Summary
- From 1 September 2026, the supervision exemption will be removed from regulated activity with children in England¹.
- This means volunteers who teach, train, instruct, care for or supervise children may need an enhanced DBS check with children’s barred list information, even if they are supervised, where the activity is carried out frequently or overnight.
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. From 1 September 2026, that exemption will no longer apply to volunteers in scope, so supervision will not remove the need for the relevant DBS check.
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:
| Scenario | Likely implication |
| A volunteer helps with reading sessions every week | May meet the frequency condition and require reassessment |
| A parent helps at an occasional parent teacher association event | Unlikely to be affected by this change |
| A volunteer supports an overnight school trip | Likely to fall within regulated activity and require an enhanced DBS check, subject to role eligibility |
| A volunteer works across several schools | Activity across settings may count towards the ‘more than 3 days in 30 days’ condition |
What should employers do before 1 September 2026?
Employers should review every volunteer role that involves contact with children and check whether it falls within regulated activity. They should then update recruitment, safeguarding, and DBS processes so they are ready before the new rule starts. It is also a good idea to train managers and safeguarding leads so they understand the change and can apply it consistently.
Your compliance checklist
- Identify all volunteer roles involving children
- Check which roles count as regulated activity
- Review whether any roles relied on the supervision exemption
- Confirm which roles will need an enhanced DBS check with children’s barred list information
- Update safeguarding and recruitment policies
- Brief managers, trustees, and safeguarding leads
- Inform affected volunteers early
- Allow time to complete any new DBS checks before 1 September 2026
- Keep records of decisions and role assessments
- Review processes again closer to the deadline
How can we help you prepare?
With the supervision exemption set to be removed, organisations should start reviewing affected volunteer roles now, not at the deadline. Experian’s background checking solutions can help you manage DBS checks more efficiently, apply consistent screening processes across teams and improve visibility of check progress from application to completion.
We can also help you strengthen your audit trail, reduce manual admin and support a smoother experience for volunteers. So whether you are updating policies, briefing managers or preparing for additional enhanced DBS checks, you can move forward with greater confidence, consistency and control.
Explore our options, or get in touch to find out how we can help you prepare for the deadline.
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