Enhanced DBS with a barred-list check & regulated activity
A barred-list check is the highest level of DBS check and is only available for roles that are “regulated activity”. Regulated activity with children and regulated activity with adults are defined separately, with separate barred lists. The 1 September 2026 change to regulated activity applies to children only.
The essentials
- A barred-list check is added to an Enhanced check and only for regulated activity.
- There are two barred lists: the Children’s Barred List and the Adults’ Barred List.
- From 1 September 2026 the supervision exemption for regulated activity with children was removed.
- The 2026 change is for children only — the adults framework is unchanged.
Regulated activity with children
Regulated activity with children broadly covers certain activities done with or for children (such as teaching, training, instructing, caring for or supervising children, or certain driving), work in specified establishments, and certain positions of responsibility — where the frequency or overnight conditions are met. Some activities, however, are regulated activity regardless of how often they happen: providing relevant personal care, and health care provided by or under the supervision of a health care professional, count even if carried out only once.
The 1 September 2026 change (supervision exemption removed)
Before September 2026, a role could fall outside regulated activity with children if the person was sufficiently supervised by someone who was themselves in regulated activity. From 1 September 2026 that supervision exemption was removed in England and Wales (with a corresponding change in Northern Ireland). As a result, a supervised role can now be regulated activity with children if it involves the relevant activities and meets the frequency or overnight conditions. [GOV.UK]
The frequency and overnight conditions
For the activities the conditions apply to, the work generally needs to be carried out frequently — more than three days in any 30-day period — or overnight (between 2am and 6am with the opportunity for face-to-face contact with children). Assess how often the duties actually happen, not just the contract type. [GOV.UK]
The frequency and overnight conditions do not apply to every activity. Providing relevant personal care, and health care provided by or under the supervision of a health care professional, are regulated activity with children even if carried out only once — frequency is not the test for those. Confirm the specific position against the official guidance before deciding.
| Activity with children | Is it regulated activity? |
|---|---|
| Teaching, training, instructing, caring for or supervising children | Only if carried out frequently (more than 3 days in any 30-day period) or overnight (2am–6am) |
| Driving a vehicle used only for children under formal arrangements | Only if the frequency condition is met |
| Relevant personal care (washing, dressing, toileting, eating) | Yes — even if done only once |
| Health care by or under the supervision of a health care professional | Yes — even if done only once |
Who may be affected by the change
Organisations should re-examine regular supervised roles that were previously treated as outside regulated activity — for example some school volunteers, assistant coaches, and staff or volunteers in youth, activity or community settings — and consider whether they now meet the definition and therefore may be eligible for an Enhanced check with a Children’s Barred List check. Confirm each role against the official guidance.
Regulated activity with adults
Regulated activity with adults is defined separately and focuses on the activity being provided to an adult who needs it, rather than on the setting. Official guidance broadly sets out these categories: providing health care; providing personal care; social work; assistance with a person’s cash, bills or shopping because of their age, illness or disability; assistance with a person’s own affairs (for example under a power of attorney); and conveying an adult because of their age, illness or disability in certain circumstances. Where a role involves one of these, it may be eligible for an Enhanced check with an Adults’ Barred List check. Confirm the exact scope against the official adults’ eligibility guidance. [GOV.UK]
Children vs adults: how the two frameworks compare
| Regulated activity with children | Regulated activity with adults | |
|---|---|---|
| What it turns on | Certain activities, specified places and positions | The activity provided to an adult who needs it — not the setting |
| Frequency test | Applies to most activities (more than 3 days in 30, or overnight); personal/health care count even once | None — carrying out any qualifying activity once is enough |
| 1 September 2026 change | Supervision exemption removed — supervised roles can now qualify | No change — adults were never subject to a supervision exemption |
| Barred list | Children’s Barred List | Adults’ Barred List |
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 →FAQs
What is a barred-list check?
It checks whether a person is on the DBS Children's Barred List and/or Adults' Barred List — the lists of people barred from working in regulated activity with those groups. A barred-list check is only available for roles that are regulated activity, added on top of an Enhanced check.
What changed on 1 September 2026?
The 'supervision exemption' was removed from the definition of regulated activity with children in England and Wales, with a corresponding change in Northern Ireland. Some supervised roles working with children can now be regulated activity if the frequency or overnight conditions are met. This change applies to children only — not to regulated activity with adults.
Did the 2026 change affect work with adults?
No. The September 2026 supervision change relates to regulated activity with children. Regulated activity with adults is defined separately and was not changed by it.
Related DBS guides
- DBS checks (hub)What a DBS check is, the Basic, Standard, Enhanced and Enhanced-with-barred-list levels, who is eligible, employer responsibilities and the 2026 regulated-activity change — a plain-English UK guide.
- Which DBS check do I need?Basic, Standard, Enhanced or Enhanced with a barred-list check? Eligibility depends on the role's actual duties, setting and regulated-activity status — not the job title. A UK employer guide.
- 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
- Change to the definition of regulated activity with children from 1 September 2026 — GOV.UK / Disclosure and Barring Service
- Eligibility for an Enhanced with Adults' Barred List DBS check — GOV.UK / Disclosure and Barring Service
- Eligibility for roles working with adults — GOV.UK / Disclosure and Barring Service
- DBS eligibility guidance — GOV.UK / Disclosure and Barring Service
- Check someone's criminal record — types of check you can make — GOV.UK
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.