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Disclosure and Barring Service

The Disclosure and Barring Service (DBS) is an executive non-departmental public body sponsored by the Home Office of the United Kingdom government, responsible for processing criminal record disclosures and maintaining barred lists to prevent unsuitable individuals from engaging in regulated activities with children and vulnerable adults.^[1]
Established on 1 December 2012 through the merger of the Criminal Records Bureau and the Independent Safeguarding Authority under the Protection of Freedoms Act 2012, the DBS facilitates safer recruitment by issuing basic, standard, and enhanced checks that reveal convictions, cautions, and relevant non-conviction information held by police forces.^[2]^[1]
In addition to disclosures, the DBS manages the Children's and Adults' Barred Lists, referring and barring individuals assessed as posing risks based on evidence of harmful conduct or convictions, thereby aiming to protect vulnerable groups across England, Wales, and associated territories.^[1]
Over the decade leading to 2023, the service has processed 52 million checks, underscoring its scale in supporting employer decisions, though independent reviews have identified operational gaps such as complex regulated activity definitions and exemptions for supervised roles, alongside vulnerabilities from uncheckable self-employed workers, leading to calls for legislative refinements to bolster efficacy without unduly impeding rehabilitation.^[3]^[3]

Origins and Legal Foundation

Pre-DBS Developments

Prior to the establishment of a centralized criminal records checking system in the United Kingdom, background vetting for individuals working with children and vulnerable adults relied on decentralized, manual processes managed by local authorities and police forces. These included consultations with the Department of Health's List 99, established under the Protection of Children Act 1999 to bar unsuitable individuals from school-related employment, and checks against the Sex Offenders Register introduced by the Sex Offenders Act 1997. Such methods often involved inconsistent information sharing and lacked comprehensive access to national police records, leading to gaps in identifying risks.^[4] The Police Act 1997 introduced provisions for criminal record certificates, laying the groundwork for standardized disclosures. Part V of the Act enabled the creation of the Criminal Records Bureau (CRB), which launched operations on 1 March 2002 to provide Basic, Standard, and Enhanced disclosures for roles involving children or vulnerable adults.^[5] The CRB aimed to streamline checks by integrating data from police, courts, and other agencies, processing over 1.4 million applications in its first year amid rising demand driven by public concerns over child safety.^[6] High-profile failures, notably the 2002 Soham murders of Holly Wells and Jessica Chapman by Ian Huntley—a school caretaker vetted via CRB but with prior unaddressed allegations—exposed systemic deficiencies in record-keeping and inter-agency communication. The subsequent Bichard Inquiry, reporting on 22 June 2004, criticized inadequate vetting practices and recommended a national scheme for mandatory registration and continuous vetting of those working with children, influencing the development of barring mechanisms.^[4]^[7] These events underscored the limitations of disclosure alone, prompting legislative moves toward integrated safeguarding including proactive barring.^[8]

Legislative Framework

The Protection of Freedoms Act 2012 established the Disclosure and Barring Service (DBS) as an executive non-departmental public body under section 87(1), effective from 1 December 2012.^[9] This legislation merged the functions of the Criminal Records Bureau (CRB), previously created under Part V of the Police Act 1997 to issue criminal record certificates, with the Independent Safeguarding Authority (ISA), formed by the Safeguarding Vulnerable Groups Act 2006 to operate vetting and barring schemes for individuals working with children and vulnerable adults.^[10] Section 88 of the 2012 Act facilitated the transfer of these functions to DBS and provided for the abolition of the ISA, streamlining operations while retaining core disclosure and barring responsibilities.^[10] The DBS's disclosure functions derive primarily from the Police Act 1997 (as amended by the 2012 Act), which authorizes the issuance of basic, standard, and enhanced criminal record certificates under sections 112 to 116, including provisions for relevance of convictions and access to local police records. These enable employers to assess suitability for roles involving vulnerable groups, with a code of practice issued under section 120A governing the handling and use of disclosed information by registered bodies.^[11] Barring functions, conversely, stem from the Safeguarding Vulnerable Groups Act 2006, which under sections 1-4 established barred lists for children and vulnerable adults, defined criteria for inclusion (e.g., relevant conduct or convictions per Schedule 3), and imposed prohibitions on barred persons engaging in regulated activities, with DBS assuming these duties post-merger.^[12] Amendments via the 2012 Act refined these schemes, narrowing the scope of regulated activities to reduce bureaucracy while maintaining safeguards.^[13] Supplementary governance is outlined in Schedule 8 of the Protection of Freedoms Act 2012, covering transfer schemes, staffing, and operational continuity, with DBS accountable to the Home Office under a framework document specifying ministerial oversight and annual reporting to Parliament.^[14] This legislative structure interacts with related laws, such as the Rehabilitation of Offenders Act 1974 (amended by the 2012 Act), which filters certain spent convictions from disclosures except in barred or enhanced checks. The framework emphasizes data protection and proportionality, with DBS required to balance public safety against privacy rights, though critics have noted tensions in over-disclosure practices addressed by subsequent judicial reviews and amendments.^[15]

Establishment and Merger

The Disclosure and Barring Service (DBS) was formally established on 1 December 2012 as an executive non-departmental public body sponsored by the Home Office, through the merger of the Criminal Records Bureau (CRB) and the Independent Safeguarding Authority (ISA).^[2]^[16] This consolidation was legislated under the Protection of Freedoms Act 2012, which sought to simplify and integrate vetting processes previously divided between the two organizations.^[16] The CRB, launched in 2002, had been responsible for issuing criminal record certificates to organizations employing individuals in roles involving contact with children or vulnerable adults, processing over 13 million checks by the time of the merger.^[17] The ISA, created in 2008 in response to safeguarding failures highlighted by inquiries such as the Bichard Inquiry into the Soham murders, administered a national vetting and barring scheme to prevent unsuitable individuals from working with vulnerable groups.^[18] The merger addressed operational overlaps, with the DBS inheriting the CRB's disclosure functions and the ISA's barring responsibilities to form a unified framework.^[2] This restructuring aimed to reduce administrative burdens on employers, accelerate check processing, and enhance overall efficiency in protecting children and adults at risk, while maintaining separate handling for barring referrals to ensure due process.^[2] Initial implementation included transitional arrangements, such as the phase-out of ISA's Independent Safeguarding Authority checks in favor of DBS equivalents, with full operational integration achieved by early 2013.^[19] The move was projected to save £110 million over four years through economies of scale, though it faced scrutiny over potential impacts on barring decision independence.^[16]

