Disclosure Scotland has released an important update on the implementation of the Disclosure (Scotland) Act 2020, outlining significant changes to the Protecting Vulnerable Groups (PVG) Scheme that organisations should be aware of ahead of April 2026.
Most provisions of the Act came into force on 1 April 2025. Looking ahead, Disclosure Scotland has confirmed that from 1 April 2026, anyone joining the PVG Scheme will move to a five-year membership, replacing the current lifetime model. This membership will be tied to the type of regulated role an individual undertakes, and renewal will be required at the end of each five-year cycle.
Renewals will be completed separately from disclosure applications and will be carried out primarily online, with a paper-based option available where necessary. Importantly, Disclosure Scotland has confirmed there is no change to the current application process at this stage, and organisations should continue submitting PVG applications as normal.
Existing PVG members will transition to the new five-year model in phases from April 2026, with further details on the transitional arrangements to follow. Organisations are encouraged to begin preparing by keeping their PVG records accurate and up to date, including informing Disclosure Scotland when individuals leave regulated roles. Employers will also be notified at least three months before a linked member’s renewal date once the new system goes live.
DDC will continue to monitor these developments closely and provide updates to help organisations navigate the changes and maintain compliance. If you need support with managing PVG records or streamlining your safeguarding checks, our team is here to help.
