How employers use the DBS Update Service

The DBS Update Service can help an employer check whether information has changed since an eligible Standard or Enhanced certificate was issued. It does not deliver a new certificate to the employer, make a hiring decision, decide whether the role is eligible for a particular level or watch the workforce on the employer's behalf. The individual owns the subscription. The employer must take a separate, lawful step each time it checks a certificate's status.

That distinction matters in daily recruitment. A manager may see “on the Update Service” in a worker record and assume that all checks are complete. The statement says little unless the organisation has seen the original certificate, confirmed the worker's identity, established its entitlement to the same level and any relevant workforce and barred-list element, obtained consent, run a current status check and acted on the result. The DBS employer guide, updated in August 2026, sets out these conditions and gives examples of how employers can use the service.

This guide is about the employer's status-check decision. Whether a prior certificate fits a new role is a separate decision. Use the DBS employer guidance on accepting an earlier certificate for that question. Retention and handling of the resulting evidence require a separate privacy policy.

What the service actually does

An individual can subscribe a Standard or Enhanced DBS certificate to the Update Service. When an entitled organisation checks that certificate online with the person's consent, DBS returns a status result. The check is free for the employer. The DBS guidance says Basic certificates are not covered. The service can be useful when a person moves between eligible roles or when an organisation conducts checks at points set by its policy.

DBS searches underlying sources for relevant new information at different intervals. Its employer guide describes weekly searches for new conviction and barred-list information and less frequent searches for potential non-conviction information, which then require police consideration before a status change is confirmed. An employer should not interpret this as real-time monitoring. DBS does not push a notice to every employer when a status changes. The employer needs to run a status check to discover the result available at that point.

The guidance says there is no prescribed general frequency for employers' status checks. A review schedule should reflect the work, safeguarding risk, regulatory requirements and the organisation's policy. A six-month interval in a DBS example is an illustration, not a universal legal rule. A status check is one part of safer employment practice alongside identity, references, conduct and relevant professional checks. It cannot substitute for a local response to a current safeguarding concern.

The individual's subscription and joining windows

The subscription belongs to the certificate holder. An employer may pay with the applicant's permission, but payment does not give the employer control of the account. The person can manage or cancel it. The DBS applicant guide explains joining, renewal and account management. For a paid subscriber, the annual fee is £16 on 27 September 2026. DBS has announced a reduction to £15 from 5 October 2026. Qualifying volunteers can subscribe without the fee. Confirm the fee on the day of release rather than leaving an outdated price in evergreen copy.

There are two joining routes with different clocks. After a certificate is issued, the person can join using its certificate number within 30 days of the original issue date. If they join during the application using an application or e-bulk reference, DBS must receive the application within 28 days of joining. Those are not interchangeable deadlines. The DBS employer guidance says a certificate reprint does not restart the 30-day period. A current Complys page says “28 days for a reprint”; that wording needs removal when this replacement is integrated.

If the person misses the joining window after issue, a new eligible DBS application is needed before they can join. If a paid subscription lapses, the applicant guide describes a new application and new subscription to rejoin. A free volunteer subscription still needs annual renewal. The organisation should therefore confirm that a status check actually succeeds. A note in a worker file saying the person subscribed last year does not prove that the subscription remains active today.

The volunteer distinction also affects a change to paid work. DBS says a certificate for a paid position cannot be added to a free volunteer subscription. A person moving from a free volunteer arrangement to paid work may need a fresh application and paid subscription under the applicant guide. That is a subscription rule as well as a role-eligibility question. The DBS applicant guide explains the subscription fee rules; this page explains what an employer should check before relying on Update Service status.

Decide entitlement before opening the status-check screen

The employer must be legally entitled to request a new DBS check of the same type and level for the actual role. It must also have the individual's consent to check the status. For an Enhanced certificate, the employer must compare the workforce with what it is entitled to know about. The DBS guide says that workforce need not be compared for a Standard certificate status check because it does not affect the Police National Computer information on a Standard certificate. Where barred-list information appears, the employer must be entitled to that exact barred-list element. The DBS employer guide asks the organisation to answer each of these questions before proceeding.