Core Functions and Processes

Criminal Record Check Types

The Disclosure and Barring Service (DBS) administers four principal types of criminal record checks, each escalating in scope and eligibility based on the nature of the role or position, as defined under the Police Act 1997 and subsequent legislation.^[20] Basic checks provide the minimal level of disclosure, revealing only unspent convictions and adult cautions recorded on the Police National Computer (PNC), and are available to any individual or employer without specific legal entitlement.^[1] Standard checks expand to include spent and unspent convictions, cautions, reprimands, and warnings, but are restricted to roles explicitly permitted by the Rehabilitation of Offenders Act 1974 (Exceptions) Order 1975, such as in legal, accounting, or security professions.^[21] Enhanced checks incorporate all standard-level information plus any additional relevant police intelligence deemed pertinent by chief officers, applicable solely to positions involving frequent contact with children or vulnerable adults under exemptions from the Rehabilitation of Offenders Act.^[20] Enhanced checks may also include verification against the DBS children's and adults' barred lists, mandatory for roles where such contact is unsupervised and integral to the position.^[22] Basic DBS checks, introduced as a portable certificate under the DBS framework, disclose convictions and cautions that remain unspent under the Rehabilitation of Offenders Act 1974, excluding filtered youth cautions or convictions unless exceptionally relevant.^[1] These checks do not access barred lists or non-conviction police data, and their certificates can be reused by applicants via the DBS Update Service for ongoing validity confirmation without reapplication.^[21] Processing typically occurs within 14 days, with no statutory barring information included, making them suitable for general employment vetting where higher disclosures are ineligible.^[20] Standard DBS checks reveal a broader criminal history, encompassing all convictions, cautions, reprimands, and final warnings irrespective of spent status, drawn from central records like the PNC and local police holdings.^[1] Eligibility is confined to occupations listed in secondary legislation, such as solicitors, barristers, or those in licensed conveyancing, ensuring disclosure aligns with roles where access to full conviction history mitigates risks of professional misconduct.^[23] Unlike enhanced variants, standard checks omit subjective police intelligence or barred list cross-references, with certificates valid for the issuing date and subject to the same update service portability.^[21] Enhanced DBS checks build on standard disclosures by mandating chief constables to append any "relevant" non-conviction information, such as ongoing investigations or local intelligence, from force records not held centrally.^[20] Governed by the Safeguarding Vulnerable Groups Act 2006, these are required for regulated activity with children or vulnerable adults, where the position involves unsupervised access, as determined by statutory definitions.^[22] When combined with barred list checks—against the Independent Safeguarding Authority's successor lists—the enhanced check flags individuals barred from working with children or adults, prohibiting employment in eligible roles upon positive matches.^[1] This level, processing in 2-4 weeks on average, underscores DBS's role in preemptive risk assessment, though disclosures remain subject to filtering rules since 2013, which omit certain minor, non-violent spent convictions after defined periods.^[23]

Barring Scheme Operations

The Disclosure and Barring Service (DBS) operates two separate barred lists: the Children's Barred List, which prohibits individuals from regulated activities involving children, and the Adults' Barred List, which applies to regulated activities with vulnerable adults.^[24] These lists are maintained under the Safeguarding Vulnerable Groups Act 2006, with barring decisions based on evidence of relevant conduct (actions causing or risking harm), satisfaction of the harm test (likelihood of future risk), or relevant offences, alongside a connection—past, present, or potential—to regulated activity.^[24] Barring occurs through automatic or discretionary processes. Automatic barring applies to individuals cautioned or convicted of specified relevant offences, such as sexual assault on a child under 13 or murder of a vulnerable adult, leading to immediate list inclusion; certain cases allow representations within 8 weeks, while others permit no discretion or appeal.^[24] Discretionary barring stems from mandatory referrals by regulated activity providers (e.g., employers, agencies) when permission for such activity is withdrawn due to suspected harm, risk of harm, or relevant cautions/convictions; other entities like local authorities may refer voluntarily.^[25] Referrers must supply details on the individual, incident, and evidence; non-compliance without justification constitutes an offence fined up to £5,000.^[25] The discretionary process unfolds in five stages: initial assessment of referral validity and regulated activity link; information gathering from police records, referrers, and other sources; risk evaluation via the Structured Judgement and Phased Disposition (SJPD) model, analyzing predispositional (e.g., history of violence), cognitive, emotional, and behavioral factors; issuance of a provisional "minded to bar" notice, granting 8 weeks (extendable) for representations; and final decision, weighing evidence, representations, and public confidence in the system, with complex cases escalated to the DBS Quality Standards Committee.^[24] Decisions aim for consistency, with barring imposed if the individual is deemed likely to cause harm in regulated roles. List maintenance includes periodic reviews for removal eligibility: after 1 year for those under 18 at barring, 5 years for ages 18-24, and 10 years for those 25 and older, based on reassessed risk.^[24] Appeals for discretionary barring must be filed with the Upper Tribunal's Administrative Appeals Chamber within 3 months of the final decision, focusing on errors of law, fact, or procedure; automatic barring without representations offers no appeal route.^[26] In 2023-24, DBS added 5,792 individuals to the lists, contributing to a total of approximately 88,700 people retained on one or both as of March 2023.^[27]^[28]

