The biggest changes to DBS eligibility in years come into effect on 1 September 2026. Join Oliver Jones, DBS Specialist at Verifile, for a practical session exploring what these changes mean for volunteer-involving organisations.

Oliver will cover:

• The removal of the supervision exemption.

• The new regulated activity criteria.

• How DBS eligibility is changing.

• When Enhanced DBS checks with Children's Barred List checks will be required.

• What these changes mean for your volunteer recruitment and onboarding processes.

Notes from the call: DBS changes from 1 September 2026

The key change in one sentence

From 1 September 2026, the supervision exemption for people carrying out certain activities with children is being removed.

This means that being supervised by another adult will no longer automatically prevent a role from being considered regulated activity with children.

For organisations, the big thing to review is whether people who work with children while supervised may now be eligible for an Enhanced DBS check including a check of the Children’s Barred List.

What happens now vs from 1 September?

Before 1 September 2026

If someone carries out relevant work with children but is sufficiently supervised, that supervision can currently mean the activity is not treated as regulated activity for the purposes of a Children’s Barred List check.

They may still be eligible for an Enhanced DBS check for the child workforce, but without the Children’s Barred List check.

From 1 September 2026

The fact that the person is supervised will no longer create that exemption.

If their role involves the relevant activities with children and they meet the required frequency criteria, they may now be eligible for:

Enhanced DBS + Children’s Barred List

This could affect a lot of volunteer roles that organisations previously considered covered because another DBS-checked member of staff, teacher, parent or supervisor was present.

The frequency rule

Oliver explained that the main frequency threshold discussed in the session is:

More than three days in any 30-day period — in other words, four days or more.

It does not need to be four consecutive days.

For example:

• 4 separate volunteering days within one 30-day period could meet the threshold.

• 10 days in one 30-day period followed by no activity the following month could still meet the threshold.

• Oliver also described once a week on an ongoing basis as meeting the frequent activity test.

There is also an overnight rule.

A person can meet the regulated activity criteria if they work once overnight between 2:00am and 6:00am, where there is an opportunity for contact with children.

This could be relevant for:

• residential trips

• overnight camps

• residential volunteering activities

Even somebody who does not normally volunteer frequently could therefore potentially meet the criteria because of an overnight activity.

A simple way to think about it

If someone is working directly with children:

Frequently

Generally, if the relevant activity happens four days or more in any 30-day period, the session guidance was:

Enhanced DBS + Children’s Barred List

Infrequently

If the activity is expected to happen, but happens less than four days within a 30-day period, the session guidance was:

Enhanced DBS for the child workforce, without the Children’s Barred List

Important

This is a simplified way of understanding the change.

Some activities, particularly healthcare and personal care, have different eligibility rules and can qualify on the basis of the activity being carried out even once.

What sort of activities count?

Oliver explained that relevant activities with children can include:

• teaching

• training

• instruction

• caring for children

• supervising children

• providing advice or guidance relating to their educational, emotional or physical wellbeing

• providing healthcare

• providing personal care

• driving children in certain circumstances

• some online communication or moderation roles

• certain roles within specified establishments for children

The important question is generally:

Is working with children actually part of the role?

Simply being somewhere where children happen to be does not automatically mean somebody is eligible for an Enhanced DBS check.

Supervision by another adult no longer removes the issue

This was one of the biggest themes of the session.

From 1 September, it does not necessarily matter that:

• a teacher is in the classroom

• a DBS-checked member of staff is nearby

• a parent or guardian is present

• another volunteer is supervising

• the activity is taking place as part of a family volunteering session

If the person themselves is carrying out an eligible activity with children, their own role needs to be assessed.

The frequency of that activity will then help determine whether the Children’s Barred List can be checked.

Does having parents present make a difference?

Not necessarily.

An example was discussed where a family attends a volunteering activity together and the children remain with their parent or guardian.

