DBS checks for charities: decide by role, not by organisation

A charity can have trustees setting strategy, paid staff delivering services, volunteers running activities, shop workers selling donations and contractors maintaining a building. Their connection to the same charity does not give them identical DBS eligibility. The check that may be requested depends on the actual duties, the people served and the legal rules for the role. A sensible charity policy begins with a role assessment rather than a blanket instruction to obtain the highest available check for everyone.

This is particularly important for smaller charities. A volunteer who meets children every week, a trustee who never delivers a service and a fundraiser who works only with other adults are not one screening category. At the same time, a trustee or volunteer should not be overlooked simply because they are unpaid. A charity needs a process that is both protective and lawful.

The Charity Commission expects safeguarding to be a governance priority for charities in England and Wales. Its guidance for charities and trustees says trustees should assess the checks needed for each role and use DBS information alongside references, interviews and other evidence. The Disclosure and Barring Service has separate child and adult charity leaflets. These are the main sources for the decisions below. This article is an operational guide to applying them, not a substitute for the legal eligibility test.

First, separate safeguarding duties from access to a check

Every charity should think about risks to the people who encounter its work. That does not mean every role qualifies for a Standard, Enhanced or barred-list DBS check. The law limits access to those checks. DBS guidance says the role's actual day-to-day responsibilities, not a possible emergency task or a generous interpretation of a title, must support the application. The organisation must decide whether it is entitled to request the particular level.

The Charity Commission guidance uses different language for obligations and expected practice. It explains when “must” denotes a legal or regulatory requirement and when “should” describes good practice that the Commission expects trustees to follow. An editorial page should preserve that distinction. A charity may adopt a policy that calls for a check whenever a role is legally eligible, but that policy cannot create eligibility for an ineligible role. Nor should it imply a barred-list check is an optional extra that can be purchased for reassurance.

Start with a role description. Record the activities, beneficiaries, place of work, frequency, whether the work involves children or adults receiving specified services, and whether the worker has another position with different duties. Identify which DBS guidance route applies. If the answer is uncertain, seek specialist help before a high-level application is sent. The current DBS eligibility guidance explains the general structure; the charity-specific questions are addressed here.

Trustees of charities working with children

The DBS charity guidance says a trustee of a children's charity may be eligible for an Enhanced check in the child workforce. For that trustee role alone, it does not give access to the Children's Barred List. The leaflet defines a children's charity for this purpose by reference to charity workers or volunteers who perform regulated activity with children. That is more specific than saying a charity has children among its supporters or donors.

A trustee may also have a second role. Imagine a trustee who regularly teaches children as part of the charity's programme. The teaching duties need a separate assessment. If those duties meet the definition of regulated activity with children, the barred-list position may differ from that of a trustee who only attends board meetings. Record both roles accurately rather than assuming the board title either grants or blocks access to a barred-list check. The current DBS child charity leaflet explains that distinction.

The definition of regulated activity with children changed from 1 September 2026 in England and Wales when a supervision exemption was removed. Do not copy an older decision tree that treats supervision as an automatic exclusion. The activity and applicable period conditions still matter. A trustee with occasional contact at an event is not automatically in regulated activity because they belong to a children's charity.

Trustees of charities working with adults

The adult charity rules take a different route. The DBS adult charity leaflet, updated in September 2026, explains when trustees of charities whose workers or volunteers carry out qualifying work with adults may be eligible for an Enhanced check in the adult workforce. A trustee who personally carries out regulated activity with adults may be eligible for an Enhanced check with the Adults' Barred List for that additional role. The duties must be examined, and both positions should be correctly described in the application where relevant.

It is easy to overgeneralise from the phrase “adults at risk”. The adult check rules focus on specified services and activities, rather than a permanent label attached to a person. A charity that runs social events, offers advice, delivers personal care and transports people may have several distinct role types. Some activities may amount to regulated activity with adults. Others may support a different level or only a Basic check. Use the adult leaflet's stages to identify what the recipient is receiving and what the worker actually does.

This is also why the child and adult barred lists should not be treated as interchangeable. A children's charity trustee check cannot simply be reused to answer an adult-workforce question. Use the current DBS adult charity leaflet for the separate adult test.

