Dr Jeanette Rowley discusses how the introduction of the new Welsh school food regulations may influence the availability of plant-based choices for learners
New Welsh Healthy Eating in Schools Regulations for maintained primary schools are due to come into effect on 31 October 2026. They strengthen standards on healthy eating in schools, include plant-based alternatives to cow’s milk and promote plant foods such as beans and pulses but do not mandate a daily vegan lunch option.
The positives for “lifestyle” and ethical vegan lunch provision
- Plant-based alternatives to cow’s milk are included: the Regulations permit plain, unsweetened, calcium-fortified plant-based drinks within the permitted drinks framework.
- A weekly legumes-based protein alternative meal is required: at least once each week, schools must provide a non-meat and non-fish lunch option where beans and/or pulses are the main source of protein. This must be offered as the alternative to a meat or fish lunch on the same day.
- Plant-based meat alternatives can be used in meal design: “processed alternatives” to meat and fish (meat alternative foods such as burgers and sausages) are allowed at lunch but are limited to no more than two days per week.
- Soya, pea-protein and mycoprotein mince/pieces/chunks are not classified as “processed alternatives to meat and fish” and therefore not included in the two days per week rule above. This offers additional opportunities to design vegan meals.
- The Integrated Impact Assessment recognises “lifestyle” vegan diets in the ‘special diets’ category and says forthcoming guidance due in 2026 will support inclusive provision. It will also reassert that failing to provide appropriate dietary options could constitute discrimination where it engages protected characteristics. The positive here is that ethical veganism is a protected philosophical belief in the category ‘religion or belief’ and vegan families will be able to rely on the prohibition on discrimination under the Equality Act 2010.
What the Regulations still do not do
The Regulations do not mandate a fully vegan (100% plant-based) lunch option every day. The weekly legumes-based alternative is not, by itself, required to be vegan and could therefore contain eggs, milk or other animal-derived ingredients. Nevertheless, with appropriate menu design it should be feasible to accommodate vegan learners under the Regulations.
How daily vegan provision could work in practice (one workable model)
Even without a daily vegan mandate, caterers can accommodate vegan pupils under the Regulations across a five-day week by menu design, for example:
- 1 day: the required weekly option where beans/pulses are the main protein.
- Up to 2 days: a plant-based burger/sausage-style option (within the “processed alternatives” cap).
- Other days: plant-based meals built around non-meat proteins not treated as “processed alternatives” under the Regulations’ definitions (e.g., mince/pieces/chunks formats that are excluded from that category).
This example is for illustration. It will also be important that suitability for vegans must be specified in ingredients and preparation, and meals must also meet the school food nutrition standards.
The 2026 “inclusive and strengthened” Guidance will be vital for vegans
The Welsh Government’s Integrated Impact Assessment recognises the dietary needs of vegan learners and states that risks are being mitigated through “inclusive and strengthened” guidance to be published in 2026, supported by stakeholder engagement and monitoring. It also indicates that the guidance will:
- Include a dedicated section on managing special diets. Special diets includes both “lifestyle” and those related to protected characteristics such as those grounded in protected beliefs.
- Encourage schools and local authorities to engage learners and families in menu planning so that food provision is inclusive and responsive.
- Refer to the Equality Act 2010, including the duty to make reasonable adjustments.
- Clarify that failure to provide appropriate dietary options could constitute discrimination on multiple grounds, including “belief”.
- Address concerns about learners opting out if menus do not meet needs.
The Welsh Government has stated its commitment to upholding the principles of human rights and to reinforcing legal duties under the Equality Act 2010. It also confirms that its school food strategy “aligns with the broader human rights obligation to support the well-being of all children, ensuring that school food provision is culturally sensitive, and responsive to individual needs.” Given that it is well-established that ethical veganism can be protected under both human rights and equality law, it is disappointing that the Welsh Government has not taken the opportunity to mandate a fully plant-based daily meal option in the long-awaited updated school food Regulations. This is especially so considering that vegan meals are suitable for wide range of learners including those with protected characteristics.
However, the new Regulations confirm welcome steps for school catering, but it is vital to the wellbeing of vegan pupils that the promised inclusive and strengthened guidance adequately supports the provision of a daily vegan meal without the need for individual requests. This will contribute to true inclusion and pupil wellbeing and remove the administrative burden placed on vegan families who would otherwise have to request vegan food for their children and potentially engage the formal complaint process. The guidance must also be published as soon as possible so that schools, local authorities and caterers can plan compliant menus for all, detail procurement contracts and address operating processes in time for the deadline.
The views expressed by our bloggers are not necessarily the views of The Vegan Society.
