In mid-April, the Ministry of Education submitted for approval a draft government regulation that sets new requirements for the learning and developmental environment in general education schools.

Among other things, the draft stipulates that, as a rule, school lessons should start at 9 a.m. instead of the current 8 a.m. It also requires that grass in schoolyards be mowed, school walls be painted with non-glossy paint, stair railings be installed on both sides of staircases and that windows on higher floors not open more than 10 centimeters.

Feedback received so far on the draft has highlighted several concerns. The Estonian School Principals' Association announced that its members had discussed the matter and do not support the proposed changes.

"The association's position is that the regulation should not be implemented in its current form. Amendments, improvements, clearer wording and further discussion are necessary," said Urmo Uiboleht, chair of the association's board.

He pointed out that opinions submitted by school principals and regional organizations indicate the regulation is legally inconsistent. Some provisions are very general — for example, all rooms must have artificial lighting — while others are extremely detailed, such as requiring that indoor air movement speed generally remain below 0.21 meters per second.

According to the principals, Education Minister Kristina Kallas has told the media that school leaders are best positioned to manage operations on-site. However, they argue that the draft regulation contradicts this claim by prescribing exact start times for lessons, specifying meal interval lengths and so forth.

"Autonomy and the so-called 'freedom' of school principals are lacking precisely in the politically complex areas where disputes and differing interpretations are possible. This feels more like shifting responsibility onto the schools, so that if parents are dissatisfied, the schools are blamed," the principals noted.

As an example, they cited a provision barring students who show clear signs of illness and could pose a health risk to themselves or others from attending school. However, the draft does not specify the legal grounds or procedures by which schools should enforce this rule. The principals added that in the event of a legal dispute, the school would likely be held responsible in any case.

More time should be allowed before start of school day changed

Separately, Uiboleht raised the question of who would cover the costs of the necessary changes, such as upgrading ventilation systems to meet the new requirements. Principals also want to know whether they would need permission if they wish to continue starting the school day at 8 a.m.

"Overall, we need to seriously consider not overregulating all our activities. Otherwise, we'll end up struggling when we can't comply with certain provisions for financial or other practical reasons. It's important that we don't box ourselves in," Uiboleht said.

He suggested that shifting the school start time to 9 a.m. or later should take effect starting September 1, 2026, rather than this fall, to give schools time to revise their schedules. As a compromise, Uiboleht proposed starting lessons at 8:30 a.m.

The draft regulation's requirements for school facilities have also drawn criticism from principals, including a mandate to provide both hot and cold water in every classroom.

"In older school buildings, classrooms only have cold water because hot water was not required when the buildings were constructed. The existing plumbing ensures room-temperature water. What is the issue with not having hot water in classrooms? Both hot and cold water are available in washrooms and restrooms. Bringing water supplies up to the new standards would impose a significant cost on school owners," the principals explained.

The regulation introduces a host of new responsibilities for schools, principals, teachers and local governments, which would be required to conduct technical audits of all school buildings, develop investment plans and commission construction work.

In conclusion, the principals noted that although the draft's explanatory memorandum claims it would not impose significant new obligations on schools, it would, in fact, create real additional tasks, such as first aid training for all staff, documentation of environmental risks and more detailed room and furnishing requirements. The draft would also increase bureaucracy.

The association stressed that implementing the changes would require a longer preparation period than just the summer — especially since summer is also vacation time for schools. They also raised concerns about how to fit all the new requirements into teachers' working hours.

Special pedagogues worried about number of tests

The Estonian Association of Special Education Teachers has also submitted feedback on the draft to the Ministry of Education. Its chair, Liina Õmblus, said that most of the proposed changes seem appropriate from the standpoint of modernizing conditions.

However, they expressed concern about provisions related to homework. Under the draft, homework deadlines cannot fall on Mondays, the day after school breaks or the day following public holidays unless otherwise agreed with the students. Special education teachers would prefer to allow Monday deadlines for subjects that meet only once a week and are scheduled on Mondays.

"Regarding the school day start time, the Estonian Association of Special Education Teachers believes it would be reasonable to add a clarification that, by agreement with families, time before 9 a.m. could be used to provide support specialist services to students who have been assigned enhanced or special support," the association proposed.

The draft no longer specifies requirements for the timing of tests or the number of tests allowed per day or week.

"We are somewhat concerned about this and hope that academic workload in the second and third stages of schooling will not be unreasonably increased at the end of grading periods," the special education teachers said.

The Ministry of Education accepted feedback on the draft until May 7, but it currently has no information on how many changes will be made based on the responses received.

"Several of our key partners have requested extensions for submitting feedback. We have granted them additional time," said Elo Eesmäe, the ministry's communications adviser. "Once we receive all feedback, we will need some time to analyze it before making any decisions."

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