Volunteers are no longer 'low risk': what the September 2026 regulated activity change means for faith organisations

A significant change to safeguarding law lands on 1 September 2026, and every faith organisation that involves volunteers with children needs to understand it. In short: the "supervision exemption" is being removed from the definition of regulated activity with children. It sounds technical. It isn't. Underneath the legal language is a real shift in thinking — a recognition that a supervised volunteer is not automatically low risk, and that supervision alone is not a substitute for proper checks. This article explains what's changing, why it matters for faith communities, and the practical steps to take before the deadline. It is general information, not advice — take guidance from your denominational or faith safeguarding body on your specific setting.

What was the "supervision exemption"?

Until now, there has been a carve-out in the law. If a volunteer carried out activities that would normally be regulated activity with children — teaching, training, instructing, caring for, or supervising them — but was themselves supervised (to a reasonable, day-to-day degree) by someone who was in regulated activity, then that volunteer was not treated as being in regulated activity.

The practical consequence was important: because they weren't in regulated activity, those supervised volunteers could not have an enhanced DBS check with the children's barred list — the check that reveals whether someone has been formally barred from working with children. The logic was that supervision made them lower risk. Many faith organisations relied on exactly this reasoning: "our helper is supervised by the group leader, so they don't need a barred-list check."

What's changing on 1 September 2026

The Crime and Policing Act 2026 removes that exemption. From 1 September 2026 (the current rules apply until 31 August 2026), being supervised no longer takes a volunteer out of regulated activity.

From that date, if a volunteer carries out those activities with children:

• frequently — meaning once a week or more, or
• on more than three days in any 30-day period, or
• overnight (between 2am and 6am),

then they are in regulated activity — regardless of whether they are supervised. And that means they become eligible for, and should have, an enhanced DBS check with children's barred list information.

Crucially, it becomes possible — and expected — to run the barred list check on these volunteers. If someone is on the children's barred list, it is a criminal offence for them to engage in regulated activity, and for an organisation to knowingly allow it. A barred person currently volunteering in a supervised role must stop. That is the heart of the change: the door that let barred individuals into supervised volunteer roles unchecked is being closed.

Why this matters so much for faith communities

Faith-based organisations are among the biggest volunteer movements in the country, and much of that energy goes into children and young people:

• Sunday schools, junior church and children's groups
• Mosque and madrasah classes, and supplementary schools
• Youth clubs, choirs and music groups
• Holiday clubs, camps and residentials
• Toddler and parent-and-child groups, tutoring and mentoring

A great deal of this work is done by supervised volunteers — the willing helper alongside the lead worker. Under the old rules, many of those helpers sat outside regulated activity and were never barred-list checked. From September, many of them will be inside it. For a lot of faith communities, this means a meaningful number of volunteers who previously "just helped out" will now need enhanced DBS checks with the barred list.

This is also a shift in culture, not just paperwork. The old model quietly treated supervised volunteers as low risk. The new one recognises what safeguarding experience has taught painfully: that harm is often done by trusted, familiar people, and that supervision is a safeguard — but not the only one, and not a reason to skip checks.

Who is not caught by this

The change is proportionate, and it does not sweep in every helper:

• Parents and carers helping occasionally — for example at a one-off event — are not brought into regulated activity.
• Genuinely occasional or one-off help that doesn't meet the "frequently / more than three days / overnight" thresholds is not caught.

So the question to ask of each role is simple: does this person do this activity with children frequently, or does it meet the period condition? If yes, they are now in regulated activity.

What to do before September

Don't panic — but don't leave it. A calm, methodical review now will save a scramble later:

1. Map your children's and youth activities and list everyone who volunteers with them.
2. Identify who is now in regulated activity under the new rules — the frequency and period tests above are the key.
3. Arrange enhanced DBS checks with the children's barred list for those volunteers. Remember: DBS checks for volunteers are free of charge — cost is not a reason to delay.
4. Update your safer recruitment and safeguarding policies to reflect the change, and make sure your DBS/safer-recruitment lead understands it (this builds on keeping your safeguarding robust and your approach to DBS checks).
5. Talk to your denomination or faith safeguarding body — many (such as thirtyone:eight for Christian organisations, and denominational safeguarding teams) are issuing tailored guidance.
6. Keep the wider culture strong. Checks are necessary, not sufficient: good recruitment, induction, supervision, training and an open "it could happen here" culture all still matter (this connects to running youth clubs and being family-friendly well).

Don't over-correct, either

Two cautions. First, you still can't run a barred-list check on someone who genuinely isn't in regulated activity — doing so is unlawful, so apply the tests honestly rather than checking everyone reflexively. Second, this is a floor, not a ceiling: meeting the new legal minimum is not the same as being safe. The reform is an invitation to revisit your whole safeguarding culture, not just your paperwork.

The bottom line

From 1 September 2026, "they're only a supervised volunteer" is no longer a reason to skip a barred-list check. The removal of the supervision exemption reflects a hard-won truth: that supervision alone doesn't make someone low risk, and that the children in our care deserve the fuller protection that proper checks provide. For faith organisations — built on trust, and rich in willing volunteers — this is a moment to act promptly, check who is now covered, and treat the change not as red tape but as what it is: a strengthening of the duty of care we already hold.

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This article is general information, not advice. Safeguarding law is detailed and its application depends on your specific activities and setting — always check the current official guidance and take advice from your denominational or faith safeguarding body. If a barred person may be involved in your activities, act immediately and seek professional advice. For help getting the governance and policies around this right, get in touch.

Sources verified (July 2026):

• 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
• GOV.UK — Regulated activity with children in England and Wales (DBS guidance leaflet) — https://www.gov.uk/government/publications/dbs-guidance-leaflets/regulated-activity-with-children
• GOV.UK — Crime and Policing Act 2026: Independent Inquiry into Child Sexual Abuse recommendations factsheet — https://www.gov.uk/government/publications/crime-and-policing-act-2026-factsheets
• thirtyone:eight — Regulated activity timeline (safeguarding guidance for faith organisations) — https://thirtyoneeight.org/blogs/regulated-activity-timeline/