Supervised roles and regulated activity: implementation from 1 September 2026

What is changing?

Under the current framework, individuals who work or volunteer with children in a supervised capacity are not in regulated activity. This means they are not required to have an enhanced DBS check with children’s barred list information. From 1 September 2026, this exemption will no longer apply.

From 1 September 2026, any role involving close and frequent contact with children will be classified as regulated activity, regardless of supervision. Individuals in such roles will need an enhanced DBS check with children’s barred list information. The main group affected is volunteers who were previously supervised and therefore exempt.

It will be an offence for a barred individual to work in a role involving regulated activity with children. It will also be an offence for an employer knowingly to permit a barred individual to undertake such work.

Practical steps for schools

Academies and maintained schools should review their current arrangements for volunteers and individuals in supervised roles who work closely with children. This will help identify roles that will fall within the scope of regulated activity under the updated definition.

For individuals whose roles meet the new criteria, schools will need to obtain enhanced DBS checks with children’s barred list information before 1 September 2026. Schools may also wish to review their policies and procedures and consider the administrative lead time needed to complete the necessary checks.

Schools should begin planning now to identify affected roles and ensure recruitment processes align with the new requirements. The Department for Education has published updated guidance on working or volunteering within regulated activity involving children, which schools should review as part of their preparation. 

For more information, please contact Nick Murrell in our Employment team.