DBS checks are changing in September 2026: what employers need to do now

From 1 September 2026, the supervision exemption for regulated activity with children will be removed. Organisations that use supervised volunteers to work with children should review those roles now, identify who will fall within regulated activity under the new rules, and update their DBS checking processes before the change takes effect.

For schools, nurseries, charities, sports clubs and other organisations working with children, this is a practical safeguarding change with an immediate recruitment impact.

What is changing on 1 September 2026?

Under the current rules, some people working with children are excluded from regulated activity because their work is supervised. This supervision exemption has been particularly relevant to volunteers.

From 1 September 2026, that exemption disappears. Where the activity itself meets the definition of regulated activity and is carried out frequently or satisfies the relevant period condition, supervision will no longer prevent it from being regulated activity. The period condition includes activity carried out on more than three days in a 30-day period or overnight.

The government guidance makes clear that volunteers are the main group affected. Paid staff who have qualifying contact with children are already within regulated activity, so the change does not create a new category for all supervised employees.

For affected volunteers, the consequence is significant: they will need an Enhanced DBS check with Children's Barred List information.

Employers can read more about the different levels of screening in Veremark's complete guide to DBS checks in the UK.

Which organisations should review their roles?

Any organisation that regularly uses volunteers to teach, train, instruct, care for or supervise children should check whether its current arrangements rely on the supervision exemption.

That could include classroom volunteers in schools, helpers in nurseries, regular youth charity volunteers and adults supporting children's sports sessions. The exact level of DBS check depends on the activities involved, so employers should assess the role itself rather than relying on a job title.

This matters because Children's Barred List checks are restricted to eligible roles. Employers cannot simply request the highest level of DBS check as a precaution. Veremark's guide to what criminal record checks UK employers can legally request explains why eligibility needs to be established first.

What should employers do now?

DBS checks are changing in September 2026, so organisations should review existing roles before the September deadline rather than waiting for their next recruitment cycle.

Start by identifying volunteers whose work with children is currently treated as outside regulated activity because it is supervised. Check the activities they perform and how frequently they perform them against the updated definition.

Where a role will become regulated activity, confirm that your process can obtain an Enhanced DBS check with Children's Barred List information. DBS has specifically told organisations to review affected roles and recruitment arrangements ahead of the change.

Recruitment documents may also need updating. Job and volunteer descriptions, safeguarding policies, onboarding workflows and communications with candidates should reflect the correct eligibility from 1 September.

Organisations in early years settings may also want to review the wider role of screening in safeguarding. Veremark covers this in its guide to background checks in the nursery and early childhood care sector.

September is too late to start checking

The change comes into force on 1 September, but the work for employers starts before then. Organisations need enough time to identify affected volunteers, confirm eligibility and change their screening processes.

DBS checks are changing in September 2026: what employers need to do now comes down to one priority: review any child-facing volunteer roles that currently depend on supervision to sit outside regulated activity. If those roles will become regulated activity, the appropriate DBS and Children's Barred List checking process needs to be ready before the new rules take effect.