Despite dictatorial ministers and the strait-jacket of league tables, school leaders enjoy more freedom than their colleagues in the developed world. Dorothy Lepkowska reports
Schools in England enjoy more freedoms than most of their counterparts in the developed world, thanks to radical funding reforms introduced 16 years ago.
Local management of schools, or LMS as it became known, put heads and governors in charge of millions of pounds when previously they had only a few thousands for books and resources. Overnight it revolutionised the way schools were run.
Some coped better than others, and in the first few years several heads fell foul of the system and found themselves suspended amid accusations of maladministration.
Today it is taken for granted that a major part of the burden of headship is responsibility for managing a multi-million pound organisation.
John Dunford, general secretary of the Association of School and College Leaders, remembers his time as head of Durham Johnston school, in Durham, as a career of two halves.
"I was there for 16 years - the first eight were pre-LMS. There was no comparison between what I was able to achieve before and after LMS arrived," he said.
"Before I had an annual budget of about pound;30,000 which went mainly on books. Afterwards it was closer to pound;3 million, giving me the flexibility and freedom to spend according to the needs of the school.
"The first thing I did was put a carpet in the staffroom. The second was to hire more support staff. There is no doubt that being able to target money where it's needed helps to raise standards."
With the growth of trust and foundation schools, and now academies, heads in England enjoy more freedom than most colleagues in the developed world.
Heads can hire and fire their own staff, are responsible for school buildings, set their own pay scales and even opt out of the national curriculum.
It is a very different story elsewhere in the developed world.
However, Professor Ron Glatter, an expert in school governance and visiting professor at the Open University, warned ministers not to get carried away with giving English schools too much autonomy, and suggested schools had enough freedom already.
"There is a tension between independence and interdependence," he said.
"International studies suggest that where schools collaborate results are better. Setting up a series of well-funded schools is not going to improve standards overall."
In Australia, degrees of autonomy vary among the eight states and territories, but secondary principals enjoy greater freedom than their primary counterparts.
They can hire some, but not all, staff and receive a fixed sum every year from the government, for use on maintenance and administrative staff.
Teachers are employed and paid by the education department.
German teachers in state schools are paid by the individual states, which also make their own education policies.
Headteachers can apply to hire the teachers they need but the final decision rests with the state, which will try to maintain a fair distribution of well-qualified teachers throughout its schools.
Teachers in western Germany - but not yet in the eastern states - acquire permanent job status after three years. Schools cannot fire them after that.
Recent years have seen a shift towards greater individual school autonomy in Japan, with heads having some control over part of their budget, though it can vary from one region to another.
In Yokohama city, for example, budgets are under the total control of headteachers.
All schools now have some say as to how they teach the national curriculum and it is up to headteachers to arrange their school curriculum within the national standards.
However, principals have no control over pay and conditions or hiring and firing of staff. These powers still reside with the local education authorities.
The French education system, meanwhile, is centralised, with decisions on employment, appointment and payment of teachers, number of teaching hours in the year, and all aspects of the curriculum taken nationally.
However, some functions are partly decentralised. Maintenance of buildings and the provision of some out-of-school activities are controlled and financed by local or regional authorities in consultation with schools.
In French schools, autonomy, such as it is, rests with the collective control of schools' governing councils, which include representatives of teachers, administrators and other staff, parents, and local authorities and interests. Different systems apply to primary and secondary sectors.
Primary heads - or directors - have limited freedom and effectively are little more than classroom teachers granted time off from their teaching duties.
The director has the same status as colleagues teaching full-time, and has no authority over them. The job is mostly administrative. Decisions concerning running the school, including budget allocations, must be approved by the school council. At secondary level, heads - the principal at coll ge (lower secondary), proviseur at lycee (upper secondary) - have much more autonomy.
Executive status brings hierarchical superiority over all other staff and responsibility for overall management of the school.
They have no teaching duties and are responsible for liaising with the education and local authorities; monitoring teaching standards; ensuring school security and order. They allocate the global budget received from the controlling authority - the departement for coll ges or region for lycees - but the governing school council, over which the head presides, must approve financial decisions, as well as any proposals heads make concerning the school's internal organisation or activities in or outside school.
Schools in America have limited autonomy but some cities, including Chicago, Boston and New York, are starting to experiment with devolution.
Heads in California have discretion over no more than 8 per cent of school funding - the small change left over after sums have been earmarked for staffing and materials. Generally, budgetary powers rest chiefly with school districts -education authorities, which draw up budgets, and school boards, composed of elected officials, with right of approval or veto over them.
The country's 3,800 charter schools - publicly-funded but independently-run -have freed up heads from central control to spur innovation.
In the Netherlands, heads have been pushing for more autonomy in schools but without the political interference they consider is prevalent in England.
Almost 70 per cent of schools are church-run, though state funded, and the church boards act as a kind of local education authority. Secondary heads have control over their budgets which are provided as a lump sum according to pupil numbers and the proportion of ethnic minority and socially disadvantaged children.
Schools are required to teach a common curriculum, but those guidelines are vague and heads can decide on textbooks and how the curriculum is delivered, including teaching methods. The range of available books, though, is limited so in practice they are not as free as it would appear.
Heads can appoint staff but must adhere to strict pay and condition regulations decided by national collective negotiation. It is not easy to fire teachers as they are virtually civil servants.
Canada's 10 pro-vinces run their own school systems, but they are structured in similar ways.
Principals have little or no control over the school budget. In Ontario, for example, they are determined by the number of students enrolled in the school. They might have some control over the school's maintenance budget, but that too is set by the district.
They also have little control over the staff. A school's individual staffing needs are assessed using a formula which takes into account pupil numbers.
Principals have no say in pay rates, though in a few provinces there are pilot projects under way which would grant them the power to approve "merit pay", for example, if students exceeded expectations on exams.
Italy is among the most autonomous countries in Europe. The past decade has seen a steady flow of legislation devolving autonomy to regions and to schools. Until recently schools' funding arrived already earmarked for specific purposes, but now heads have more control over how they spend.
However, they have no control over how much they receive, as this is allocated according to fixed formulas. Compared to British schools, the sums are relatively small, as teachers' salaries are paid directly by the government. All schools follow a national curriculum or rather, a programme of educational objectives, but legislation passed in 2002 has made it possible for up to 15 per cent of the curriculum to be decided locally.
Heads are not involved in selecting staff, and cannot hire and fire, except in the case of short-term supply teachers. There have been cases of heads being accused of leaving classes without supply cover to save money.
Additional reporting by TES international correspondents