DBS and Barred List Checks – Regulated Activity

From 1 September 2026, all volunteers/unpaid helpers who fit criteria will be considered in regulated activity with children and will require an enhanced DSB with barred list check. Currently those volunteers/unpaid helpers do not need those checks because they are considered supervised by someone else in regulated activity, which has been recognised as a weak safeguarding arrangement. They will now automatically be in regulated activity themselves and subject to a barred list check which can prevent them working from children (if relevant) even though they have a clear basic or enhanced DBS.

Criteria is a person undertaking activities such as teaching, training, instructing, caring for or supervising children, even if under supervision of another person

• on more than 3 days in a 30-day period (volunteering hours in different roles are considered to be one amount so 2 roles of 1.5 days each in a month is regulated activity)
• overnight (only needs to happen once)

All agencies will need to start reviewing their existing volunteers and ensure plans are put in place to trigger enhanced DBS and barred list checks from the 1 September 2026. They will need to ask volunteers if they have activities in other agencies which may be accumulative to 3 days + in a 30-day period. Any new onboarding of volunteers needs to include these new checks from this date.

Although the government guidance specifically mentions schools and colleges, this is because they are likely to have a large workforce impacted by this. However, the changes apply to all organisations providing services to children.  

See: Regulated activity: removal of the supervision exemption (comes into force 1 September 2026) - GOV.UK