How it fits together
Do children’s activity clubs need a universal licence?
There is no single children’s club licence that settles every registration, safety and data-protection question. Start by describing the service you actually offer, rather than assuming a business name such as ‘sports club’ or ‘holiday camp’ determines the rules. Record the activities, ages, hours, premises, staffing and whether you are providing childcare alongside tuition.
This hub is an overview, not an exhaustive permissions checklist. The Ofsted and Department for Education guidance below applies to England. Scotland, Wales and Northern Ireland have their own childcare registration arrangements; DBS guidance also has territorial limits. Check the regulator for the nation where you operate and any activity-specific, venue or local requirements.
- Registration exemptions · Ofsted
- Out-of-school settings: safeguarding guidance for providers · Department for Education
Ofsted and childcare registration
In England, most childcare for children under eight requires registration unless an exemption applies. Activity-based tuition or coaching for children aged three and over can fall within specified exemptions, subject to conditions about the activity, age and duration; not every activity club is automatically exempt. A label such as ‘after-school club’ does not decide the outcome.
Compare your actual arrangements with Ofsted’s current exemptions guidance before making a registration decision. For example, a focused coaching session and a full-day mixed-activity holiday programme may need different assessments. If you cannot clearly identify an applicable exemption, ask Ofsted rather than treating this overview as a registration decision.
- Registration exemptions · Ofsted
Safeguarding arrangements
The Department for Education’s out-of-school settings guidance covers safeguarding and child protection, safe and suitable people, governance, and health and safety, including online safety where relevant. It is government guidance, not evidence that a club is approved or a substitute for requirements applying to registered childcare or other regulated provision.
As a practical starting point, identify who receives concerns, how staff report them and which local services to contact. Make collection arrangements and staff conduct expectations clear. Rehearse how a substitute instructor gets help. Safeguarding involves people and processes; keeping a register or buying software cannot establish that these arrangements are adequate.
- Out-of-school settings: safeguarding guidance for providers · Department for Education
DBS checks and the 1 September 2026 change
From 1 September 2026, the supervision exemption for relevant regulated activity with children was removed in England and Wales, with changes also applying in Northern Ireland. For relevant teaching, training, instruction, care or supervision, the DBS explanation includes work on more than three days in a 30-day period or once overnight between 2am and 6am. Supervision alone no longer keeps an otherwise qualifying role outside regulated activity.
Review paid and volunteer roles that previously relied on that exemption. A regularly supervised assistant coach may now be eligible for an Enhanced check with Children’s Barred List information. Record the actual duties and frequency, then check current eligibility and sector guidance. Only request the level of criminal-record information the role is legally eligible for; do not infer eligibility from a job title alone.
DBS explicitly says the change does not itself impose a new blanket requirement to obtain checks. Other sector requirements still matter, and it remains unlawful for a barred person to undertake regulated activity. Not every role involving children becomes regulated activity. Scotland uses Disclosure Scotland/PVG arrangements rather than treating DBS as a UK-wide system.
- DBS eligibility guidance · Disclosure and Barring Service
- Regulated activity with children: changes from 1 September 2026 · Disclosure and Barring Service
- September 2026 supervision changes: common misconceptions · Disclosure and Barring Service
Read DBS roles and 2026 changes
Back to the 8 checksChildren’s information and UK GDPR
Names, dates of birth, parent and emergency contacts, photographs, bookings and attendance can be personal information. The ICO explains that children merit specific protection. Identify what you collect, why you need it, who can access it and what you tell families. A useful practical step is to remove questions collected only because an old paper form included them.
You need an appropriate lawful basis for each processing purpose; consent is not automatically the right basis for everything. Health information, such as allergy or medical details, is special category data and needs an Article 9 condition as well as an Article 6 lawful basis. Do not assume an ordinary booking checkbox resolves those questions.
Review access, sharing, security, retention and rights procedures against current ICO guidance. Determine the responsibilities of your organisation and service providers for the actual processing involved. A booking platform can assist administration; using it does not establish GDPR compliance or settle controller/processor responsibilities.
