Legislation enacted in 2014 in England and 2016 in Scotland attempts to boost the rights of children and young people with special and additional support needs in the context of education, particularly with regard to opportunities for their participation in decision-making and local planning, with governments in both nations claiming that the new measures place the UK at the forefront internationally on this issue. There are, however, key differences in the respective nations’ legislation and policy, as well as similarities, which the article explores. Using case studies, it then examines the central issues arising in each jurisdiction in the practical realisation of the relevant rights. The article concludes with a comparative discussion of the recognition of children’s autonomy in the context of education in the two nations, highlighting gaps between rhetoric and reality.