DBS & safer recruitment

Regulated activity with children

Work with children is regulated activity when it involves certain specified activities, carried out frequently enough (or overnight) to meet the test. It is the trigger for an Enhanced check with the Children’s Barred List. From 1 September 2026 the supervision exemption has been removed — a change that brings some previously-exempt supervised roles into regulated activity.

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.

Important: Complys is not the Disclosure and Barring Service and is not a DBS Registered or Umbrella Body. We do not carry out DBS checks, issue certificates, or decide legal eligibility, and we are not endorsed by the DBS or the UK government. This page is general information to help you understand the rules and find the official guidance — employers and organisations remain responsible for confirming the correct, legally eligible level of check.
Change in force — 1 September 2026: the supervision exemption for regulated activity with children has been removed. [GOV.UK] Roles that relied on being “supervised” to sit outside regulated activity should be reassessed against the current definition. Do not apply the pre-September-2026 supervision rule to current roles.

The specified activities

Regulated activity with children covers specified kinds of work, including teaching, training, instructing, caring for or supervising children; providing advice or guidance on wellbeing; certain health care and personal care; driving a vehicle only for children; and day-to-day management or supervision of people doing those activities. [GOV.UK]Some of these count as regulated activity whatever the frequency; others rely on the frequency test below.

The frequency and overnight test

Where an activity relies on frequency, it is regulated activity if the person does it:

Three days or fewer in a 30-day period, and not overnight, does not meet the frequency test — although the role may still be eligible for an Enhanced check without a barred-list check, for example in a specified place such as a school. The frequency test decides the barred-list element, not whether any check is available.

Worked examples

The roleRegulated activity?Likely direction (confirm)
Teacher, in class most daysYes (frequency met)Enhanced + Children’s Barred List
Weekly sports coach, term-timeYes (more than 3 days / 30)Enhanced + Children’s Barred List
Supervised classroom volunteer (from 1 Sep 2026)Reassess — supervision no longer exemptsMay now be regulated activity; confirm
One-off school trip helperNot on frequency groundsMay be Enhanced without barred-list; confirm
Overnight residential activity leaderYes (overnight test)Enhanced + Children’s 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 →

Where Complys fits

Complys does not carry out DBS checks or decide eligibility. It helps you record the level and date of each worker’s check and keep review reminders, within the official handling rules. See related sector guidance for education and childcare.

FAQs

What is the frequency test for regulated activity with children?

For activities that rely on frequency, the role is regulated activity if the person carries it out more than three days in any 30-day period, or at any time between 2am and 6am with the opportunity for face-to-face contact (the overnight test). Some activities count as regulated activity whatever the frequency.

What changed on 1 September 2026?

The supervision exemption was removed. Before that date, some roles that would otherwise be regulated activity with children were treated as not regulated activity if the person was supervised to a required standard. From 1 September 2026 that exemption no longer applies, so some supervised roles that were previously outside regulated activity are now within it. Assess current roles against the current definition, not the old supervision rule.

Do one-off or occasional helpers count?

It depends on the activity. Where the frequency test applies, occasional help below the threshold (three days or fewer in 30 days, and not overnight) is not regulated activity on frequency grounds — though the role may still be eligible for an Enhanced check without a barred-list check, for example in a specified place such as a school. Some activities count from a single occurrence regardless of frequency.

Is working in a school automatically regulated activity?

No. Working in a specified place such as a school can make a role eligible for an Enhanced check, but that is not the same as regulated activity. Whether it is regulated activity depends on the actual duties and the frequency/overnight test. A role can be Enhanced-eligible in a school without the barred-list check that regulated activity adds.

Does supervision still matter at all?

Supervision no longer removes a role from regulated activity as a general exemption from 1 September 2026. It may still be relevant to how an organisation manages safeguarding and risk, but it should not be used to conclude a role is outside regulated activity. Confirm the current position against the official guidance.

Related DBS guides

Official sources and further guidance

  1. Regulated activity with children (DBS guidance leaflet) — GOV.UK / Disclosure and Barring Service
  2. Change to the definition of regulated activity with children from 1 September 2026 — GOV.UK / Disclosure and Barring Service
  3. Regulated activity: removal of the supervision exemption (in force 1 September 2026) — GOV.UK / Disclosure and Barring Service
  4. DBS eligibility guidance — GOV.UK / Disclosure and Barring Service
  5. 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.