From 1 September 2026, the Crime and Policing Act 2026 introduces changes to the definition of the DBS’s regulated activity by removing the volunteer supervision exemption.
Previously, unpaid volunteers carrying out activities such as teaching, training, caring for, or supervising children were not considered to be undertaking regulated activity if they were supervised by someone who was already engaged in regulated activity.
For example, this may affect the following scenarios involving:
- People who volunteer in schools, such as reading helpers who are supervised by a teacher.
- People who coach children’s sports clubs, such as assistant coaches that are supervised by a head coach.
- People who work or volunteer with children in outdoor activity centres, youth groups, charities or community groups, and are supervised by someone else who is in regulated activity with children.
Regardless of whether an individual is paid or unpaid, anyone carrying out teaching, training, instruction, care or supervision of children will be considered to be undertaking regulated activity if they:
- Carry out the activity frequently (on more than 3 days within a 30-day period).
- Meet the period condition by providing overnight (2am to 6am) care or supervision.
This applies regardless of whether another member of staff is present.
Employees who were already undertaking regulated activity with children will continue to require the same level of DBS checks. The main impact of these changes is on volunteers. They may now require an Enhanced DBS check with Children’s Barred List information.
Children’s Barred List:
Organisations must ensure that volunteers and staff who now fall within the definition of regulated activity are not barred from working with children.
Individuals are placed on the Children’s Barred List because they are considered to pose a risk to children. It is a criminal offence for a barred person to undertake regulated activity with children. It is also an offence for an organisation to knowingly allow a barred individual to do so.
Any person who becomes barred from working with children must inform the organisation immediately and stop undertaking any regulated activity.
Volunteers Working Across Multiple Schools or School Events:
Schools and colleges can obtain a standalone Children’s Barred List check through the Department for Education’s Check a Teacher’s Record service. This should only be used where:
- the individual will begin regulated activity before their DBS certificate has been received; or
- the school recently obtained an Enhanced DBS check without Children’s Barred List information, with no break in the individual’s service.
The frequency test applies across all settings. This means that if a individual teaches, trains, cares for, or supervises children at multiple schools, the days worked are combined when assessing the 3-day-in-30-day threshold.
For example, if a volunteer supports four different schools on one day each within a 30-day period. They will now be considered to be undertaking regulated activity and will require the appropriate DBS check.
Volunteers who provide supervision or care on overnight school trips will also be considered to be undertaking regulated activity because they meet the overnight (period) condition. These volunteers will therefore require an Enhanced DBS check with Children’s Barred List information before participating.
Parents who volunteer only occasionally do not usually require an Enhanced DBS check with Children’s Barred List information. This includes those helping on a school trip, at a PTA event, or during other occasional school activities.
This is unless they meet the frequency or overnight conditions for regulated activity. The school may wish to request an Enhanced DBS check with no barred list.
Next steps
Organisations should review their roles, activity, policies and processes in place and update appropriately. Organisations should also check if any person’s DBS certificate needs to be updated to the relevant level.
The change comes into effect from 1st September 2026.
Further information
Department for Education’s guidance on supervision in schools, colleges and childcare settings: Working or volunteering in regulated activity with children – GOV.UK
News article from The Disclosure and Barring Service: News Article.
