DBS checks in education & schools
Most people who work in a school regularly are in regulated activity with children and are eligible for an Enhanced check with the Children’s Barred List — but not everyone, and the 1 September 2026 change moved the line. This page shows the two ways a school role becomes regulated activity, what changed for supervised roles, and the checks schools must run beyond the DBS.
Two ways a school role becomes regulated activity
A role can be regulated activity with children through the activity (teaching, training, instructing, caring for or supervising children) when it is carried out frequently — more than three days in any 30-day period, or overnight — or through the place: working in a school (a “specified establishment”) with the opportunity for contact, again frequently. [GOV.UK] That second route is why a school cleaner or caretaker working most days can be in regulated activity even without teaching duties. Providing personal care or health care to a pupil is regulated activity even if done only once.
What changed on 1 September 2026
The “supervision exemption” was removed. [GOV.UK] Previously a supervised person could fall outside regulated activity even if they taught or supervised children often enough; now, if they meet the frequency or overnight conditions, they are in regulated activity even if supervised. The main group affected is volunteers — and every volunteer on an overnight school trip is now in regulated activity. Genuinely occasional helpers are not caught, because the frequency threshold still applies. [GOV.UK]
School role → duties → frequency → likely route
| Role | Basis | Likely route (confirm) |
|---|---|---|
| Teacher / teaching assistant | Teaches, cares for or supervises pupils | Regulated activity → Enhanced + Children’s Barred List |
| Caretaker, cleaner, catering, admin working at the school | Specified place + opportunity for contact, more than 3 days in 30 | Regulated activity → Enhanced + Children’s Barred List |
| Anyone giving a pupil personal or health care | Once is enough | Regulated activity → Enhanced + Children’s Barred List |
| Supervised volunteer (e.g. weekly reading helper) | Since 1 Sep 2026, if the frequency/overnight condition is met | Regulated activity → Enhanced + Children’s Barred List |
| Governor | A specified position (governance), not regulated activity | Enhanced without a barred-list check (unless also in regulated activity) |
| Genuinely one-off or occasional visitor/contractor | Below the frequency threshold | Not regulated activity — Enhanced without barred list or lower. Confirm. |
Worked examples
| The role | Likely direction (confirm) |
|---|---|
| Reading volunteer helping weekly, supervised | Since 1 Sep 2026 regulated activity → Enhanced + Children’s Barred List |
| School cleaner or caretaker working most days | Specified place → Enhanced + Children’s Barred List |
| Regular sports coach instructing pupils | Regulated activity → Enhanced + Children’s Barred List |
| Office administrator | Enhanced; barred-list check if the specified-place conditions are met — confirm |
| Volunteer on an overnight residential trip | Overnight → regulated activity → Enhanced + Children’s Barred List |
| One-off visiting speaker | Not regulated activity → lower level. Confirm. |
Checks schools must run beyond the DBS
A DBS check is not the whole picture in education. In its safer-recruitment part (Part 3), Keeping Children Safe in Education requires schools to make additional checks alongside the appropriate DBS check: the teacher prohibition check for those in teaching work, and, for management or governance positions in academies and independent schools, a section 128 direction check. A barred-list check is added only where the person is in regulated activity. [GOV.UK] Record all of these in your single central record, not just the DBS.
Not sure which level applies?
Our free DBS eligibility guidance checker walks you through the official criteria and points you to the guidance to confirm against. It is guidance, not a legal determination.
Open the DBS eligibility checker →Where Complys fits
Complys does not carry out DBS checks. For schools and trusts it helps hold the record that each check was done, its level and date, and the other safer-recruitment evidence and reminders in one place — within the official handling rules (see DBS record keeping & compliance). See also Complys for education.
FAQs
Does every person who works at a school need the same DBS check?
No. Staff who teach, care for or supervise pupils, and other staff who work at the school often enough to have the opportunity for contact, are usually in regulated activity and get an Enhanced check with the Children's Barred List. A genuinely one-off or occasional visitor, or a governor (a specified position, not regulated activity), may be eligible for an Enhanced check without the barred-list check. Assess the actual role.
How did the 1 September 2026 change affect schools?
It removed the 'supervision exemption'. Before, a supervised role could fall outside regulated activity even if it involved teaching, caring for or supervising children frequently. From 1 September 2026 that no longer applies, so supervised staff and volunteers who meet the frequency or overnight conditions are now in regulated activity — and all volunteers on an overnight school trip are in regulated activity. Genuinely occasional parent helpers are not caught, because the frequency threshold still has to be met.
Related DBS guides
- DBS for childcare & early yearsHow DBS and suitability checks work for nurseries, childminders and early-years staff: registered childcare as regulated activity, Ofsted or agency suitability, household checks for childminders, and how the 2026 change affects assistants and volunteers.
- Enhanced with barred list & regulated activityWhen a role needs an Enhanced DBS check with a children's or adults' barred-list check, what regulated activity means for each, and the 1 September 2026 change to regulated activity with children.
- DBS eligibility guidance checkerA free guided tool that helps UK employers work out which official DBS eligibility guidance to review for a role. Guidance only — it does not make a legal eligibility determination.
Official sources and further guidance
- Regulated activity with children (DBS guidance leaflet) — GOV.UK / Disclosure and Barring Service
- Change to the definition of regulated activity with children from 1 September 2026 — GOV.UK / Disclosure and Barring Service
- Regulated activity: removal of the supervision exemption (in force 1 September 2026) — GOV.UK / Disclosure and Barring Service
- Keeping children safe in education (statutory guidance for schools and colleges) — GOV.UK / Department for Education
- DBS eligibility guidance — GOV.UK / Disclosure and Barring Service
This guidance is maintained by the Complys team and reviewed against the primary DBS / GOV.UK sources listed above (last reviewed 24 September 2026). It is general information, not legal advice, and DBS rules can change — always confirm against the official sources.