Application and Support Services

Individuals apply for Basic DBS checks directly through the online self-service portal on the GOV.UK website, providing personal details and paying a fee of £21.50, with processing typically averaging three days.^[29]^[30] For Standard or Enhanced checks, required for roles involving children or vulnerable adults, applications are initiated by employers or registered umbrella bodies, which supply paper or online forms to applicants for completion, followed by identity verification using specified documents per DBS guidelines.^[31]^[32]^[33] Volunteers may access Basic checks independently but rely on sponsoring organizations for higher-level disclosures, with no fee exemption for Basic applications despite common misconceptions.^[34] Support services include an automated online tracking system accessible via GOV.UK, allowing applicants and countersignatories to monitor application status using reference numbers.^[35] The DBS provides a customer helpline at 03000 200 190, operational Monday to Friday from 08:00 to 18:00, for inquiries on application status, identity issues, or procedural guidance, with a Welsh-language line at 03000 200 191.^[36]^[37] Additional webchat support operates Monday to Friday from 09:00 to 17:00 for general customer queries, while email contact at [email protected] handles specific escalations.^[38]^[39] The DBS Update Service enables subscribers to transfer existing certificates to new employers by confirming no status changes since issuance, reducing repeat applications for a £10 annual fee.^[35] Comprehensive guidance documents, such as filtering rules and ID validation protocols, are freely available on GOV.UK to assist applicants and organizations in compliance.^[20]^[33]

Operational Realities

Processing Efficiency and Capacity

The Disclosure and Barring Service (DBS) processes millions of criminal record check applications annually, with 7.37 million certificates issued during the 2023-2024 financial year amid sustained high demand.^[40] This volume reflects a capacity to manage substantial throughput, including approximately 4.5 million enhanced checks in the prior 2022-2023 period, representing a 10.8% increase from previous levels.^[41] However, processing efficiency is constrained by dependencies on external entities, particularly police forces for "stage 4" verification in enhanced checks, which involves manual review of local records and has averaged 18.78 days in some jurisdictions as of 2024.^[42] Average turnaround times differ by check type: basic checks typically complete in 0.8 to 3 days, standard checks in 1 to 2 days, and enhanced checks in 8 to 14 days as reported in early to mid-2025 data.^[30]^[43]^[44] DBS performance targets include completing 75% of disclosures within 14 days, though actual outcomes vary due to application complexity, error rates, and peak demand periods.^[45] Quarterly improvements were noted in Q2 2025, attributed to enhanced government agency coordination, but enhanced check times rose 18% from mid-2024 to January 2025 in some metrics.^[46]^[44] Capacity strains have led to growing backlogs, exacerbated by staffing shortages, outdated IT systems, and police resource limitations, with delays described as a critical issue requiring new software implementation by late 2025.^[47] High volumes—exceeding 52 million checks since DBS inception—underscore operational scale, yet bottlenecks in police-held data disclosure highlight inefficiencies inherent to the decentralized verification process rather than DBS core operations alone.^[48]^[47] These factors contribute to variable efficiency, with basic and standard checks generally meeting rapid processing goals, while enhanced checks remain vulnerable to external delays averaging up to several weeks in complex cases.^[49]

Funding and Economic Costs

The Disclosure and Barring Service operates on a full cost-recovery model, generating revenue primarily through fees paid by applicants or employers for disclosure checks and ancillary services such as the Update Service subscription. This self-funding approach aligns with HM Treasury guidelines for executive non-departmental public bodies, aiming to break even without relying on routine government grants or taxpayer subsidies.^[41]^[50] Income is segmented by check type, with enhanced checks—required for roles involving frequent contact with vulnerable groups—forming the largest share due to higher processing demands.^[27] In the 2023-24 financial year, DBS recorded total income of £216 million, broken down as £136 million from enhanced checks, £48.1 million from basic checks, £7.1 million from standard checks, £23.6 million from the Update Service, and £1.1 million from other sources. No grant-in-aid was received from the Home Office, though prior years saw targeted reimbursements, such as £10.3 million in 2022-23 for free COVID-19-related checks. Expenditure reached £226.3 million, yielding a net operating deficit of £10.3 million after accounting for a one-off court judgment provision; excluding this, a £4.6 million surplus was achieved, with surpluses remitted to the Consolidated Fund.^[27]^[41] Key cost components include staff expenses of £60.4 million, IT systems and development at £60.1 million, and £54.9 million paid to police forces for criminal record data access and verification. DBS met its efficiency target with 5.4% savings relative to total spend (excluding police and supplier costs), comprising 93% cashable reductions and recurring efficiencies from process optimizations. Fee adjustments, such as the December 2, 2024, increases to £21.50 for basic and standard checks and £49.50 for enhanced checks (with barred list additions), are calibrated to cover these rising inputs like inflation and volume-driven police charges while maintaining free checks for volunteers.^[27]^[51]^[52] The economic costs of the DBS system are largely borne by private users—employers, individuals, and organizations—through these fees, which totaled over £215 million in fee income for 2023-24 and reflect the marginal cost of each application's processing, including third-party police and IT dependencies. This structure limits direct fiscal impact on the UK government, as DBS avoids ongoing subsidies and pursues digital efficiencies to curb per-check overheads, though broader societal costs arise from administrative burdens on applicants and potential delays in recruitment for fee-sensitive sectors like volunteering. Projected 2024-25 income stands at £220.9 million against costs including £63.8 million in pay and £58.7 million in police fees, underscoring the service's reliance on sustained application volumes for financial equilibrium.^[27]^[52]

Safeguarding Outcomes and Evaluation

Documented Achievements

The Disclosure and Barring Service (DBS) has processed vast numbers of criminal record checks, issuing nearly 7.4 million certificates in the 2023-24 financial year, a record volume that supports employers in identifying risks during recruitment for roles involving vulnerable groups.^[53]^[54] This scale includes over 4.5 million enhanced checks in prior years, with demand rising 10.8% in 2022-23 alone, demonstrating capacity to manage heightened application volumes amid ongoing safeguarding needs.^[41] In barring operations, DBS reviewed 59,048 referrals in 2023-24, including 33,277 automatic cases closed within target timelines at a 98.1% rate, resulting in thousands added to prohibited lists.^[53] Cumulative barring lists stood at 97,244 individuals across children's (85,629) and adults' (66,542) categories as of November 2023, with 5,456 additions from 14,845 closed cases that year; these prohibitions bar listed persons from regulated activities, directly limiting access to at-risk populations.^[55] Annual barring decisions reached 6,266 in 2022-23, up from prior years, enhancing protections against known risks.^[41] Operational quality remains high, with 99.99% accuracy in certificate disclosures of criminal and barring data, and a 99.97% quality assurance rate for barring closures exceeding targets.^[53] DBS also handled 11,039 employer referrals and 14,732 enhanced check disclosures, while delivering over 520 workshops to more than 13,990 participants, fostering recruitment best practices and awareness.^[53] These metrics reflect sustained delivery of reliable services, as evidenced by a UK Customer Satisfaction Index score of 76.2, surpassing the public sector average.^[53]

