DBS checks for volunteers: what employers need to do from September 2026

What is the DBS supervision exemption?

The supervision exemption meant that some people carrying out certain child related activities did not fall within regulated activity if they were properly supervised.

In other words, the law treated supervised activity differently from unsupervised regulated activity.

That changed on 1 September 2026. The supervision exemption no longer applies to volunteers in scope, so being supervised does not in itself remove a volunteer role from regulated activity.

Why does this matter for you?

This change matters because it helps close a gap in safeguarding checks for roles involving children. Under the previous rules, some individuals could carry out child related activities without being classed as engaging in regulated activity, provided they were supervised. Removing the supervision exemption means organisations will need to assess more volunteer roles consistently and ensure that eligible individuals receive the appropriate level of DBS check, including a children’s barred list check where required.

For employers, charities, schools, clubs and other organisations that rely on volunteers, the change supports a clearer and more consistent approach to safer recruitment, helping to strengthen safeguarding processes and reduce uncertainty around who should be checked.

Who is affected?

The main group affected is volunteers carrying out regulated activity with children. If a volunteer role falls within the regulated activity rules, it may now require an enhanced DBS check with children’s barred list information, even if the person is supervised. Employers, volunteer managers, charities, schools, sports clubs, and other organisations using volunteers should review their roles carefully.

What checks may now be needed?

Depending on the role, organisations may now need:

• An enhanced DBS check
• Children’s barred list information
• Updated safeguarding checks as part of recruitment and ongoing oversight

The exact check needed will depend on the type of work involved and whether the role is classed as regulated activity.

What are some example scenarios?

Let’s have a look at some examples where a volunteer may or may not require additional checks:

What should employers do now?

Now that the new rules are in force, employers should review every volunteer role that involves contact with children and check whether it falls within regulated activity. Where a role is now considered regulated activity, organisations should ensure the appropriate DBS and barred list checks are in place.

It is also important to make sure recruitment and safeguarding policies have been updated and that managers, trustees and safeguarding leads understand how the rules apply. This is particularly important for organisations with large volunteer populations or volunteers working across multiple settings.

Your compliance checklist

• Identify all volunteer roles involving children
• Check which roles now count as regulated activity
• Identify roles that previously relied on the supervision exemption
• Confirm which roles require an enhanced DBS check with children’s barred list information
• Make sure the appropriate checks have been completed for affected volunteers
• Update safeguarding and recruitment policies to reflect the new rules
• Brief managers, trustees and safeguarding leads
• Make sure affected volunteers understand what the change means for their role
• Keep clear records of decisions and role assessments
• Build regular reviews into your safeguarding and recruitment processes

If your organisation has not yet completed these steps, it is important to review affected roles as soon as possible.