From 1 September, the rules on DBS checks for volunteers are changing in a way that will catch out a significant number of schools, colleges, childcare providers and other organisations that rely on volunteer support around children. If your organisation has volunteers who help out regularly – even under supervision – it’s worth understanding exactly what’s changing, and why “we’ve always done it this way” is no longer a safe assumption.
By Tim Stokes, Sales Director, Security Watchdog
What’s actually changing
The Crime and Policing Act 2026 removes what’s known as the “supervision exemption” from the legal definition of regulated activity. Until now, unpaid volunteers teaching, training, instructing, caring for or supervising children weren’t classed as being in regulated activity if a member of staff supervised them – a class teacher overseeing a parent helper, for example. That exemption disappears from 1 September 2026.
In practice, this means volunteer activity now counts as regulated activity – triggering the requirement for an enhanced DBS check with children’s barred list information, the highest level of criminal record check available in the UK – if it meets any of these conditions:
- It happens frequently
- It takes place on more than three days in any 30-day period
- It involves an overnight stay between 2am and 6am
Get any of these wrong and you risk a genuine safeguarding gap, not just a compliance box left unticked.
Who this actually affects
The people most exposed by this change are supervised volunteers – the group the old exemption was designed to cover. Paid staff with contact with children were already in regulated activity regardless of supervision, so nothing changes there.
This isn’t limited to schools. We’re already seeing the ripple effect into childcare settings, youth sport, heritage organisations and charities that rely on volunteers working alongside children – anywhere a supervised volunteer has regular, hands-on contact.
A few practical details are worth flagging, because this is where organisations tend to trip up:
- The three-day threshold is cumulative across settings – A volunteer helping four days a month, split across two or three different schools, still meets the period condition. Organisations sharing volunteers should talk to each other about who initiates the check.
- Overnight trips change the picture automatically – Any volunteer helping on an overnight school trip is now in regulated activity, full stop.
- Occasional helpers are unaffected – A parent helping at a one-off PTA event doesn’t need an enhanced check with barred list information – though schools can still request a standard or enhanced check without it.
- The fee waiver only covers part of the cost – Volunteers won’t pay the government’s own DBS fee for Standard, Enhanced or Enhanced with Barred List checks. But applications have to go through a Registered Body or umbrella body, which typically charges an administration fee for handling identity verification and submission – worth budgeting for, and worth choosing a provider that’s upfront about what it covers.
The common thread across all four is the same: the rules are more precise than they first appear, and getting the detail wrong on eligibility, on frequency, or on process, is where organisations tend to create risk rather than reduce it.
What organisations should do before 1 September 2026
For anyone responsible for safeguarding, HR or volunteer management, this is a live risk-assessment exercise, not a distant deadline:
- Map your volunteer base – Identify anyone currently volunteering under supervision with children, and assess whether their activity will meet the frequency or period conditions from September.
- Check for cross-organisation volunteers – If volunteers split their time across settings, establish who owns the DBS process and how information will be shared.
- Build in time for processing – Enhanced DBS checks with barred list information take time to process, particularly during peak back-to-school periods. Starting early avoids a September scramble.
- Encourage the DBS Update Service – It’s free for volunteers and lets your organisation confirm a certificate is still current without triggering a fresh application every time someone moves between roles or settings.
- Review your safeguarding policy documentation – Boards and senior leaders will reasonably expect to see that this change has been risk-assessed and actioned, not just noted.
The bigger picture
This change reflects a straightforward principle in my mind: A child’s safety shouldn’t depend on whether the adult supporting them is paid or unpaid. Removing the supervision exemption closes a gap that’s existed for years, and it’s a sensible one to close. But sensible legislation still needs careful, practical implementation, and with September 2026 fast approaching, organisations that treat this as a genuine safeguarding review, rather than a paperwork exercise, will be in a far stronger position.
For many organisations, that review will also mean a real increase in the number of enhanced DBS checks with barred list information going through their umbrella body – often at a point in the year when processing times are already under pressure.
If you’re responsible for volunteer safeguarding and want support working through what this means for your organisation, we can help. Reach out to the team for everything from eligibility assessments to managing enhanced DBS checks with barred list information at scale.
