Volunteer DBS and Regulated Activity Changes

SSS Learning 1 min read
Volunteer DBS and Regulated Activity Changes feature image

Previously, a volunteer who was supervised by a member of staff engaged in regulated activity could fall outside the regulated activity definition, regardless of how often they volunteered. From 1 September 2026, that exemption no longer applies.

As a result, some volunteers who teach, train, instruct, care for or supervise children may now be undertaking regulated activity even when they are supervised. This means that some volunteers who previously did not require an enhanced DBS check with children's barred list information may require one from September 2026.

This change is significant because the children's barred list is not a criminal record. An individual can be barred from working with children following consideration by the Disclosure and Barring Service, even where there has been no criminal conviction. A person may therefore hold a clear enhanced DBS certificate but still be barred from working with children. Where an individual is undertaking regulated activity, schools have a legal entitlement to obtain children's barred list information as part of the DBS process.

At the time of writing, schools should continue to follow existing DBS eligibility requirements until 1 September 2026. Further implementation guidance may be issued by the Disclosure and Barring Service, the Department for Education and the Home Office before the changes come into force. Schools should ensure local procedures are updated in line with any published guidance.

What schools should do now

  • Review all volunteer roles involving contact with children.
  • Identify volunteers who teach, train, instruct, care for or supervise children on a regular basis.
  • Consider whether any volunteers support residential visits, overnight stays or other activities that may fall within the regulated activity definition.
  • Check the type of DBS certificate currently held by each volunteer and whether it includes children's barred list information.
  • Prepare records and application processes so any required checks can be submitted promptly after 1 September 2026.
  • Ensure that safeguarding leaders and senior leaders have oversight of the review process and maintain an audited record of decisions.
  • Follow updated statutory guidance, including Keeping Children Safe in Education and DBS eligibility guidance, when implementing the new requirements.

Who may be affected?

The changes are likely to affect a range of volunteer roles, including:

  • Classroom volunteers
  • Reading helpers
  • Mentors
  • Sports coaches
  • Educational visit volunteers
  • Volunteers supporting extracurricular activities
  • Volunteers involved in residential or overnight activities

Schools should begin planning now to ensure they understand which volunteer roles may be affected and can implement any necessary DBS and barred list checks from September 2026.

The removal of the supervision exemption represents one of the most significant changes to volunteer vetting arrangements for many years. Early preparation will help schools ensure compliance while continuing to benefit from the valuable contribution volunteers make to school life.

SSS Learning

24 June 2026