If a member of staff or volunteer is still:

• giving the children instructions

• guiding them through the volunteering activity

• supervising them

• advising them

Oliver said their role could still be eligible for an Enhanced DBS check.

After 1 September, the fact that the child's parent is there does not automatically remove the DBS eligibility.

Do we need to check every adult who is near a child?

No.

This distinction came up several times.

Working near children is not the same as working with children.

For example, if several adult volunteers work in a charity shop and one 14-year-old volunteer is there, that does not automatically mean every adult volunteer in the shop needs an Enhanced DBS.

The adults whose actual role involves things such as:

• managing the young volunteer

• supervising them

• training them

• instructing them

• directly supporting them

are the people whose roles need to be assessed.

Simply working in the same room or building would not automatically qualify somebody for an Enhanced check.

Museums, heritage sites and visitor attractions

This generated quite a few questions.

A museum or heritage site is not automatically treated in the same way as a school or children's home simply because children visit it.

The role itself matters.

For example:

Likely to need further DBS eligibility consideration

A museum volunteer whose role includes:

• running activities for children

• teaching or instructing children

• taking children around an exhibition

• explaining exhibits directly to children as part of their role

• supervising children's activities

could potentially be eligible for an Enhanced check.

If they do this frequently enough, the Children’s Barred List may also be appropriate.

Incidental contact is different

Someone working in:

• a museum shop

• a café

• a technical role

• another general visitor-facing role

doesn't automatically become eligible for an Enhanced DBS simply because they sometimes speak to or serve a child.

Oliver used the example that someone working in a shop might come into contact with children, but working with children isn't actually part of their role.

The organisation therefore needs to look carefully at what the role is expected to involve, rather than simply whether children might be present.

Charity retail and young volunteers

A really useful example came from charities that take volunteers aged around 14–17.

If an adult volunteer is directly responsible for:

• training

• supervising

• supporting

• instructing

• managing

a younger volunteer, their role may be eligible for an Enhanced DBS check.

However, this doesn't mean everyone working in the shop needs one.

It is particularly the people with direct day-to-day responsibility for that young person whose role needs reviewing.

16 and 17-year-old volunteers – an area needing more clarification

This was one of the main grey areas in the session.

A DBS check can be requested for somebody from the age of 16.

However, Oliver explained that whether a 16 or 17-year-old is treated as a child for DBS eligibility purposes can depend on the context.

In particular, there can be different considerations when someone aged 16 or 17 is:

• in employment

• an apprentice

• in a workplace environment

• completing work experience

• volunteering

Oliver said there are some complexities around 16 and 17-year-olds in workplace-style environments and that Verifile would seek/provide further clarification and examples.

So don't take the session as providing a blanket rule for every 16–17-year-old volunteer situation.

The individual role and context need to be assessed.

Work experience and student placements

Oliver also highlighted that the DBS definition of a volunteer does not necessarily include:

• work experience

• student trainees

• student teachers

• student placements

Those checks may therefore be treated differently from a genuine volunteer check and may be chargeable rather than processed as volunteer applications.

School visits and awareness talks

One example was charity ambassadors going into schools to deliver awareness sessions.

If giving talks, instruction or guidance to children is part of the volunteer's role, they may be eligible for an Enhanced DBS.

The frequency then matters.

For example:

Four days or more within any 30-day period:
Enhanced DBS + Children’s Barred List may be appropriate.

At least once but below the frequency threshold:
Enhanced DBS for the child workforce without the Children’s Barred List may be appropriate.

The fact that a teacher or DBS-checked staff member is in the classroom will no longer create the same supervision exemption after 1 September.

Fundraising events and children's activities

Another example was volunteers at fundraising events helping children with activities such as:

• games

• crafts

• biscuit decorating

• other children's activities

If the volunteer's role actually involves directly working with the children, Oliver said an Enhanced DBS may be appropriate.

Again:

Frequent activity → potentially Enhanced + Children’s Barred List

Infrequent activity → potentially Enhanced child workforce without the Barred List

But if somebody is simply running a general fundraising stall where children may happen to attend, that is different.