Start with duties, not a job title. “Support worker”, “coach” or “administrator” can describe very different activities. A role may be eligible for Standard, Enhanced or Enhanced with a particular barred-list check only if the relevant legal criteria are met. A certificate containing more information than the new employer is permitted to request is not automatically acceptable. The DBS eligibility guidance provides the entry point, while sector guidance may add detail. An Update Service subscription does not give an employer permission to see information outside its legal entitlement.

For the first status check, the organisation must have seen the original paper certificate in person at some point since issue, or use the alternative original-certificate process described in DBS guidance where in-person viewing is not possible. A photocopy or video view is not enough under the current employer guide. Confirm that the certificate is genuine, check the applicant's identity under DBS ID guidance, inspect its level, workforce and barred-list elements, and consider any information on it for the role. The employer guide says a later status check need not involve seeing the original again if the earlier conditions and identity controls have been met, but a new role may require a new entitlement assessment.

Consent should be clear and traceable. The applicant can see organisations that have checked their status through their account. The employer makes a legal declaration when running a check. A general hiring form or an old consent note should not be treated as unlimited authority after the person leaves, changes to a role that no longer justifies the level, or withdraws consent. DBS guidance says further checks must stop in those situations. Assign someone to remove the status-check task from the schedule when the entitlement ends.

A first-check workflow for a hiring team

Use a short sequence that can be followed and audited:

1. Describe the real duties and record why the role permits the same certificate level and any relevant workforce and barred-list element. 2. Match the worker's identity to the original certificate and inspect its security features and content through the approved process. 3. Confirm the person has subscribed that certificate and obtain their consent to the status check. 4. Enter the details into the official DBS Update Service, make the required declaration and run the check. 5. Record the date, result, reviewer and decision under the organisation's handling policy. Restrict access to the result and certificate information. 6. If the result calls for action, follow the current DBS guidance and the organisation's safeguarding and recruitment process before deciding whether the person can start or continue the work.

The checklist is an employer process aid. It does not determine legal eligibility. Do not put the worker's certificate number into an unapproved shared spreadsheet merely because the online form asks for it. The DBS handling policy and the organisation's privacy controls govern how sensitive check information is stored and disposed of.

Read all four result types correctly

The employer guide distinguishes four practical outcomes. The wording on the live service can change, so the organisation should follow the current result screen and guidance rather than relying on a memorised label.

The “no longer current” message is often misread. It is not a disclosure of the new information and not a final suitability decision. Speak with the individual through a fair process, consider whether immediate safeguards are needed, and request a new eligible DBS check to see the current certificate content. The employer guide describes a limited early confirmation check in specific barred-list circumstances. That is not a routine shortcut and should be used only where its listed conditions are met, including the relevant barred-list entitlement and the person's consent. Where a current concern exists, follow safeguarding procedures without waiting for a routine review date.

“Details do not match” also needs a controlled response. Check spelling, identity data and the certificate number through the authorised process. If the subscription lapsed or the certificate was removed, the organisation cannot treat an old status result as current. Decide whether a new application is needed. Do not tell the worker that new criminal information exists when the service has only reported a mismatch.

Repeat checks without claiming continuous monitoring

For an ongoing role, agree a schedule that the organisation can execute. Name the owner and the consent process. At each review point, confirm the worker remains in a role for which the employer is entitled to the same check. Then run a new status enquiry and record its result. The DBS example of an academy conducting checks every six months illustrates an employer policy. It does not establish a general legal interval for other employers. A certificate itself has no official expiry date, as DBS employer guidance confirms.

A status check does not automatically run because someone has an active subscription. DBS does not alert the employer to a changed status. A reminder in software can prompt a person to make a fresh enquiry, but only the official status result answers whether the subscribed certificate remains current at that moment. Between enquiries the employer has no automatic live view. The organisation should also encourage staff to report relevant changes through its conduct and safeguarding procedures, subject to fair and lawful policy.

When someone changes duties, review the underlying entitlement first. Moving from adult to child work, changing to a role with a barred-list element, or changing from a role that permits Enhanced to one that permits only Standard can defeat the assumption that an old certificate is suitable. The service cannot amend the original certificate to a different workforce or level. The receiving organisation must make its own acceptance decision under current DBS employer guidance. This page addresses the status enquiry after that decision path has been checked.

