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DBS Checks: Changes to Regulated Activity with Children

Helpers who work under supervision may now need an Enhanced DBS check with Barred List. Please review roles by the end of February 2027.

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Volunteers helping children with crafts in a church hall

The legal definition of “regulated activity” with children in England and Wales has changed, and it affects many of our churches’ children’s and youth work. The URC Safeguarding team first reported the change in its July newsletter, and is now asking every church to act on it.

What has changed

Until now, the “supervision exemption” meant that some people working or volunteering with children did not need a Barred List check, as long as they worked under supervision. For example, a helper who was never alone with children and always worked under the guidance of the group leader.

The Crime and Policing Act 2026 removes that exemption. A worker or volunteer is now engaged in regulated activity if:

  • they teach, train, instruct, care for or supervise children, or give advice or guidance on their wellbeing; and
  • they do so frequently, meaning on more than 3 days in any 30-day period, or overnight.

This applies whether or not the person is supervised. If someone helps with more than one group or in more than one setting, every session counts towards the “more than 3 days in 30” total.

Anyone engaged in regulated activity needs an Enhanced DBS check with Barred List.

What your church needs to do

  • Review each role in your children’s and youth work against the new definition, including helpers and assistants who did not need a Barred List check before.
  • Start a new Enhanced DBS check with Barred List for anyone whose role now counts as regulated activity.
  • Complete this by the end of February 2027, the deadline agreed by the URC Safeguarding Committee.

We know this is an extra task for churches, and we’re grateful for everything you do to keep children safe. If you need help deciding whether a role is affected, or with the DBS process, please contact our Lead Synod Safeguarding Officer, Belinda Herbert, at [email protected] or on 07471 531 977.

There is more guidance for church safeguarding coordinators and DBS verifiers on our Safer Recruitment and Volunteers page.

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