Incidental interaction with children does not automatically make the role eligible for Enhanced DBS.

Mascots

The example of volunteers dressing up as a charity mascot was also discussed.

Previously, organisations may have relied on the fact that the mascot was accompanied or supervised by another person.

From 1 September, that supervision alone will not necessarily remove eligibility.

If the mascot volunteer is genuinely working directly with children as part of their role, the role may need to be assessed for Enhanced DBS eligibility.

Frequency would then determine whether a Children’s Barred List check is appropriate.

Online helplines, chats and moderation

The rules are not limited to face-to-face volunteering.

Oliver confirmed that online roles can potentially qualify too.

This could include volunteers:

• providing children with advice or guidance online

• supporting children through a helpline

• communicating through online chat

• moderating an online space used by children

• having rights to add or remove information within certain online communication systems

If this forms part of the role, Enhanced DBS eligibility should be considered.

Conservation activities / working alongside young people

One example involved adult conservation volunteers working alongside Duke of Edinburgh students aged 14+.

Oliver's distinction was useful:

Working alongside or in the vicinity of children is not automatically the same as working with them.

If the adult volunteer isn't:

• supervising

• teaching

• instructing

• caring for

• advising

• managing

the young people, Oliver said the role would not automatically qualify for an Enhanced DBS simply because young people were also volunteering nearby.

Competitions and sporting activities

A question was raised about volunteers such as:

• judges

• belayers

• officials

• competition volunteers

working at events involving children.

The key question is what the person is actually doing.

If the role can reasonably be described as:

• supervising children

• keeping them safe

• instructing them

• advising or guiding them

then it could potentially qualify for an Enhanced DBS check.

This was another area where Oliver stressed that organisations need to be really clear about the actual duties in the role description.

Healthcare and personal care

Healthcare and personal care have their own eligibility rules.

Oliver explained that providing healthcare or personal care can qualify for the relevant Enhanced DBS and Barred List check even where the activity only happens once.

This means organisations shouldn't simply apply the general "four days in 30" rule to healthcare or personal care roles.

A healthcare setting itself doesn't automatically mean everybody working there needs the highest level of check.

For example, somebody based in a hospital who isn't actually providing healthcare may fall under a different DBS eligibility route.

What about adults?

The change discussed in this session is specifically about the supervision exemption for work with children.

Oliver said the change does not introduce an equivalent new supervision rule for the adult workforce.

Existing eligibility rules around regulated activity with adults continue to apply.

Does this affect Northern Ireland?

Oliver said Verifile had checked this and confirmed that the corresponding changes also affect AccessNI.

Organisations operating in Northern Ireland should therefore review their roles too.

Existing volunteers – do we need to run new DBS checks?

This was one of the biggest practical questions.

Oliver's advice was to review your existing roles.

Some volunteers may currently have:

Enhanced DBS without Children’s Barred List

because the person was supervised.

After 1 September, that same role may qualify for:

Enhanced DBS + Children’s Barred List

Oliver said organisations should consider rerunning checks where the eligibility of the role has changed.

However, he also explained that the decision about rerunning existing checks sits with the organisation.

For new applications after 1 September, checks should definitely be requested using the correct eligibility under the new rules.

Can we start the new checks before 1 September?

No.

Oliver explained that the new level of disclosure cannot be requested under the new rules until the changes come into force on:

1 September 2026

If someone urgently needs a DBS before then, the check has to be processed under the current legislation.

This could mean:

1. completing the appropriate check now under the existing rules; and

2. potentially completing another check after 1 September if the role then becomes eligible for a Children’s Barred List check.

Some organisations are therefore choosing to wait until after 1 September where practical.

What should organisations do now?

Oliver recommended that organisations use the change as an opportunity to review their DBS processes.

1. Review your current volunteer and staff roles

Look particularly at roles involving children where you previously relied on supervision.