Staff and volunteers who deliver services

For people delivering services, assess the tasks rather than the pay arrangement. The DBS charity guidance says the eligibility rules for a role can apply whether the person is paid or unpaid. A volunteer delivering personal care may meet a regulated-activity definition. A paid charity shop worker may not. The fact that an activity is described as charitable does not determine the level of check.

Consider a food-distribution charity. One volunteer packs parcels in a store room. Another visits people at home and provides support. A third transports adults because of age, illness or disability. These roles should not be bundled into one “volunteer DBS” category. The specific activities and the recipients' circumstances need to be tested against the DBS adult guidance. If the charity also works with children, perform the separate child assessment. The result could be different for each person, even if the same coordinator supervises them.

For work with children, the adult's contact, activity and frequency can matter. The 2026 change to the supervision exemption must be reflected in any new assessment. It is also important to identify work with 16 and 17 year olds in employment or work placements accurately. The DBS charity guidance includes a specific exception for people teaching, training, instructing, caring for or supervising a child aged 16 or 17 in employment. Do not treat every youth-facing role as the same type of regulated activity. When an unusual situation arises, use the current leaflet and underlying law instead of an oversimplified chart.

Charity shops, fundraising and office roles

The DBS leaflets give examples for charity retail. Working in a charity shop does not itself make a person eligible for a Standard or Enhanced check. Many retail roles can only be asked for a Basic check. Eligibility may differ when a worker performs specific additional services or activities for qualifying recipients, but the charity should be able to explain those duties precisely. Being trusted with donations or working under a charitable brand is not enough to assume barred-list access.

The same caution applies to general fundraising, finance and office roles. Some particular positions may have their own legal eligibility route, yet a generic office title is not a reason to submit an Enhanced application. If a person also delivers a programme, assess those duties separately. Keep the role description current. A move from office administration to regular delivery of children's activities may change the analysis, while a temporary possibility that someone might help in a crisis does not automatically justify checking at a higher level now.

Good safeguarding measures for roles without high-level DBS access still matter. Recruitment interviews, references, separation of duties, supervision, visitor controls and clear reporting routes may help manage risk. A Basic check can be considered where appropriate. The aim is to choose a lawful mix of safeguards, not to use DBS as the only measure of whether someone is suitable.

A free volunteer check is a separate question

There are two questions that can be confused. The first is whether the role is legally eligible for a Standard or Enhanced check. The second is whether the applicant meets the DBS definition of a volunteer for a free-of-charge application. Passing one test does not automatically pass the other.

The DBS adult charity leaflet explains that the volunteer definition involves spending time unpaid, apart from permitted expenses, doing something intended to benefit a third party rather than only a close relative. It also explains exclusions for certain work placements, courses and trainee arrangements. An applicant may be described as a volunteer by the charity yet fail the DBS free-check test. Only eligible Standard or Enhanced volunteer applications receive the DBS fee relief. A Registered Body or umbrella organisation may charge an administration fee even where the DBS fee is waived.

Ask the programme manager to document whether the role meets both tests before selecting the volunteer box on an application. If the answer is unclear, check the current DBS employer and volunteer guidance. This charity guide focuses on how a mixed charity workforce is assessed consistently.

A practical role matrix for a mixed charity

A role matrix prevents a single blanket rule from becoming embedded in recruitment forms. It can be as simple as the following, provided someone owns it and revisits it when duties change.

The matrix is a prompt to examine the facts, not a legal answer generator. Keep the full reasoning with the role record. When a programme changes, such as moving from supervised online contact to in-person activities, review the eligibility and safeguarding controls. Do not wait for the next recruitment round to discover that old job descriptions no longer describe the work.

Applying, viewing and retaining the result

A charity that is entitled to request a Standard or Enhanced check may submit it through its own DBS registration if it meets the registration conditions, or through a Registered Body acting as an umbrella organisation. The applicant cannot simply order a Standard or Enhanced check for any purpose. A Basic check has a different application route. The DBS employer guidance explains the application steps.