Empirical Evidence on Effectiveness

Empirical assessments of the Disclosure and Barring Service (DBS) reveal substantial operational scale but limited direct evidence linking its processes to reductions in safeguarding incidents. Between 2012 and 2022, the DBS issued approximately 52 million criminal record checks, which officials assert contribute to safer recruitment by identifying individuals with relevant convictions or cautions.^[56] In the 2016-17 fiscal year alone, 4 million disclosures were provided to employers, with 260,000 (6.1%) containing information deemed potentially relevant to child or vulnerable adult protection, such as prior offenses.^[57] However, these figures measure disclosure volume rather than downstream outcomes, as the DBS and Home Office have not systematically tracked how many unsuitable individuals were subsequently barred from employment or volunteering due to this information.^[57] Barring decisions provide some quantifiable deterrence: as of March 2017, 64,000 individuals were listed on the barred registers, prohibiting regulated work with children or vulnerable adults.^[57] Supplementary schemes, such as the Misconduct Disclosure Scheme introduced for care providers, conducted over 29,000 checks by November 2022, resulting in the prevention of more than 140 job applications from individuals with substantiated misconduct.^[56] The DBS Update Service, which alerts employers to certificate changes, logged 3,198 status updates in the year ending October 2021, prompting 1,102 checks and 75 new applications in response, though uptake remains low at around 1 million subscribers annually.^[56]^[57] Despite these metrics, independent evaluations highlight a critical evidence gap: no robust studies demonstrate causal reductions in abuse rates attributable to DBS interventions. The 2023 Independent Review of the Disclosure and Barring Regime, commissioned by the Home Office, concluded that while DBS aids recruitment decisions, systemic data on prevented harms—such as avoided abuse cases—is absent, complicating claims of overall effectiveness.^[56] Similarly, the National Audit Office noted in 2018 that without employer follow-up tracking or longitudinal impact analyses, the regime's broader safeguarding benefits remain unquantified, potentially overstating preventive impact amid unmeasured circumventions like identity changes.^[57] This paucity of outcome-based research underscores reliance on proxy indicators like disclosure relevance rather than empirical validation of harm prevention.

Criticisms and Challenges

Bureaucratic Expansion and Overreach

The Disclosure and Barring Service (DBS) has experienced substantial bureaucratic expansion since its establishment, with the volume of criminal record checks processed increasing markedly over time. In 2016-17, DBS issued approximately 4 million disclosures.^[57] By 2022-23, it handled around 4.5 million enhanced checks alone, representing a 10.8% year-on-year rise.^[41] This trend continued, reaching nearly 6 million total checks in 2022 and almost 7.4 million certificates in 2023-24.^[58] ^[53] Between 2020 and 2022, total checks rose by 34.92%, driven by broader application to roles involving children, vulnerable adults, and even some low-risk positions.^[59] This proliferation reflects mandate creep, where initial vetting focused on high-risk professions has extended to ancillary activities, such as volunteer positions with minimal unsupervised contact, fueled by employer risk aversion and liability concerns rather than proportionate risk assessment. Data protection consultants have highlighted a growing trend of excessive screening in the third sector, warning organizations against unnecessary checks that inflate administrative burdens without enhancing safeguards.^[60] Larger organizations exhibit a higher propensity for requesting DBS checks beyond legal requirements, exacerbating the issue.^[61] Critics contend this constitutes overreach, as the system's broad disclosure rules—including non-filterable minor or historical offenses—disproportionately affect individuals with spent convictions, hindering rehabilitation and employment. Advocacy groups like Unlock have documented misuse through ineligible checks, which unlawfully impact law-abiding applicants and deter volunteering; for example, enhanced checks on minors under 16 numbered nearly 150,000 from 2020-2022, raising questions about necessity.^[62] ^[59] Recent reports describe DBS requirements as an "unnecessarily confusing barrier" to volunteering, particularly in community settings like London, where simpler processes could suffice without compromising safety.^[63] Government delays in reforming filtering rules, despite court rulings on disproportionality, have perpetuated these inefficiencies, with modernization efforts overrun by £229 million and lagging 46 months behind schedule as of 2018.^[64] ^[57] Such expansion has strained capacity, leading to processing delays that prevent job starts—e.g., weeks-long backlogs reported in Sussex in 2024—and imposed unrecovered costs, like subsidies for underutilized services.^[65] ^[57] While DBS data shows only 6.1% of 2016-17 checks revealed relevant information, the routine mandating of checks for marginal risks prioritizes bureaucratic compliance over targeted, evidence-based vetting, potentially eroding public trust in the system's proportionality.^[57]