2. Review what each role actually involves

Ask:

• Does the person teach children?

• Train them?

• Give instructions?

• Supervise them?

• Care for them?

• Give advice or guidance?

• Provide healthcare or personal care?

• Work with children online?

• Directly manage young volunteers?

3. Check the frequency

Don't just look at an average month.

Consider whether the activity could happen four days or more within any 30-day period.

4. Update your role descriptions

Make sure job and volunteer role descriptions accurately describe the person's contact with children.

This makes DBS eligibility decisions much easier to justify.

5. Update recruitment and safeguarding processes

Make sure the correct check is built into onboarding for each role.

6. Train staff who request DBS checks

People responsible for recruitment and onboarding should understand the difference between:

• Basic

• Standard

• Enhanced

• Enhanced + Children’s Barred List

7. Keep a record of your decision

Oliver recommended keeping clear records explaining why a particular level of DBS check was requested.

This is particularly useful where the role falls into a grey area.

Basic DBS checks

A Basic DBS check can be requested for anybody and shows unspent convictions and conditional cautions.

Oliver said Verifile generally recommends considering a Basic DBS where somebody isn't eligible for a Standard or Enhanced check.

However, this was a Verifile recommendation from the session, rather than part of the specific 1 September supervision change.

The important point is that organisations cannot simply request an Enhanced DBS because they would prefer one — the role must actually meet the eligibility criteria.

Standard DBS checks

Standard DBS checks came up much less during the session.

Oliver explained that they apply to specific eligible occupations and activities rather than acting as a halfway point between Basic and Enhanced.

For most of the children's volunteering scenarios discussed during the webinar, the decision was more likely to be between:

Basic DBS

or

Enhanced DBS / Enhanced DBS + Children’s Barred List

depending on the role.

The DBS Update Service

The DBS Update Service was raised during the Q&A.

Oliver explained that this is operated directly through the DBS and is not a service Verifile itself provides.

Whether an organisation accepts an existing DBS certificate or uses the Update Service is something the organisation will need to decide in line with its safeguarding and recruitment policies.

One really important distinction

Don't ask:

"Will this volunteer ever come into contact with a child?"

That test would capture huge numbers of completely unrelated roles.

Instead ask:

"Is working with children actually part of what we expect this person to do?"

Then look at:

• what activity they carry out

• who they are working with

• how frequently they do it

• the setting

• whether any other DBS eligibility route applies

That distinction came up repeatedly throughout the session.

Areas where further clarification is still needed

Not every question had a completely black-and-white answer.

In particular, further clarification was discussed around:

16 and 17-year-olds in workplace-style volunteering

The treatment of 16 and 17-year-olds can differ depending on whether the activity is employment, an apprenticeship, work experience or volunteering.

Verifile said they would provide more examples/clarification.

Roles where "supervision" is difficult to define

For example:

• sports judges

• belayers

• event officials

• museum floor volunteers

• people providing occasional support at activities

Organisations will need to look carefully at what the role actually requires rather than relying solely on the role title.

Ad-hoc parents helping at events

Where somebody isn't yet formally volunteering or working for the organisation, there may not be a basis to request an Enhanced DBS immediately.

Oliver said these situations also become a safeguarding decision for the organisation, particularly where parents are recruited to help on the day.

The biggest takeaway

The change isn't:

"Everybody who is around children now needs an Enhanced DBS."

The change is:

"If someone is carrying out an eligible activity with children, being supervised will no longer automatically prevent that activity from being regulated activity."

So the best thing organisations can do now is review roles rather than people.

Look at what each role actually does, how often it happens and whether your previous DBS decision relied on the fact that the person was supervised.

Please note

These notes summarise the guidance shared by Oliver Jones from Verifile during the Volunteero DBS session.

They are designed to make the session easier to understand and shouldn't replace an individual DBS eligibility assessment. Some scenarios depend heavily on the exact duties, frequency and context of a role, and several grey areas discussed during the session require case-by-case assessment or further clarification.