Volunteer DBS checks: what is changing?

9th Jul 2026

Author: Mohammed Balal

If your organisation relies on volunteers to work with children, a change coming into force on 1 September 2026 may affect the checks you need to carry out.

The change is most likely to be relevant to schools, childcare providers, charities, sports clubs, youth groups, community organisations and other groups that use volunteers in child-facing roles.

Not every volunteer will be affected, but some regular volunteers who were previously outside the scope of regulated activity because they were supervised may now fall within regulated activity and therefore require an enhanced DBS check with children’s barred list information.

Employment law specialist Mohammed Balal explains what is changing and what organisations should consider now.

Who is likely to be affected?

The change is most likely to affect organisations that regularly use volunteers in child-facing roles.

This may include:

• parent volunteers who regularly help in classrooms
• reading mentors
• volunteer sports coaches
• youth group leaders
• volunteers supporting after-school or holiday activities
• volunteers attending overnight trips or residential visits

A person helping at a one-off event or a non-overnight day trip may not meet the threshold. However, the position will depend on the role, how often the person volunteers and what they are actually doing.

This is why it is important to look at each role carefully rather than assuming that all volunteers fall into the same category.

What is changing?

At present, some unpaid volunteers who work with children may fall outside the definition of regulated activity if they are properly supervised by someone who is already in regulated activity.

From 1 September 2026, that supervision exemption will be removed.

This means that supervision will no longer prevent certain unpaid volunteer roles from being treated as regulated activity. If a volunteer teaches, trains, instructs, cares for or supervises children often enough to meet the relevant threshold, they may need an enhanced DBS check with children’s barred list information.

For these purposes, the period condition is met where the activity takes place on more than three days in a 30-day period or overnight (specifically overnight between 2am and 6am).

What this means for your organisation

If a volunteer is carrying out regulated activity with children, the organisation should ensure that appropriate checks are carried out to confirm they are not barred from working with children.

This is both a safeguarding issue and a legal compliance issue. Organisations need to understand which roles fall within regulated activity, what level of DBS check is appropriate and how those checks should be recorded.

For organisations that rely heavily on volunteers, the change may also affect how quickly new volunteers can start, who manages the onboarding process and how information is shared with safeguarding leads, trustees, governors, managers or committee members.

What should organisations do now?

Although the change does not take effect until September 2026, it would be sensible to start preparing now.

A useful first step is to review all volunteer roles involving children. You should consider what the volunteer does, how often they do it, whether the role involves overnight responsibility and whether the role currently relies on supervision to fall outside regulated activity.

You may also want to review:

• safeguarding policies
• safer recruitment procedures
• volunteer application forms
• induction and training processes
• DBS checking procedures
• record keeping
• communication with existing volunteers

Where volunteers work across more than one setting, that volunteers can join the Update Service without charge, which is specifically encouraged by the Department of Education.

Do occasional volunteers need an enhanced DBS check?

Occasional volunteers may not need an enhanced DBS check with children’s barred list information simply because they help from time to time.

For example, a parent helping at an occasional school event or a volunteer supporting a non-overnight day trip may not meet the threshold for regulated activity.

However, the position can change if the volunteering becomes regular, involves certain types of activity or includes overnight responsibility. Organisations should therefore keep volunteer roles under review, especially where informal help develops into a more regular arrangement.

How Butcher & Barlow can help

Advance notice of this change gives organisations time to prepare, but it should not be left until the final few weeks before September 2026.

Clear policies and careful role assessments can help you understand which volunteers may be affected and what steps you need to take. They can also help avoid confusion for staff, volunteers, parents, trustees and managers.

If your organisation works with children and relies on volunteers, Butcher & Barlow can help you review your policies, recruitment processes and safeguarding arrangements before the new rules come into force.

For advice, please contact our Employment Law Team. Mohammed can be contacted on 0161 764 4062 or by email on mbalal@butcher-barlow.co.uk

Information in this article was correct at the time of publication. The information is for general guidance only. Laws and regulations may change, and the applicability of legal principles can vary based on individual circumstances. Therefore, this content should not be construed as legal advice. We recommend that you consult with a qualified legal professional to obtain advice tailored to your specific situation. For personalised guidance, please contact us directly.