When the certificate is issued to the applicant, the charity should review it in the context of its recruitment policy and the role. A disclosed matter is not an automatic reason to reject a person unless a legal bar or other rule applies. The decision should be fair, consistent and focused on relevance. The DBS code of practice and Charity Commission guidance call for an ex-offender recruitment policy where DBS information is used. If an applicant disputes the certificate, use the official DBS dispute route rather than treating a challenge as misconduct.

Criminal-record information needs restricted access and a defined retention process. The DBS handling guidance is more nuanced than a rule that a copy can never be retained. It describes limited retention and circumstances linked to disputes or safeguarding audits. A charity should set a lawful, documented policy with its data-protection lead and any sector-specific requirements. The operational record can usually identify the date, level, workforce, position and decision without reproducing the certificate's detailed contents.

When a worker changes role or works for several charities

A certificate reflects a point in time and the role for which it was sought. If a worker begins a new activity, the charity should revisit the legal eligibility assessment and decide whether an existing certificate is suitable. The DBS Update Service can support status checks for subscribed Standard or Enhanced certificates when the conditions are met, including consent and an appropriate workforce and level. It is not a substitute for comparing the new role against the certificate. Basic checks are outside the Update Service.

If a volunteer works for several charities, each receiving organisation must decide whether it can rely on the available certificate or needs a fresh check. There is no automatic “volunteer passport” that makes the original decision bind every charity. The charity should record which role and evidence it accepted, who authorised the decision and when it will be reviewed.

The same principle applies when a trustee becomes a paid service manager or a shop volunteer begins visiting beneficiaries at home. Change in duties should trigger review. The trigger is the new work, not an invented statutory certificate expiry date. A charity may set its own recheck policy and must follow any relevant sector requirement, but should not describe a DBS certificate as automatically expiring after a fixed number of years.

Charities working overseas

A UK charity may send staff or volunteers abroad, recruit people who have lived abroad or make suitability decisions for work outside the UK. These situations need separate analysis. The DBS child and adult charity leaflets explain when a DBS check may be available for an overseas charity role if the suitability decision is made in England or Wales. They also warn that DBS cannot generally access criminal records held overseas. Foreign certificates of good conduct may need to be sought through country-specific processes.

This does not make the charity's own safeguarding duty disappear. Assess the activities and local context, identify which disclosure body has jurisdiction and check the current country route. If a document is unavailable, record the steps attempted, alternative evidence and the risk decision. The Home Office country guidance is the starting point for overseas evidence. Do not copy country tables into this charity page, because they change and would create duplicate maintenance.

What should the board see?

Trustees need assurance that role assessments are being done consistently without receiving unnecessary sensitive certificate detail. A periodic governance report could show the number of role types assessed, which ones require checks, overdue decisions, policy exceptions, training needs and significant safeguarding issues escalated through the proper route. It should not be a list of convictions or scanned certificates circulated with board papers.

The board should know who owns the role matrix, who confirms legal eligibility, how applicants are told about checks, who views certificates, how disputes are handled and when policies are reviewed. The Charity Commission says safeguarding policies should be reviewed as needed, after a serious incident and at least annually. If the charity expands into a new service, starts working with children or adults in a new way, or adds an overseas programme, bring the role and DBS decisions back to the board or delegated safeguarding lead.

For a small charity, these arrangements need not be elaborate. A clear role sheet, a named decision maker and a restricted record may be more reliable than a complicated form nobody maintains. For a larger group, the same principles can be applied across branches while leaving room for different service settings. Either way, an auditor should be able to see why a particular level was requested, not merely that “all volunteers have Enhanced DBS”.

How Complys can fit without overstating the product

Complys is not the DBS, a Registered Body or an umbrella body. It does not decide legal eligibility, run barred-list searches, submit applications or query the Update Service. Complys provides staff and volunteer document records with dates and reminders. These can help a charity organise reviews and evidence, subject to its own privacy and retention rules. The charity must still make its own source-backed decisions about DBS level, barred-list eligibility and the separate volunteer fee rule.

If your charity is reviewing its workforce evidence, start with the DBS eligibility guidance and the official child or adult charity leaflet. Then document the role-specific decision, including the separate free-volunteer question. The Complys charity compliance overview describes its record and reminder features. A software trial can test whether those features suit your workflow; the charity still owns the eligibility and safeguarding decisions.