Privacy Risks and Data Handling Failures

The Disclosure and Barring Service (DBS) handles sensitive personal data, including criminal convictions, cautions, and non-conviction information, which subjects individuals to risks of unauthorized disclosure, identity theft, or misuse if security is compromised. Such data is shared with employers, third-party check providers, and law enforcement, amplifying exposure through supply chain vulnerabilities.^[66] Privacy risks are heightened by the mandatory nature of checks for certain roles, where inaccuracies or leaks can lead to reputational harm or employment barriers without recourse.^[67] A notable data handling failure occurred in August 2025, when a cyber-attack targeted Access Personal Checking Services (APCS), an authorized DBS submission firm, compromising records of applicants from December 2024 to May 8, 2025. Affected data included names, dates of birth, email addresses, passport details, driving licenses, and National Insurance numbers, impacting thousands across organizations such as churches, colleges, and residents in Guernsey and the Channel Islands.^[68] ^[69] APCS notified affected parties, classifying the breach as high-risk under data protection regulations due to its potential to enable fraud or discrimination, though no evidence of data misuse has been confirmed to date.^[70] This incident underscored failures in third-party cybersecurity, as DBS relies on external providers for check processing without apparent centralized breach prevention mandates.^[71] An Information Commissioner's Office (ICO) audit in December 2016 identified deficiencies in DBS data practices, including the absence of a tailored Privacy Impact Assessment (PIA) policy and framework to systematically evaluate risks in personal data processing.^[72] The audit recommended establishing PIAs to mitigate privacy intrusions, noting that without them, DBS operations risked non-compliance with data protection principles. Additionally, DBS data retention policies permit indefinite storage of barring decisions and certain police records, raising proportionality concerns; for instance, non-conviction data was historically disclosed broadly until a 2015 European Court of Human Rights ruling in cases like R (T) v. United Kingdom deemed such practices a violation of Article 8 privacy rights for lacking individualized risk assessment.^[73] These retention practices have persisted with filtering mechanisms introduced in 2013, but critics argue they still over-retain minor or cautionary information, potentially stigmatizing individuals indefinitely.^[73]

Burdens on Volunteers and Employers

The requirement for Disclosure and Barring Service (DBS) checks imposes administrative burdens on volunteer-involving organizations, particularly small charities and community groups, which must verify applicants' identities, countersign forms, and assess eligibility before submission, often through umbrella bodies if conducting fewer than 100 checks annually.^[74]^[75] This process diverts limited resources from core activities, with organizations facing additional fees from umbrella bodies—typically £10–£20 per check—to cover processing, despite DBS certificates being free for volunteers in standard, enhanced, or barred list roles.^[75]^[76] Over-application of checks beyond legally eligible roles exacerbates deterrence, as unnecessary vetting for low-risk positions, such as fundraising without vulnerable group contact, can discourage potential volunteers through perceived bureaucracy or stigma, with some organizations opting not to recruit at all to avoid compliance risks.^[75]^[77] A 2024 report on London volunteering noted that complex safeguarding processes, including DBS, contribute to recruitment challenges, with 58% of managers advocating for streamlined systems akin to driving license verification to reduce barriers.^[63] For employers, DBS checks entail direct costs for paid positions—£49.50 for enhanced checks as of December 2, 2024—alongside administrative demands for tracking certificate validity, managing renewals via the separate Update Service (which requires post-application registration within tight deadlines), and handling paper-based ID verification that conflicts with digital norms.^[34]^[32]^[78] These elements delay hiring, particularly in small enterprises reliant on rapid recruitment, and create incentives for repeat applications rather than retention, as the system's fee structure benefits from volume over efficiency.^[78] Recent fee hikes have amplified pressures on resource-constrained employers, prompting calls for modernization to alleviate undue compliance loads without compromising safeguards.^[79]

Reforms and Ongoing Developments

Key Adjustments Post-2012

Following the enactment of the Protection of Freedoms Act 2012, which narrowed the scope of regulated activities requiring DBS checks—reducing eligible posts from approximately 9.3 million to 5 million—and eliminated requirements for continuous monitoring and worker registration, subsequent implementations refined the system's efficiency and proportionality. These post-2012 adjustments addressed criticisms of excessive bureaucracy by limiting disclosures to more relevant information, with the revised definition of regulated activity excluding certain peripheral roles involving children or vulnerable adults unless direct care or unsupervised contact was involved.^[80]^[13] In May 2013, DBS introduced filtering rules for criminal records, effective from 29 May, under which certain minor, non-violent cautions and convictions are automatically removed from standard and enhanced certificates after specified periods—such as 11 years for adults with custodial sentences under 4 years, or 5.5 years for youth convictions without custody—if they meet criteria like being a single offence and not posing ongoing risk. This reform, amending the Rehabilitation of Offenders Act 1974, aimed to balance safeguarding with rehabilitation by preventing perpetual disclosure of outdated minor infractions, though serious violent, sexual, or exploitative offences remain non-filterable.^[81]^[82] The DBS Update Service launched on 17 June 2013, enabling certificate holders aged 18 and over to subscribe annually for £10 (free for volunteers), allowing real-time online status checks by employers to confirm if records have changed since issuance, thereby reducing repeat application volumes and processing times from weeks to minutes. By 2023, this service facilitated over 22 million status checks, contributing to cost savings estimated in the millions annually while maintaining access to updated records without full reapplications.^[83]^[16] Further refinements included the rollout of Basic DBS checks on 1 December 2017 (with full access from January 2018), providing unspent conviction and caution details to any employer or individual via a £23 online or paper application, extending criminal record verification beyond regulated roles to general employment and insurance purposes. Subsequent filtering updates, such as those effective 28 October 2023, shortened disclosure periods for some offences (e.g., 3 years for certain non-custodial adult cautions) and excluded all youth reprimands, warnings, and cautions from certificates, enhancing proportionality for early-life infractions while preserving disclosure of barring-relevant data.^[16]^[84]^[85]

