that councils have different thresholds for deciding if learners have ALN, and that there is no universal understanding of what counts as provision “generally available”.
[4] Audit Wales, Additional Learning Needs: Do public bodies know if the system is working?, April 2026. Findings that some learners were receiving ALP without an IDP, contrary to the intentions of the Act.
[5] Audit Wales, Additional Learning Needs: Do public bodies know if the system is working?, April 2026. Findings that there is no national data on waiting times for ALN decisions, that support while waiting varies, and that many cases depend on wider input such as speech and communication assessments and educational psychology.
[6] Audit Wales, Additional Learning Needs: Do public bodies know if the system is working?, April 2026. Findings that the system continues to be adversarial; complaints, disputes and appeals are often fraught; appeal numbers are not the only measure; and 54% of parents and carers were not aware of rights to challenge decisions.
[7] Audit Wales, Additional Learning Needs: Do public bodies know if the system is working?, April 2026. Findings that there is only a limited picture of outcomes for learners with ALN, and recommendations for improved data, transparency and monitoring.