- Children and the UK GDPR · Information Commissioner’s Office
- A guide to lawful basis · Information Commissioner’s Office
- What is special category data? · Information Commissioner’s Office
- A guide to the data protection principles · Information Commissioner’s Office
Health and safety
Identify the significant risks arising from your activities and decide proportionate controls. Think about your venue, equipment, arrivals and collection, as well as the activity itself. Record who checks equipment and what happens when conditions change, such as a different room or an outdoor session in poor weather.
Health and safety duties depend on the organisation and work involved. HSE has separate guidance for voluntary organisations; having volunteers does not justify assuming either that every employment duty applies or that safety can be ignored. Check the applicable duties and coordinate responsibilities with the venue. A venue’s assessment does not automatically cover your own activity.
- Managing risks and risk assessment at work · Health and Safety Executive
- Volunteering: how to manage the risks · Health and Safety Executive
First aid and emergency arrangements
Employers must assess first-aid needs and provide adequate and appropriate arrangements for employees. HSE explains that those first-aid regulations do not themselves impose provision for non-employees, but strongly recommends including them in the assessment. Childcare rules, sector requirements and contractual arrangements may impose additional expectations.
For a children’s club, investigate arrangements for the children as well as staff: available training, suitable equipment, an emergency phone, accurate contacts, relevant medical/care information and access for emergency services. Plan how you contact parents and arrange collection. Agree who calls for help and who supervises the rest of the group. Check what happens if the usual first-aider is absent; a certificate held by someone off-site does not describe your session’s actual cover.
- First aid: legislation and employers’ duties · Health and Safety Executive
Read first-aid coverage in our safety guide
Back to the 8 checksInsurance
Employers’ liability insurance is generally compulsory when you employ staff, subject to exemptions; GOV.UK sets out the requirement for at least £5 million cover with an authorised insurer. Check the exceptions and the status of people working for you instead of assuming that a small club or a volunteer label settles the issue.
HSE distinguishes employers’ liability from public liability insurance, which is generally voluntary rather than the same statutory duty. Venue contracts, governing bodies and particular activities may require cover. Ask an insurer or broker whether your policy covers your actual activities, participants, workers and locations, and check exclusions. Insurance does not replace safe working arrangements.
- Employers’ liability insurance · GOV.UK
- Employers’ liability insurance: a guide for employers · Health and Safety Executive
Read existing insurance overview
Back to the 8 checksPolicies and procedures
Turn your decisions into usable instructions. Use the checklist below as a set of possible areas to investigate and tailor; it is not a universal statutory list. The exact requirements vary with your provision. A template is a starting point, not evidence that staff know what to do or that all applicable duties are satisfied.
HSE explains that businesses must have a health and safety policy and, where there are five or more employees, write it down. Other written-policy requirements may arise from childcare registration, sector rules or contracts. Give each relevant procedure an owner and make sure temporary staff can find the instructions they need. Review policies against what happens in practice.
- Safeguarding and child protection, including reporting concerns
- Safer recruitment and staff/volunteer conduct
- Complaints and accountability
- Health and safety and emergency procedures
- Privacy and data protection
- Photography and media use
- Behaviour expectations
- Collection and non-collection of children
- Missing child procedures
- Online safety where relevant
- Out-of-school settings: safeguarding guidance for providers · Department for Education
- Prepare a health and safety policy · Health and Safety Executive
Read existing safeguarding policy coverage
Back to the 8 checksKeep your assessment under review
Compliance is an ongoing operating task. Revisit the official guidance when activities, ages, hours, staff roles, venues or data processing change. For example, extending a coaching session into all-day provision can affect a registration assessment, while changing a volunteer’s duties can affect DBS eligibility.
As good practice, keep a short record of the question, official source, decision, responsible person and next review point. Check that staff training, emergency information and insurance remain suitable. This hub and its linked guides help organise the questions; they do not issue a compliance verdict or replace advice on uncertain circumstances.
- Registration exemptions · Ofsted
- September 2026 supervision changes: common misconceptions · Disclosure and Barring Service
- Children and the UK GDPR · Information Commissioner’s Office