Recent Reviews and Policy Shifts

In April 2023, the Home Office published the Independent Review of the Disclosure and Barring Regime, commissioned in February 2022 and led by Simon Bailey, which assessed the system's effectiveness in safeguarding children and vulnerable adults.^[86] The review affirmed the regime's overall utility, noting that the DBS had conducted 52 million checks over the prior decade to inform safer recruitment, but identified gaps such as the exemption for supervised roles in regulated activity, ineligibility of self-employed individuals for enhanced checks, and risks from name changes circumventing identity verification.^[56] It recommended eight reforms, including removing the supervised activity exemption, clarifying the regulated activity definition, extending enhanced checks to self-employed workers and certain councillors, and mandating birth certificates to mitigate name-change risks; as of late 2025, implementation status remains under Home Office assessment without confirmed adoption of these measures.^[56]^[86] Policy adjustments to DBS filtering rules took effect on 28 October 2023, refining criteria for non-disclosure of certain convictions and cautions on standard and enhanced certificates to balance safeguarding with rehabilitation, building on prior 2020 changes that eliminated automatic disclosure of youth reprimands and warnings.^[85] These updates apply to certificates issued after that date, with previous rules retained for historical reference, aiming to reduce over-disclosure of minor or spent offenses while maintaining access to relevant police intelligence.^[87] The DBS issued a mid-point refresh of its 2020-2025 strategy in June 2023, refining priorities toward quality and safeguarding amid rising check volumes, followed by a new 2025-2028 strategy launched on 2 April 2025, emphasizing digital transformation, AI integration for efficiency, and value for money in line with government priorities on crime prevention and economic growth.^[88]^[54] The updated strategy targets end-to-end digital processes, a revised Update Service with proactive notifications by March 2028, and expansion to 3 million subscribers, while noting a 30% increase in certificates issued since 2020, reaching 7.4 million in 2023-24.^[89] Accompanying business plans for 2024-25 and 2025-26 outline sustained focus on processing efficiency and stakeholder engagement, with barred lists growing 20% to nearly 100,000 entries since 2020.^[52]^[90]^[89]

