What DBS checks does your faith-based charity need for youth and vulnerable-adult work?

If your faith-based organisation runs a youth group, a supplementary or faith school, a luncheon club for older members, or any activity involving children or vulnerable adults, you will need to think carefully about background checks. Getting the level right is both a safeguarding duty and a legal one — ask for too little and you may leave people unprotected; ask for too much and you can fall foul of data-protection and rehabilitation-of-offenders rules.

This article explains the levels, the all-important concept of "regulated activity", how the rules differ across the UK, and a major change — in force from 1 September 2026 — that particularly affects faith communities.

First, the key idea: "regulated activity"

Almost everything about background checks turns on one concept. Regulated activity is a legal definition of the most sensitive kinds of work with children or with adults at risk — the work that unlocks the highest level of check. Broadly, it covers close, regular or intensive contact: teaching, training, instructing, caring for or supervising children; or providing personal care, healthcare, or certain assistance to vulnerable adults.

Whether a role counts as regulated activity drives which check you're legally allowed to request. You cannot simply choose the highest check for everyone — you must match the check to the role.

The four levels of DBS check (England and Wales)

In England and Wales, the Disclosure and Barring Service (DBS) issues four levels:

• Basic — shows unspent convictions only. Anyone can apply for their own. Suitable as a general check where no eligibility for higher levels exists.
• Standard — shows spent and unspent convictions, cautions, reprimands and warnings. Used for certain positions of trust.
• Enhanced — everything in a standard check, plus any local police information considered relevant to the role. This is the level commonly needed for roles working with children or vulnerable adults.
• Enhanced with barred-list check — the highest level. It adds a check against the children's barred list, the adults' barred list, or both. This is reserved for roles that meet the regulated activity definition.

The two barred lists are records of people legally prohibited from working with the relevant group. It is a criminal offence to employ someone in regulated activity who is on the barred list for that group — and an offence for a barred person to apply.

Most faith organisations running youth work or vulnerable-adult work will be looking at enhanced checks, with a barred-list check where the role is regulated activity. If you're unsure whether a specific role qualifies, use the official eligibility tool on GOV.UK rather than guessing.

Children and vulnerable adults are assessed differently

A subtle but important point: the two are defined differently. Children's regulated activity often depends on the frequency and nature of contact and whether it's supervised. Adults' regulated activity is defined more by the activity itself — providing personal care, for instance, can count even if done only once. Don't assume the rule that applies to your youth work also applies to your work with older or disabled members.

The UK is not one system — check your jurisdiction

This is where many UK-wide faith bodies slip up. The DBS covers England and Wales only. The equivalents are:

• Scotland — Disclosure Scotland, including the PVG (Protecting Vulnerable Groups) Scheme for regulated work.
• Northern Ireland — AccessNI.

The levels, terminology and rules differ. If your organisation operates across borders, you must satisfy the relevant scheme in each nation — a DBS check does not simply carry over.

A major change: the supervision exemption is being removed (from 1 September 2026)

This area has now moved decisively. What began as a proposal in the Crime and Policing Bill is now law: the Crime and Policing Act 2026 removes the "supervision exemption" from the definition of regulated activity with children, coming into force on 1 September 2026 (the position described above applies until 31 August 2026).

Until now, some roles where an adult works with children under supervision fell outside regulated activity — so those supervised volunteers could not have a barred-list check. From 1 September 2026, being supervised no longer takes a volunteer out of regulated activity: if they work with children frequently (once a week or more), on more than three days in any 30-day period, or overnight, they are in regulated activity and become eligible for — and should have — an enhanced check with the children's barred list.

This matters especially to faith communities, where a great deal of children's work is done by supervised volunteers who were never previously barred-list checked. It is a significant shift, not a technicality — we cover it in full, with a practical before-September checklist, in Volunteers are no longer 'low risk': what the September 2026 regulated activity change means for faith organisations.

A check is not a safeguarding policy

Finally, a background check is one tool, not a complete answer. It tells you about a person's record at a point in time; it does not replace references, safer-recruitment practices, induction, training, supervision and a culture where concerns can be raised. Certificates have no formal expiry, so most organisations set their own renewal cycle (commonly around every three years) and use the DBS Update Service to monitor changes between renewals. And remember the duty that runs the other way: if someone is removed from a regulated role because they pose a risk of harm, you may have a legal duty to refer them to the DBS.

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This article is general information, not advice. Rules and figures change and can depend on your circumstances. Check the current position with the DBS, Disclosure Scotland or AccessNI, your safeguarding lead, or get in touch and we'll help.

Sources verified (June 2026; regulated-activity change updated July 2026):

• GOV.UK, Regulated activity with children / adults and the DBS eligibility guidance — https://www.gov.uk/government/collections/dbs-eligibility-guidance
• GOV.UK, Types of DBS check — https://www.gov.uk/dbs-check-applicant-criminal-record
• GOV.UK, Regulated activity: removal of the supervision exemption (comes into force 1 September 2026) — https://www.gov.uk/government/publications/working-or-volunteering-in-regulated-activity-with-children/regulated-activity-removal-of-the-supervision-exemption-comes-into-force-1-september-2026
• Thirtyone:eight, Regulated activity timeline (safeguarding guidance for faith organisations) — https://thirtyoneeight.org/blogs/regulated-activity-timeline/
• Disclosure Scotland (PVG) — https://www.mygov.scot/pvg-scheme ; AccessNI — https://www.nidirect.gov.uk/campaigns/accessni-criminal-record-checks