DBS checks for children’s clubs: roles and the 2026 changes

Scope: children’s activity providers in England

This guide focuses on children’s clubs in England. DBS checking guidance also covers Wales; the sports guidance includes the Channel Islands and Isle of Man. Scotland uses Disclosure Scotland and Northern Ireland uses AccessNI. Do not assume the same application process applies throughout the UK.

The September supervision change also affects Wales and Northern Ireland, with separate Northern Ireland guidance. This page does not determine an individual role’s eligibility or replace sector-specific advice.

• DBS checks in sport: working with children · Disclosure and Barring Service
• Change to regulated activity with children from 1 September 2026 · Disclosure and Barring Service

Does every children’s coach or volunteer need an Enhanced DBS check?

There is no single check level for everyone working around children. Assess duties, setting and frequency for each role. Eligibility is about the check legally available; whether a check is required can also depend on sector rules and your organisation’s circumstances.

The recruiting organisation is responsible for assessing eligibility. Standard and Enhanced checks are restricted to eligible roles. A club policy cannot authorise a higher-level check than the law permits. Use the current DBS eligibility guidance and ask DBS or your umbrella body if the position is unclear.

• DBS eligibility guidance · Disclosure and Barring Service
• DBS checks guidance for employers, voluntary organisations and third parties · Disclosure and Barring Service

Basic, Standard, Enhanced and Children’s Barred List checks

Basic: information about unspent convictions and conditional cautions. Standard: spent and unspent convictions and cautions, subject to filtering. Enhanced: Standard-level information plus relevant information held by local police.

Enhanced with Children’s Barred List: Enhanced information plus whether the person is barred from the relevant work with children. An Enhanced certificate without that check is not the same thing. Standard is not a universal intermediate step for club staff; establish eligibility for the actual role.

• Checks you can make on someone’s criminal record · Disclosure and Barring Service
• DBS eligibility guidance · Disclosure and Barring Service

When can a role be regulated activity with children?

For teaching, training, instructing, caring for or supervising children, the current DBS guidance includes a period condition: more than three days in a 30-day period, or once overnight between 2am and 6am with an opportunity for face-to-face contact. These activities can qualify even when someone else supervises the worker.

That is not a complete test for every role. Other routes and exceptions exist: certain healthcare or personal-care activities have different frequency rules, specified establishments can bring additional roles into scope, and day-to-day management of regulated activity can qualify. Read the full eligibility guidance rather than applying one frequency rule to everyone.

A barred person must not undertake the regulated activity from which they are barred. Identifying regulated activity therefore has consequences beyond choosing a certificate type.

• Eligibility for Enhanced with Barred List DBS checks with children · Disclosure and Barring Service
• Change to regulated activity with children from 1 September 2026 · Disclosure and Barring Service

What changed on 1 September 2026?

The supervision exemption for relevant regulated activity with children was removed on 1 September 2026. A paid worker or volunteer who was outside regulated activity solely because of sufficient supervision can now fall within it if the other criteria are met. Their eligible check can move from Enhanced to Enhanced with Children’s Barred List.

This change is already in force. It is not limited to schools or volunteers, and does not mean every role involving children becomes regulated activity. The activity, frequency and other eligibility criteria still matter.

DBS explicitly says the change does not introduce a blanket requirement to obtain checks. Nor does it itself require removing a worker solely because an application is being processed. Consider safeguarding responsibilities, risk assessment and any sector-specific requirements when deciding interim arrangements.

• Change to regulated activity with children from 1 September 2026 · Disclosure and Barring Service
• September 2026 supervision changes: common misconceptions · Disclosure and Barring Service

Conditional examples: coaches, volunteers and other staff

A sports coach teaching children on four days within 30 days: if the relevant criteria are met, an Enhanced with Children’s Barred List check is available. For coaching more than once but below the period condition, sports guidance describes eligibility for Enhanced without the barred-list check.

A volunteer assistant coaching alongside a lead instructor: supervision alone no longer excludes the role from regulated activity. Review the actual activity and frequency, just as for paid workers. Helping occasionally is not automatically the same as teaching regularly.

A bookings administrator at an ordinary leisure centre: simply encountering children does not establish Standard or Enhanced eligibility. Teaching or supervision duties, or work in a specified establishment, can change the assessment. Check duties and setting before applying this example to your staff.

A manager: day-to-day management of someone undertaking regulated activity can itself qualify, even without directly teaching children. Ownership or a senior title alone is not the assessment.

• DBS checks in sport: working with children · Disclosure and Barring Service
• Eligibility for Enhanced with Barred List DBS checks with children · Disclosure and Barring Service
• Change to regulated activity with children from 1 September 2026 · Disclosure and Barring Service

Self-employed coaches and private tutors

Since 21 January 2026, eligible self-employed people and personal employees can apply for Enhanced or Enhanced with Barred List checks through a DBS umbrella body. Eligibility still depends on the role; being self-employed does not automatically entitle someone to a particular check.

For work provided directly to a private individual or family, the eligible worker applies through an umbrella body rather than asking the parent to obtain the check. If a self-employed instructor contracts with an organisation, that organisation may apply on their behalf under its policies. Agree the route with the organisation or umbrella body.

• DBS checks for self-employed people and personal employees · Disclosure and Barring Service

A practical review checklist for your club

Use these steps to organise a role review, not as a legal decision engine. If you previously relied on supervision to exclude a role, revisit that assessment under the September change. Record the reasoning without collecting unnecessary criminal-record information.

• List each paid and volunteer role, its duties, setting and children’s ages.
• Record how often relevant activities occur, including overnight work.
• Identify assessments that previously relied on the supervision exemption.
• Use current eligibility guidance to confirm the available check level and workforce.
• Check whether existing certificates include the appropriate barred-list information.
• Decide whether a new check or other action is needed under your sector guidance.
• Update recruitment arrangements and revisit the assessment when roles change.

• DBS eligibility guidance · Disclosure and Barring Service
• Change to regulated activity with children from 1 September 2026 · Disclosure and Barring Service

Existing certificates, renewals and changed duties

DBS certificates have no official expiry date; they reflect information at the time of the check. Decide when a new check is needed, taking account of applicable sector requirements. There is no universal three-year renewal rule for all children’s clubs.

Before accepting a certificate from a previous role, check identity and whether its level and type match the new role. Use the Update Service where applicable. An older Enhanced certificate without a Children’s Barred List check does not demonstrate that the barred list was checked.

Reassess when duties or working patterns change. Do not assume every existing certificate must automatically be replaced because of September 2026; review the role, what was checked and the relevant sector guidance.

• Checks you can make on someone’s criminal record · Disclosure and Barring Service
• September 2026 supervision changes: common misconceptions · Disclosure and Barring Service

DBS checks are one part of safer recruitment

A certificate supports a suitability decision; it is not a guarantee that someone is safe to work with children. DBS describes checks as one part of recruitment practice. They may not provide a complete view of criminal records for someone who has lived overseas.

Handle criminal-record information fairly and securely, for its intended purpose and only for as long as necessary. Follow the DBS code of practice and linked handling guidance. Do not put certificate contents or criminal-record details into ordinary child or class notes.

RocketClass can help organise bookings, attendance and day-to-day club administration. It does not assess DBS eligibility, carry out DBS checks or certify your safeguarding arrangements. Continue to review your wider recruitment and safeguarding processes.

• DBS checks guidance for employers, voluntary organisations and third parties · Disclosure and Barring Service