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The changes to those systems are included in the Protection of Freedoms Act 2012, which recently received Royal Assent.
[14]
https://www.legislation.gov.uk/ukpga/2012/9/schedule/8
[15]
[PDF] Disclosure and Barring Service (DBS) Framework Document
This document sets out the broad framework within which the DBS will operate. The document does not convey any legal powers or responsibilities. It is signed ...
[16]
10 years of making recruitment safer - GOV.UK
Dec 1, 2022 · DBS was established on 1 December 2012 through the Protection of Freedoms Act 2012, when the Criminal Records Bureau (CRB) and the Independent ...
[17]
A Brief History of CRB Checks
Feb 29, 2024 · The CRB was merged with the Independent Safeguarding Authority (ISA) in 2012, to form the Disclosure and Barring Service (DBS). The DBS ...
[18]
Why Was The DBS Introduced? - Employment Tools
Oct 13, 2023 · In 2012, the DBS was formed when the CRB and the ISA were merged. But why is this the case, and where did the CRB and ISA originate anyway?
[19]
The History of DBS Checks: From CRB to the Present Day
Rating 4.3 (5) Jul 26, 2025 · Before CRB, checks were inconsistent. CRB was introduced in 2002, then DBS replaced CRB in 2012, and now DBS checks are legal for many ...Missing: establishment | Show results with:establishment
[20]
DBS checks: detailed guidance - GOV.UK
An employer may request a DBS check as part of their recruitment process. These checks are processed by the Disclosure and Barring Service (DBS).
[21]
[PDF] A guide to DBS checks - GOV.UK
A DBS check is a record of a person's criminal convictions and cautions. This leaflet provides an overview of the different types of DBS check, and how to apply ...
[22]
Types of DBS check | NCVO
There are four types of DBS check for people aged 16 and over (the minimum age a check can be carried out).
[23]
Criminal record checks for employment (basic, standard and ...
There are three main types of criminal record check carried out by the Disclosure and Barring Service (DBS) for employment purposes – basic, standard and ...
[24]
DBS referrals guide: referral and decision-making process - GOV.UK
Oct 25, 2024 · This guide is intended as a general overview of typical DBS referral and barring decision-making processes.
[25]
Making barring referrals to DBS - GOV.UK
Advice about when employers and volunteer managers can make a barring referral to the Disclosure and Barring Service (DBS).
[26]
DBS barring: appeals - GOV.UK
May 16, 2023 · If you want to appeal, you should send your application directly to the Tribunal no later than three months after the date of the DBS' final ...
[27]
[PDF] Disclosure and Barring Service Annual Report and Accounts
Jan 24, 2025 · We added 5,792 individuals to the Barred Lists during 2023-. 24, affording greater protection to vulnerable people by barring unsuitable ...
[28]
Disclosure & Barring Service facts and figures - Olliers Solicitors
Apr 29, 2024 · As of March 2023, 88,700 people were retained on one or both barred lists. ... many as 58% were barred – only 42% of people succeeded.
[29]
Request a basic DBS check - GOV.UK
Apply for a basic Disclosure and Barring Service ( DBS ) check to get a copy of your criminal record. This is called 'basic disclosure'.
[30]
Basic DBS check: guidance for applicants - GOV.UK
Reports, analysis and official statistics. Policy papers and ... Disclosure and Barring Service; Published: 4 July 2019; Last updated: 14 August ...
[31]
DBS application form: guide for applicants - GOV.UK
Step by step guidance for applicants filling in the Disclosure and Barring Service (DBS) application form.
[32]
Get a standard or enhanced DBS check for an employee - GOV.UK
How to do a check. Ask DBS or your umbrella body for an application form. Give the form to the applicant to fill in.Guidance · Find a DBS umbrella body · Basic · Documents proving their identity
[33]
DBS ID checking guidelines - GOV.UK
Guidance to help you validate the identity of a DBS check applicant and a new lead/countersignatory. From: Disclosure and Barring Service; Published: 19 ...ID · DBS digital identity verification · ID checking guidelines for
[34]
DBS check application process for volunteers - GOV.UK
Dec 2, 2024 · Basic DBS checks cost £21.50 for all applicants, including volunteers. You can apply for a DBS check online, through the DBS online application route here or ...
[35]
Disclosure and Barring Service - GOV.UK
The Disclosure and Barring Service helps employers make safer recruitment decisions. DBS is an executive non-departmental public body, sponsored by the Home ...About us · Request a basic DBS check · Update Service and other DBS... · Overview
[36]
New address and telephone numbers for the DBS - GOV.UK
Mar 9, 2015 · From Monday 9 March you can get in touch with us on our new numbers. DBS helpline: 03000 200 190. Welsh language line: 03000 200 191.
[37]
How to contact the DBS (Disclosure & Barring Service)
Mar 5, 2025 · Telephone Helpline: +44 (0) 3000 200 190—Open Monday to Friday: 08:00am to 18:00pm. DBS does now have a Web Chat service. Service times vary.
[38]
Disclosure & Barring Service - Webchat - Synthetix
Live chat. The Disclosure and Barring Service webchat is available Monday to Friday from 09:00 to 17:00. The webchat is available to answer general customer ...
[39]
How do I contact the DBS? - First Advantage
In order to reach the DBS directly, please use the following contact information: Phone: 03000 200 190. Email: customerservices@dbs.gov.ukMissing: support | Show results with:support
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DBS annual report and accounts: 2023 to 2024 - GOV.UK
Jan 28, 2025 · This is the DBS annual report and accounts for 2023 to 2024, covering activities and financial statements from 1 April 2023 to 31 March 2024.Missing: capacity | Show results with:capacity
[41]
[PDF] Disclosure and Barring Service Annual Report and Accounts
Jul 19, 2023 · We barred 6,266 people during 2022-23, an increase from. 5,952 people in 2021-22, thereby protecting more children and vulnerable people from.
[42]
Enhanced DBS 'records held by the police' or 'stage 4' checks
Since the start of 2024, how many days, on average, are you taking ... The MPS are currently on average processing Enhanced DBS applications in 18.78 days.
[43]
Police and uCheck performance on DBS check processing times ...
Jul 25, 2025 · Enhanced DBS checks: Average turnaround time: 8.8 days. Standard DBS check: Average turnaround time: 1 day. DBS Basic checks: Average turnaround ...Missing: capacity | Show results with:capacity
[44]
DBS Turnaround Times (A Six-Month Update) - EBC Global
Feb 19, 2025 · In January 2025, Enhanced DBS turnaround was 14.3 days, Standard was 1.3 days, and Basic was 0.8 days. Enhanced increased 18% from July 2024.Missing: capacity | Show results with:capacity
[45]
Statistics at DBS - Disclosure and Barring Service - GOV.UK
Sep 23, 2014 · DBS aims for 75% of disclosures within 14 days, 99.6% accuracy for barring, 80% of discretionary cases closed within 110 days, and 85% of ...Missing: backlog | Show results with:backlog
[46]
News / Updates | dbsdirect.co.uk
Processing times for criminal record checks during the second quarter of 2025 have generally improved, due to improvements made by the government agencies ...
[47]
DBS delays: Staff and new software needed to halt growing backlog
Nov 19, 2024 · Six takeaways on six months of DBS delays · 1. The backlog is growing · 2. New software is coming next year · 3. The next six months is 'critical'.<|separator|>
[48]
DBS Statistics & Annual Reports - Personnel Checks
The DBS Barred 5792 people between 1 April 2022 to 31 March 2023. · 67,481 people were listed on the Adults' barred list. An increase of 2797 (+4.32%). · 82,799 ...
[49]
2025 Update: Why is my DBS Check taking so long?
Jan 1, 2025 · DBS check delays can be due to police backlogs, application errors, high demand, and staffing issues. Basic checks take 24-48 hours, but can ...
[50]
How the Disclosure & Barring Service is funded - LinkedIn
Nov 20, 2024 · The crucial work we do is funded by the fees paid by DBS check customers. Each DBS check has its own price that is designed to cover all costs of that specific ...
[51]
DBS fees are changing in December - GOV.UK
Nov 8, 2024 · DBS fees are changing in December · Update Service – £16 (per year) · Basic DBS check – £21.50 · Standard DBS check – £21.50 · Enhanced DBS check – ...
[52]
DBS business plan: 2024-25 - GOV.UK
Sep 11, 2024 · The budget sets our estimated costs to deliver our services and business priorities this financial year, reflecting financial estimates of service demand, ...
[53]
DBS annual quality account: 2023 to 2024 - GOV.UK
