Enhanced DBS Check with Barred List Check
Last updated:Barred List information is not routinely provided in an Enhanced Check and can only be requested for those positions or activities listed under the definition of regulated activity in the Safeguarding Vulnerable Groups Act 2006 (as amended by the Protection of Freedoms Act in 2012).
An Enhanced DBS Check with Barred ListCheck (either Children or Adults or Children and Adults) searches against criminal records and other sources, including the PNC. The check may reveal convictions, cautions, reprimands and warnings and includes a check of whether the individual is barred from working with Children, Adults or both) depending on the appropriate workforce.
Definitions of Regulated Activity
Children and Young People
Work of a specified nature which involves close contact with children which occurs frequently/regularly in a specified place.
- Specified role/work e.g. a Teacher, Learning Support Assistant, Midday Supervisor
- Specified nature e.g. teaching, training, care, supervision, advice, treatment
- Close work which involves close proximity to a child and allows the possibility of a relationship to be built (including online)
- Frequency: On more than 3 days in a 30-day period or overnight
- Specified place e.g. a school, youth club, care home
The changes to regulated activity with children will take effect from 1 September 2026, and the previous guidance regarding supervised roles being eligible for an Enhanced DBS Check without a Children's Barred List Check will no longer applicable for many roles (Change to the definition of regulated activity with children from 1 September 2026 - GOV.UK)
Before 1 September 2026
- Individuals who taught, trained, instructed, cared for, or supervised children could be excluded from regulated activity if they were sufficiently supervised by someone already in regulated activity.
- These roles were generally eligible for an Enhanced DBS check without a Children's Barred List check.
From 1 September 2026
- Supervision will no longer remove a role from regulated activity.
- If a person teaches, trains, instructs, cares for, or supervises children:
- More than 3 days in any 30-day period, or
- Overnight (between 2am and 6am),
they will be undertaking regulated activity with children, even if supervised.
- These roles will become eligible for an Enhanced DBS check with a Children's Barred List check.
Who is affected?
This change affects individuals who were previously excluded from regulated activity solely because they were supervised, including examples such as:
- School volunteers (for example, reading helpers supervised by a teacher).
- Assistant sports coaches supervised by a head coach.
- Staff and volunteers working in youth groups, charities, community organisations, or outdoor activity centres where they work with children under supervision.
Example 1 – weekly school reading volunteer
A parent volunteers at a primary school to listen to children read. They do this every Monday morning during term time. Because a teacher is always nearby and supervises them, the school decided that the parent is sufficiently supervised in line with the guidance set by the Department for Education (DfE) and asked the parent to apply for an Enhanced DBS check without a check of the Children’s Barred List.
Before 1 September 2026, the parent was not in regulated activity with children because a teacher supervised them. Following the legislation change, from 1st September 2026, the parent will be in regulated activity with children and will be able to get an Enhanced with Children’s Barred List check. The school should consider the guidance from DfE on these changes to ensure the volunteer is still suitable for the role.
Example 2 – monthly school art volunteer
Another parent volunteers once a month at the primary school to help with art activities. Again, a teacher is always present to supervise them. This parent is not in regulated activity with children because they are not carrying out the role often enough. The parent was asked to apply for an Enhanced DBS check without a Children’s Barred List check.
The school does not need to consider the supervision changes for this role as it is not being carried out often enough to be regulated activity with children.
Example 3 – music club volunteer
A volunteer helps at a community music club for children twice a week where lessons are given and children have the opportunity to play together. The main instructor is always there and supervises the volunteer.
Before 1 September 2026, the volunteer may not have been in regulated activity with children if the club decided that the main instructor supervised them sufficiently. From 1 September 2026, the volunteer will be in regulated activity with children because they instruct or supervise children often enough. The club should consider if the volunteer needs an Enhanced with Children’s Barred List DBS check.
Example 4 – outdoor activity centre
A paid activity instructor works at an outdoor activity centre. They lead climbing and canoeing sessions for different groups of school children 4 days a week. Teachers are present and a senior instructor always supervises the instructor’s work.
Before 1 September 2026, the instructor may not have been in regulated activity with children if the centre decided that the senior instructor supervised them sufficiently. From 1 September 2026, the instructor will be in regulated activity with children because they instruct children often enough. The centre should consider if the instructor needs an Enhanced with Children’s Barred List DBS check.
Adults
The definition of Regulated Activity relating to adults no longer labels adults as ‘vulnerable’. Instead, the definition identifies the activities which, if any adult requires them, lead to that adult being considered vulnerable at that particular time.
The focus is on the activities required by the adult and not on the setting received, nor on the personal characteristics or circumstances of the adult receiving the activities. There is no longer a requirement for a person to do the activities a certain number of times before they are engaging in Regulated Activity. Any time a person engages in the activities set out below, they are engaging in regulated activity.
There are six categories of people who will fall within the new definition of regulated activity (and so will anyone who provides day to day management or supervision of those people). A broad outline of these categories is set out below:
- The provision of health care by a health care professional, or by a person acting under the direction or supervision of a health care professional (such as a health care assistant in a hospital or care home)
- The provision of relevant personal care (washing, dressing, toilet, eating, drinking)
- The provision of social work or community care services by social workers to adults who are clients or potential clients
- The provision of assistance in relation to general household matters for an adult who needs that assistance because of age, illness or disability, (e.g. managing a person’s cash, paying bills or shopping for someone)
- Any relevant assistance in the conduct of an adult’s own affairs, (e.g. under an enduring power of attorney)
- Transportation in certain circumstances which is needed because of age, illness or disability, although the Government has pointed out that this will not include family and friends or taxi drivers
Examples:
1. A care assistant in a care home who cuts and files an adult’s nails as the adult cannot do it themselves, because, for example, they cannot see well enough, would be engaging in regulated activity.
2. A beauty therapist who attends a day care centre once a week and provides manicures for anyone who would like one, instead of for people who need them because of their age, illness or disability, is not engaging in regulated activity.
3. A volunteer who prepares and serves a meal to an adult in their own home (but does not feed the adult) is not engaging in regulated activity. To be engaged in regulated activity you must provide physical assistance to the person, for example spoon feeding that person, or you must be prompting and supervising (for example, prompting and supervising a person with dementia, because without it they would not eat), or you must be training or instructing (for example, teaching a person who has suffered a stroke to eat using adapted cutlery).
4. A health care assistant on a hospital ward who feeds an adult because they are too frail to feed themselves would be engaging in regulated activity.
5. A worker in a care home who reminds a person with dementia to eat their lunch, and ensures they do so is in regulated activity.
Summary
Any time a person engages in one of the activities above, a DBS check is required as regulated activity is being undertaken. - even if the activity occurs only once.
The requirement for a DBS check is based not on the characteristics of the adult but the activities being undertaken.