Volunteer DBS Checks Are Changing: What Organisations Need to Know From September 2026

If your organisation relies on volunteers to work with children, there is an important safeguarding change coming into force on 1 September 2026 that you need to be aware of.

The Department for Education has confirmed that the supervision exemption for volunteers working with children is being removed. This means some volunteers who have previously been able to work with children without a DBS check will now require an Enhanced DBS check with Children's Barred List information.

The change is particularly important for organisations that recruit volunteers to support their activities and services for children and young people, including schools, childcare and holiday club providers, youth organisations, sports clubs, community groups and other settings where volunteers work with children.

What is changing?

Previously, some volunteers could work with children without being classed as undertaking "regulated activity" if they were appropriately supervised by someone who was already in regulated activity.

From 1 September 2026, that exemption is being removed.

This means that activities such as teaching, training, instructing, caring for or supervising children can now count as regulated activity when the volunteer carries them out:

• On more than 3 days in a 30-day period, or
• Overnight

If you currently recruit volunteers that support with these activities, the change means that they will now need an enhanced DBS check prior to being able to support your organisation.

Why does this matter to organisations recruiting volunteers?

For many organisations, the change won't mean that every volunteer suddenly needs a new DBS check.

Instead, it means you need to look carefully at what your volunteers actually do, how often they do it and whether they work with children overnight.

For example, a volunteer who comes into a school every week to listen to children read, support classroom activities or help with interventions may previously have relied on the supervision exemption. From September, if they volunteer on more than three days in a 30-day period, they will generally be undertaking regulated activity and will need the appropriate DBS check.

Another example could be a football coach who supports a team once a week, so four times a month. As above, it may have been avoidable to require them to have an enhanced DBS check as they were supervised by someone with an enhanced DBS check, however now they will need the appropriate check themselves to continue to volunteer their time and support.

The same principle applies to volunteers in other children's settings.

What about occasional volunteers?

This is an important distinction.

The change is not intended to mean that every parent, carer or occasional helper needs a Children's Barred List check.

For example, a parent who helps at an occasional PTA event or accompanies children on a non-overnight day trip will generally not be caught by the new requirements.

However, organisations should still consider their wider safeguarding responsibilities and may choose to request other types of DBS check where appropriate.

Overnight volunteering is different

One important change is around overnight activities.

Volunteers who help on overnight school trips will be now be classed as undertaking regulated activity and will therefore need an Enhanced DBS check with Children's Barred List information.

This means organisations planning residential trips, camps or other overnight activities should make sure they identify this requirement well in advance.

What if a volunteer helps more than one organisation?

The rules also take account of volunteering across different settings.

For the "more than 3 days in a 30-day period" test, each relevant day counts - even if the volunteering takes place within different settings.

For example, someone who volunteers at four different schools on four separate days during the same 30-day period could meet the threshold for regulated activity.

The Department for Education encourages organisations to work together where appropriate to avoid unnecessary duplication of DBS checks. Volunteers can also consider joining the DBS Update Service, which can make it easier for organisations to check whether an existing certificate remains current.

What should organisations do now?

With the change coming into force on 1 September, now is a good time to review your volunteer agreements and policies.

1. Review your volunteer roles

Don't just look at job titles or role descriptions. Consider what your volunteers actually do:

• Do they teach, train, instruct, care for or supervise children?
• How frequently do they volunteer?
• Will they volunteer more than three days in a 30-day period?
• Do they take part in overnight activities?
• Are they currently relying on the supervision exemption?

2. Audit existing DBS checks

Make a record of what DBS checks your existing volunteers already have, if any.

Identify volunteers whose role will be considered a regulated activity from September and determine whether they need an Enhanced DBS check with Children's Barred List information.

3. Review your recruitment process

Make sure your volunteer recruitment process clearly explains any DBS requirements.

It is also worth checking your volunteer application forms, safeguarding procedures, volunteer policies and induction materials so that they reflect the updated Act.

4. Plan ahead for residential activities

If your organisation runs residential trips, camps or other overnight activities involving children, it's worth reviewing your volunteer arrangements now.

The overnight provision is particularly important because volunteers involved in these activities will be in regulated activity.

5. Supervised no longer means "no DBS required"

From September, simply having a member of staff supervising a volunteer will no longer automatically mean that the volunteer is outside regulated activity.

The focus is now on the nature, frequency and timing of the volunteer's role, rather than simply whether they are supervised.

6. Allow time for the changes to happen

Start planning now, rather than waiting for the change on the 1st September. 

Enhanced checks can take up to 12 weeks and with an influx of applications this time may increase. If your services and support for children and young people rely on volunteers, take action now to limit the impact to your organisation and service users.

What does this mean for volunteers?

For volunteers, the change shouldn't be seen as a barrier to supporting your chosen organisation. In fact, the DBS check for volunteers undertaking regulated activity is free of charge.

The purpose of the change is to strengthen safeguarding and putting children's safety and care at the forefront of volunteer activity.

Organisations should therefore communicate the change positively and clearly.

Volunteers may have questions about why a check is now required when one wasn't previously necessary, particularly if they have been volunteering for some time.

A simple explanation is that the rules are changing, rather than there being a concern about the individual volunteer.

Volunteers are hugely important to organisations working with children.

The removal of the supervision exemption doesn't mean that organisations need to stop using volunteers, it simply means that organisations need to be clear about which volunteer roles constitute regulated activity and make sure the appropriate checks are in place.

If your organisation relies on volunteers, don't wait until September for the changes to take place to review your processes. Start by identifying which volunteers work with children regularly or overnight, check what DBS arrangements are already in place and make sure your recruitment and safeguarding processes are ready for when the change happens and you can limit the impact the change will have on your services.

This article is based on Department for Education guidance published on GOV.UK. The guidance applies to England. Organisations should refer to the latest official guidance when making decisions about individual roles.