Itchy Coo, publisher and provider of educational materials in Scots, claims it has been disadvantaged since only English, Gaelic, Urdu, Punjabi and Polish are specifically named as the different languages of Scotland in the draft guidelines for ACfE.
"It is a matter of the utmost importance that this be corrected," Matthew Fitt and James Robertson of Itchy Coo state. "As ACfE presently stands, teachers will lack official support from the curriculum for the teaching of Scots."
Mr Fitt and Mr Robertson claim that teaching children Scots can improve their English literacy too. "By introducing Scots alongside English in the classroom, pupils are immediately tasked with thinking about language at a more analytical level," they say.
"As well as fostering an appreciation of Scots, it can be demonstrated that such language study can enhance a pupil's skills in the pronunciation, spelling, reading and writing of English."
Pupils previously regarded as reluctant readers often surprise teachers and parents by showing great enthusiasm for reading books written in Scots, they say.
There is even scope, they claim, for using Scots as a vehicle to improve attainment in S2, in particular for boys.
Those who object to the strategy point out that, traditionally, the only opportunity to speak the language in school occurs once a year during the annual Scots verse-speaking competitions.
"While other minority languages are quite rightly included in a school's language provision, Scots is generally excluded, denying Scots-speaking pupils the chance to develop writing and reading skills in their first language," say the Itchy Coo publishers.
There is another practical linguistic benefit of using Scots to enhance language learning, they say. "The velar fricative, or x phoneme as in 'loch', is rapidly disappearing from the speech of our young people. Without it, pupils are unable to reproduce to a high standard the sounds of German, Spanish, Gaelic, Russian and many other languages.
"Wider use of Scots in schools would necessarily feature words such as nicht, licht, thocht, mauchit and so on, giving pupils the opportunity to hear and practise this sound, which would lead to an improved facility for foreign languages."
Each local authority should appoint at least one education officer with particular responsibility for ensuring that Scots is taught at all levels in education
More systematic and accurate methods of data collection on the number of Scots speakers should be used. According to the 2006 pupil census, only 280 children whose family language was Scots were declared
Equal treatment for Gaelic and Scots the draft strategy states that Gaelic will be "protected and promoted" but that Scots will be treated with "respect and pride"