DBS checks for employers

If you recruit into roles involving children, vulnerable adults or positions of trust, DBS checks are part of your legal and safeguarding responsibilities. These are the seven steps, in order.

1. Establish eligibility first

Access to Standard, Enhanced and Enhanced-with-barred-list checks is only available to organisations that are entitled by law to ask an individual to disclose their full criminal history, eligibility flows from legislation such as the Rehabilitation of Offenders Act 1974 (Exceptions) Order 1975. Before requesting a check you must establish that the specific role qualifies for the level you intend to request. [GOV.UK]

2. Choose, and check, the correct level

Requesting a higher level than the role is eligible for is not a safe default, it is unlawful and can breach data-protection law. Use the official eligibility guidance (and, if helpful, our eligibility guidance checker) to identify the level, then confirm it before applying. See which DBS check do I need?

3. Obtain checks through the proper route

Standard and Enhanced checks are submitted either directly (organisations registered with the DBS, typically for higher volumes) or through a registered umbrella body acting on your behalf. Individuals cannot apply for these levels themselves, only for a Basic check.

4. Verify identity correctly

You must confirm the applicant’s identity following the DBS ID-checking process, verifying name, date of birth and current address using accepted documents, before the application is submitted. [GOV.UK] Do not alter the applicant’s details on the form to resolve a discrepancy.

5. Handle the certificate lawfully

The certificate is issued to the individual. You should view it, record only the limited details official guidance permits, and not keep a copy. Certificate information must be stored securely, used only for the purpose it was requested, kept no longer than necessary and then securely destroyed. Full detail is on our DBS record keeping & compliance guide.

6. Make the recruitment decision in context

A DBS certificate is one input into a safer-recruitment decision, alongside references, interviews, qualifications and right-to-work checks. Organisations requesting checks must also have a policy on employing ex-offenders and show it to any applicant who asks. [GOV.UK]

7. Keep it current and revisit eligibility

Consider the DBS Update Service (with the individual’s consent) so a Standard or Enhanced certificate can be kept up to date, and set a policy for reviewing checks. If someone’s duties change, re-check whether the eligible level has changed too.

Child, adult and other workforces

Enhanced and barred-list eligibility is framed around the work someone actually does with three broad “workforces”: the child workforce, the adult workforce and an other workforce (roles eligible for other reasons, such as certain licensing or financial roles). A barred-list check, whether the person is barred from working with children and/or adults, is only available where the role is regulated activity with that group, which is defined separately for children and for adults. From 1 September 2026 the supervision exemption was removed from regulated activity with children, so some supervised roles with children can now be regulated activity where the frequency or overnight conditions are met. [GOV.UK] The children’s change does not apply to the adult workforce. Getting the workforce right is what determines whether Enhanced, or Enhanced with a barred-list check, is legally available, see Enhanced with barred list & regulated activity.

How long checks take

Plan your recruitment timeline around current GOV.UK guidance: a Basic check takes up to around 14 days, while Standard and Enhanced checks usually take about eight weeks, varying with the accuracy of the application and whether local police information is involved. These are official guideline timescales, not a Complys service level, Complys does not process checks. Build the wait into your onboarding, and decide in advance how you will handle a start date if a check is still outstanding.

How much checks cost

The statutory DBS fee is set by the Disclosure and Barring Service and is changing from 5 October 2026. [GOV.UK]Qualifying volunteer checks have no DBS fee. A Registered Body or umbrella organisation may add its own administration fee on top.

Looking for a “CRB check”?

Many employers still search for a CRB check, an online CRB check or a criminal record check for employment. The Criminal Records Bureau merged into the Disclosure and Barring Service in 2012, so what you are arranging today is a DBS check, Basic, Standard or Enhanced according to the role’s eligibility. The steps, levels and fees on this page are what now apply; there is no separate “CRB check” process to follow.

Registering with the DBS, or using an umbrella body

Because individuals cannot apply for their own Standard or Enhanced check, an organisation has two routes to submit them. It can register with the DBS directly, which generally suits organisations processing a higher, steady volume of checks and willing to meet the DBS’s registration and countersignatory requirements. Or it can use a registered umbrella body, an organisation already registered with the DBS that submits applications on your behalf, which is usually the practical route for smaller or lower-volume employers. Either way the legal responsibilities stay with you: confirming the role is eligible for the level requested, verifying the applicant’s identity, handling the certificate lawfully and making the recruitment decision. An umbrella body processes the application; it does not take on your eligibility or safer-recruitment duties. When you are comparing routes, check what each charges: the statutory DBS fee is fixed, but a Registered Body or umbrella organisation sets its own administration fee on top, so the total per check varies between providers.

Deciding whether work can start before the certificate

There is no single DBS answer for every role. A blanket “yes” can expose people to risk or breach sector conditions, and a blanket “no” can misstate a specific framework. Decide case by case against the role, the setting, the checks already completed, the work proposed during the wait and the relevant sector guidance, and record a written conditional-start decision that names who approved it and when it ends. In an England school or college, Keeping Children Safe in Education sets specific pre-appointment rules and, in limited circumstances, a separate barred-list check with supervision before the certificate is available. Do not transfer that arrangement automatically to a nursery, adult-care setting, charity or general office, and do not read “supervised” in a school procedure as a general exemption from regulated activity, which changed for work with children on 1 September 2026.

A conditional-start record should state what work the person may do, which tasks are excluded, who supervises and whether that supervision is continuous, which checks are complete, what evidence is still awaited, and who can stop the arrangement. Review it regularly, set an escalation date, and close it only after an authorised person has reviewed the actual certificate result.

An employer control sheet

Use this as a review agenda, not a substitute for legal analysis. A named person should own each decision and hold the source that supports it.

Where Complys fits

Complys does not carry out DBS checks. It helps you keep the surrounding evidence organised, the record that a check was done, safer-recruitment documents, and review reminders. How to do that within the official handling rules (record the metadata, never the certificate’s contents) is covered on our DBS record keeping & compliance guide.

For the software that keeps those records, see DBS compliance software, the DBS-specific part of Complys’s wider worker compliance software. Neither applies for, submits nor issues DBS checks.