What to do when the status changes

The employer guide says “no longer current” means DBS has confirmed information that would be included in a new certificate at the same level. A new application is the route to see that information. The organisation should not infer that the person has been barred, convicted or unsuitable solely from the status message. Discuss the matter fairly, protect children or adults where there is a concern, and follow sector procedures. The guide describes specific conditions for an early barred-list confirmation where the original certificate contained the relevant list check and the employer has entitlement and consent. Use the official route and specialist advice for that exceptional case.

Record the sequence carefully. When was the status checked? Who saw the result? Was the original certificate appropriate for the role? What new application was requested? What interim safeguarding decision was made and by whom? What did the later certificate show? Avoid a permanent, unexplained “red” label in a general worker profile. The person's information may be disputed or corrected, and the ultimate employment decision is the employer's responsibility under the applicable law and policy.

Do not confuse a changed status with a DBS barring referral. A referral is a separate possible duty after a regulated activity provider or personnel supplier removes or would remove someone from regulated activity for a relevant safeguarding reason. The DBS legal-duty guidance addresses that separate post-incident question. A status result by itself is not a complete referral analysis. If there is immediate risk, follow the organisation's safeguarding route first.

Keep the right evidence, with the right access

The employer guide says a successful status result may be printed and stored securely in line with DBS handling and data-protection requirements. Decide what evidence the organisation needs, who can see it and how long it should remain. Keep a dated record of the status check, the consent and the decision. Do not copy the original certificate's disclosure contents into an ordinary staff profile. The DBS certificate-handling guidance distinguishes a limited check record from justified retention of the certificate or its contents.

An audit trail should show the initial certificate review and later status checks as separate events. If the first event was not done correctly, repeated online status checks do not cure the missing original-certificate or identity evidence. If the worker has left or moved to an ineligible role, remove future status-check tasks and stop accessing the service. The DBS employer guide is explicit about this boundary.

The applicant owns the subscription, including renewal. Employers can remind people to check their account, but should not claim to renew it on their behalf without a supported arrangement. A payment made from an employer card still leaves the subscription under the individual's control. If the service returns a mismatch, verify the actual status rather than relying on the employer's payment receipt as evidence that the certificate remains subscribed.

Two examples that reveal common errors

A coach volunteers and later takes a paid role. The club saw the coach's original Enhanced certificate and ran a valid status check for the volunteer role. The person had a free volunteer subscription. The club later offers paid work with different duties. It must reassess check eligibility for the paid role and the subscription conditions. The DBS applicant guide says a certificate for paid work cannot be added to the free volunteer subscription, and describes the need for a new application and paid subscription when moving from volunteer to paid work. A previous green result cannot simply be copied into the paid-role file.

An agency worker moves to a different site. The agency has a record of an Enhanced certificate on the Update Service. The new receiving organisation has not seen the original certificate or checked the identity of the person arriving on site. It should not rely on the agency's “active” label alone. The parties need an assurance handoff that establishes the actual worker, role, level, workforce, original-certificate review, consent and current status result under the DBS guidance. The agency and receiving organisation must resolve their respective responsibilities for this placement. A site substitution should trigger a fresh identity and placement review.

These cases do not imply every employer must request a new certificate for every move. They show why the Update Service is a conditional route rather than a transferable badge. The decision turns on actual duties, legal entitlement, certificate content, subscription, consent and the receiving organisation's policy.

Where Complys can assist

Complys has generic worker-linked document records and configurable review reminders. Those can help a team know when it planned to run its next status check and which person owns the task. Current product evidence does not verify Update Service integration, automated status enquiries, subscription management or structured fields for certificate level, workforce, barred-list element or status result. Do not describe a reminder as an automatic DBS check or say Complys monitors subscribers.

If an organisation needs a reliable audit of Update Service decisions, it should specify where consent, original-certificate review, identity confirmation, role entitlement, result and next action are recorded. A generic document field may not capture that structure. The product owner should demonstrate the actual workflow before the site promises it. Any stored result or certificate detail also needs the handling and privacy controls described in the DBS certificate-handling guidance. A free checklist could help a manager ask the right questions, but it must not produce a definitive eligibility decision or claim to query DBS.

For a current case, use the official employer guide alongside the live Update Service. Confirm the person's consent and the exact legal entitlement before making the declaration. Record what the service actually returns. Then apply the organisation's recruitment, safeguarding and privacy process to the result.