September's DBS rule changes: What Volunteer Managers need to know
Understanding changes to DBS rules for volunteer management
We know that changes to DBS rules can feel confusing, especially when you are managing volunteers and keeping children safe. This guide explains the change in simple terms, what it could mean for your organisation and the practical steps you can take. If you are unsure, Wirral CVS is here to help.
The rules on regulated activity with children changed on 1st September 2026. Organisations involving volunteers or other workers who teach, train, instruct, care for or supervise children should now review relevant roles and DBS checks. Supervision by another person no longer automatically keeps an otherwise qualifying role outside regulated activity.
In brief: Regular supervised volunteers may now be eligible for an Enhanced DBS check with a Children’s Barred List check. Not every volunteer needs a new check: decisions must be based on the activities, frequency and existing certificate for each role.
Wirral CVS can process DBS applications on behalf of organisations for suitable volunteer roles. If a volunteer position meets the eligibility criteria for a DBS check, we can support the organisation by managing the DBS application process and cover costs.
What changed?
The supervision exemption has been removed from the definition of regulated activity with children. This means a supervised role may now be regulated activity if the person carries out a qualifying activity often enough or overnight. The change applies in England and Wales as well as Northern Ireland, and it can affect both volunteers and paid workers.
Which activities are covered?
Teaching children
Training children
Instructing children
Caring for children
Supervising children
For these activities, the usual period condition is met when they take place on more than three days in any 30-day period, or overnight between 2am and 6am where the legal conditions are met. Always assess the actual duties, setting and frequency of each role.
Who may be affected?
The main group affected is people who were previously treated as being outside regulated activity because they were supervised. Examples may include regular reading helpers, assistant coaches, youth-group volunteers, activity helpers and volunteers supporting children in community or charity settings.
Example: A volunteer who listens to children read every week while a teacher is present may now be in regulated activity. A person helping at a one-off event or occasionally may not meet the frequency condition through that role alone. Do not assume that all volunteers need the same check.
What does this mean for DBS checks?
If a role is now regulated activity with children, it is eligible for an Enhanced DBS check with a Children’s Barred List check. This is important because a person on the Children’s Barred List must not carry out regulated activity with children, and an organisation must not knowingly allow this.
Review each role and the certificate already held. The organisation requesting a check remains responsible for confirming that the role is legally eligible for the level of check requested.
What volunteer managers should do now
Identify relevant roles. List volunteers and workers who teach, train, instruct, care for or supervise children.
Check frequency and/or overnight activity. Record how often the activity takes place and whether it includes the period between 2am and 6am.
Check why the role was previously outside regulated activity. Was this only because the person was supervised?
Review existing certificates. Check whether each certificate is Enhanced and whether it includes Children’s Barred List information.
Confirm eligibility. Decide which roles now meet the legal definition of regulated activity and what check can be requested.
Apply where necessary. Arrange any eligible new checks promptly and keep a clear record of your decision.
Update your procedures. Make sure role descriptions, recruitment, onboarding, safeguarding and DBS processes reflect the rule now in force.
How Wirral CVS can help
Wirral CVS can help volunteer managers understand how the change affects their roles. We offer practical advice and support and can apply for and process necessary volunteer DBS checks on your organisation's behalf. We can also help you review role descriptions, frequency, safeguarding arrangements and good volunteer-management practice.
Need help reviewing your volunteer roles or arranging DBS checks? email emma.griffiths@wcvs.org.uk (WCVS Volunteer Coordinator) or call 0151 433 3371.
Official guidance and useful links
This guide is general information, not legal advice. Use the official guidance and relevant sector guidance when deciding whether a role is regulated activity and which DBS check is legally available.
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