Objective: International agencies report the importance of health promotion in planning educational strategies and school management in response to the COVID-19 pandemic. This study aimed to identify the benefits of using a Health Promoting School (HPS) approach to guide educational and school policy during the COVID-19 epidemic in Italy, the main objectives and practices to be implemented, and the challenges likely to be faced. Design: A three-phase qualitative and participatory approach--(1) identification of study objectives and relevant data, (2) data collection through an online form using open-ended questions (14 participants), and (3) online meetings to analyse the findings and reach consensus (17 participants). Setting: Educational leaders from the HPS Network in the Lombardy region in northern Italy participated in the study. Method: Qualitative content analysis was undertaken. Answers were coded into meaningful units and then grouped under higher-order headings. Codes, subcategories, categories and themes were identified. Results: Results suggested high potentiality, significance and sustainability of the HPS model during the pandemic. Objectives and actions relevant to each HPS component were identified. Adaptations to content and methodology, timing, continuity and inequalities requiring specific forms of intervention were identified. Conclusion: This study sought to develop an HPS model relevant to implementation during the COVID-19 epidemic and identified specific lines of action during this challenging period. [The Lombardian HPS Coordinators co-authored this article.]