Nov 12, 2024 · The Annual Quality Account is a testament to our unwavering commitment to safeguarding and quality assurance, reflecting our collective efforts ...
[54]
DBS launch new strategy and business plan for 2025 to 2028
Apr 2, 2025 · The plan also highlights some of DBS' achievements over the past year, such as a record number, 7.4 million, DBS certificates being issued in ...Missing: total inception
[55]
DBS - key moments and milestones of 2023 - GOV.UK
Dec 20, 2023 · As of 30th November, the barring list figures total at 66,542 individuals on the Adults' Barred List, and 85,629 individuals on the Children's ...
[56]
[PDF] Independent Review of the Disclosure and Barring Regime - GOV.UK
The Act merged the functions of the Criminal Records Bureau (CRB) and the Independent. Safeguarding Authority and transferred them to a new body, the DBS, a non ...
[57]
[PDF] Investigation into the Disclosure and Barring Service
Feb 1, 2018 · The National Audit Office scrutinises public spending for Parliament and is independent of government. The Comptroller and Auditor General ...
[58]
The Number of Criminal Record Checks Carried Out in the UK is ...
Feb 10, 2022 · The number of checks carried out annually in the UK has risen by 1.7 million. Last year the DBS processed nearly 6 million DBS Checks.
[59]
Observations from DBS FOI data - Unlock
We analysed the data to see if there were any notable patterns, besides the fact that there has been a 34.92% rise in total checks conducted across the period.Missing: growth statistics
[60]
Warning About Unnecessary DBS Checks - CRB Direct
Rating 4.3 (5) Apr 30, 2020 · Data protection consultants have warned third sector organisations about the growing trend for extensive screening checks on workers.Missing: Criticisms | Show results with:Criticisms
[61]
Why do so many misunderstand DBS?
Sep 4, 2019 · Requiring DBS checks means an organisation reduces its risk if one of its staff or volunteers violates or abuses a vulnerable person.Missing: Criticisms | Show results with:Criticisms
[62]
New report highlights potentially hundreds of unlawful criminal ...
The report highlights the significant impact ineligible checks have on the lives of law-abiding people with criminal records.
[63]
Report calls for simpler safeguarding checks to boost volunteering in ...
Dec 10, 2024 · The initial draft report says that safeguarding considerations and some level of DBS checking act as an “unnecessarily confusing barrier that ...Missing: criticism | Show results with:criticism
[64]
Criminal record checks system still broken, say campaigners
Jan 30, 2020 · Legal rights campaign groups have described as a “disgrace” the government's delay in reforming the criminal record checks system.Missing: overreach | Show results with:overreach
[65]
DBS check: Delays preventing people starting jobs in Sussex - BBC
Oct 21, 2024 · People across East and West Sussex say they are unable to start jobs because of long delays to Disclosure and Barring Service (DBS) checks.
[66]
Standard and Enhanced DBS Check Privacy Policy - GOV.UK
Jan 25, 2021 · How long will DBS hold my information? 11.1. We operate a Data Retention Policy to ensure that data is not held for longer than necessary.Missing: criticisms | Show results with:criticisms
[67]
GDPR and data protection - Guidance for individuals - Unlock
May 14, 2022 · This guidance deals specifically with the use of GDPR and DPA18 for recruitment purposes and the collection and processing of criminal record data.
[68]
Cyber-attack on DBS submission firm hits islanders - BBC
Aug 28, 2025 · A personal data breach at a firm approved for submitting Disclosure and Barring Service (DBS) checks has affected some people in Guernsey, ...
[69]
Criminal background checker APCS faces data breach - The Register
Aug 22, 2025 · Access Personal Checking Services (APCS) has written to customers to notify them that their data has been compromised, according to emails seen ...
[70]
Data Breach – Data Associated With Online DBS Checks (APCS)
Aug 28, 2025 · A high-risk data breach is one which has a significant effect on the rights and freedoms of data subjects. All parties are accountable for ...Missing: handling | Show results with:handling
[71]
Cyber-attack on DBS submission firm hits islanders - BBC
Aug 28, 2025 · A personal data breach at a firm approved for submitting Disclosure and Barring Service (DBS) checks has affected some people in Guernsey, ...
[72]
[PDF] Disclosure and Barring Service - GOV.UK
Dec 9, 2016 · A Privacy Impact Assessment (PIA) policy and framework specific to DBS processing of personal data is yet to be established to ensure PIAs are ...
[73]
The retention and disclosure of criminal records - Commons Library
Feb 10, 2021 · This note sets out the rules in England and Wales governing the retention and disclosure of conviction and non-conviction information held on the Police ...
[74]
Using the Disclosure and Barring Service (DBS) - Resource Centre
The DBS keeps a list of people who are barred from taking part in particular kinds of work with children and vulnerable adults. This type of work is known as ...
[75]
[PDF] Disclosure and Barring Service (DBS) checks
Not only can this discourage people from volunteering, it is also illegal. Conversely, there is a risk some organisations will avoid recruiting volunteers.<|control11|><|separator|>
[76]
Paying for DBS Checks - Cost - Volunteers | CRB Direct
Rating 4.3 (5) Jun 19, 2018 · In England and Wales, these checks currently cost £44, with a more basic level of checking costing £26. The job role will determine what checks ...
[77]
Understanding DBS Checks for Charity Volunteers and Organisers ...
A DBS check shows an individual's criminal convictions, cautions, and other relevant information, and is a key part of safeguarding when volunteers or staff ...Missing: burden | Show results with:burden
[78]
Evidence on Modernising the Disclosure and Barring Service
It is suggested that there is an income incentive in the DBS encouraging repeat applications and therefore a disincentive to encourage staff and volunteers to ...
[79]
The Rising Cost of Safety: DBS Fee Increases - Safeguard-Me
Nov 12, 2024 · The recent announcement to increase DBS fees from £38 to £49.50, effective from December 2nd, 2024, has raised concerns for organisations across the UK.Missing: employers | Show results with:employers
[80]
Draft Protection of Freedoms Act 2012 (Disclosure and Barring ...
Nov 7, 2012 · “The DBS will implement a range of reforms…which will see the number of posts requiring checks reduced from 9.3 million to 5 million.” Column ...<|separator|>
[81]
DBS filtering guide - GOV.UK
Oct 28, 2023 · This guidance relates to the filtering rules for DBS checks. For guidance on making or asking for self-declarations of criminal records, refer ...
[82]
Disclosure & Barring Service filters cautions and convictions
From 29 May 2013, the DBS will be removing certain specified old and minor offences from criminal record certificates issued from this date.
[83]
DBS update service launched today - GOV.UK
Jun 17, 2013 · From today (17 June 2013), you can join the DBS update service putting you in greater control of your information.
[84]
Basic criminal record checks launched today by the DBS - Unlock
Basic DBS checks, available from January 17, 2018, show 'unspent' criminal records and are used by employers and insurance companies. They are available online ...
[85]
New filtering rules for DBS certificates (from 28 October 2023 onwards)
These filtering rules apply to certificates issued on or after 28 October 2023. Filtering rules prior to 28 October 2023 are still available if required.Missing: introduction date
[86]
Independent Review of the Disclosure and Barring Regime - GOV.UK
Apr 18, 2023 · The Home Office commissioned Simon Bailey to carry out a review of the effectiveness of the disclosure and barring regime in safeguarding children and ...
[87]
Previous filtering rules for DBS certificates (from 28 November 2020 ...
Nov 28, 2020 · Please note, these filtering rules apply to certificates issued on or after 28 November 2020 and 27 October 2023.
[88]
Mid-Point Refresh: DBS Strategy 2020 to 2025 - GOV.UK
Jun 7, 2023 · This mid-point refresh of the DBS strategy remains ambitious and focused on quality and safeguarding. It refines our Purpose, Vision, and strategic priorities ...Missing: shifts | Show results with:shifts
[89]
[PDF] DBS STRATEGY 2025 TO 2028 - GOV.UK
In light of the new government's focus on economic growth and crime prevention and rehabilitation, we are also focused on providing improved value for money and ...
[90]
[PDF] dbs business plan 2025-26 - gov.uk
The budget overall is in line with our financial goal to deliver value for money with a fair view of risk and opportunity and is detailed in the table below.