DBS Checks for Charities: A Practical Guide for Trustees and Volunteers

Disclosure and Barring Service (DBS) checks are a standard part of safer recruitment for charities that work with children or vulnerable adults. But the rules about who needs which level of check — and what costs apply — are not always obvious from a first read of the guidance.

This guide covers the four check types, current fees, how the free volunteer route works, and what "regulated activity" means for a small charity board.

The four types of DBS check

Basic check — reveals unspent convictions and conditional cautions only. Available to any employer or individual. No eligibility test applies. Cost: £20.

Standard check — reveals spent and unspent convictions, cautions, reprimands, and final warnings. Requires eligibility under the Police Act 1997 — broadly, roles working with money, assets, or in positions of trust. Cost: £20.

Enhanced check — as the standard check plus any information a chief police officer considers relevant to the role. Required for roles in regulated activity with children or vulnerable adults. Cost: £41.

Enhanced check with barred list check — includes the DBS children's and/or adults' barred list alongside the enhanced disclosure. Available for roles in regulated activity with children or adults. In England and Wales, since 1 September 2026 that includes people who teach, train, instruct, care for or supervise children often enough (on more than 3 days in any 30-day period) or overnight, even where someone else supervises them. Cost: £41.

These fees have applied since 5 October 2026, when the Police Act 1997 (Criminal Records) (Amendment) Regulations 2026 reduced them. The current DBS fee schedule is published on GOV.UK's employer guidance page.

Which check does your charity need?

The starting question is whether your charity's activities fall within regulated activity. For children, regulated activity includes teaching, training, instructing, caring for or supervising children often enough or overnight, whether or not someone else supervises the person (since 1 September 2026, in England and Wales). For adults, it is defined by the activity itself, such as providing healthcare, personal care, social work, or assistance with cash and financial affairs.

If trustees or volunteers work in regulated activity: these roles are eligible for an enhanced DBS check with the relevant barred list check. For work with children, supervision no longer changes this. From 1 September 2026, in England and Wales, someone who teaches, trains, instructs, cares for or supervises children on more than 3 days in any 30-day period, or overnight, is in regulated activity even if someone else supervises them. If anyone in a supervised children's role was checked before that date without a Children's Barred List check, decide whether a new check is needed.

If trustees handle finances or sensitive personal data but do not work directly with service users: A standard DBS check is appropriate for trustees and anyone in a position of financial trust. Basic checks are acceptable for lower-risk roles where the standard eligibility criteria are not met.

If your charity does not work with children or vulnerable adults: DBS checks are not legally required, but the Charity Commission and many funders expect trustees to demonstrate good governance. Basic checks for new trustees are a widely adopted good practice standard, particularly where the charity handles significant funds.

The DBS eligibility guidance collection includes worked examples for common charity roles. Checking this before processing applications avoids wasted fees and application errors.

Free DBS checks for volunteers

Standard and Enhanced DBS checks for volunteers are free of charge. The free route is available when all of the following apply:

• The applicant is genuinely volunteering — not receiving payment or benefit (other than out-of-pocket expenses)
• The role meets the eligibility requirements for the standard or enhanced level check
• The charity confirms the volunteer status on the DBS application form (section 68)

Basic DBS checks are not free for volunteers — only standard and enhanced are covered.

The DBS guidance is clear that mismarking section 68 can result in the DBS recovering the application fee and, in some cases, cancelling the organisation's DBS registration. Only use the volunteer route when the role genuinely meets the definition. Detailed guidance on eligible and ineligible volunteer roles is published on the employer guidance page.

For charities with mixed workforces — paid staff and volunteers doing similar roles — paid staff pay the standard DBS fee; the volunteer route does not extend to employees.

Does regulated activity cover charity trustees?

Whether trustees need DBS checks depends on what they actually do, not their title.

Trustees who also carry out regulated activity for the charity — for example, a trustee who teaches, trains or instructs children for the charity on more than 3 days in any 30-day period, or who helps an older person with washing, dressing, shopping or managing their cash because age, illness or disability means that person cannot do it themselves. These roles are eligible for an enhanced check with the relevant barred list check. For children, supervision by someone else no longer decides whether the role is regulated activity. For adults, doing a listed activity once is enough, and there is no supervision exemption. Befriending or visiting an isolated older person is not, on its own, one of the listed regulated activities with adults, so use the DBS eligibility guidance to see which level of check that role may be eligible for.

Trustees who govern but do not work directly with service users — regulated activity does not typically apply for governance-only roles. Standard checks are the most commonly used level for this group, on the basis that trustees are in a position of trust with access to charity assets and finances.

Trustees in small charities where governance and operations blur — this is common in village charities and small community groups where the same people attend meetings and run activities. Where any trustee also carries out regulated activity through the charity's work (see above), treat that trustee as a worker in regulated activity, not as a governance-only trustee. For children, supervision by someone else no longer decides this. If a trustee's role, or the way they carry it out, changes, check DBS eligibility again.

Your safeguarding policy should specify which roles require which level of check and the process for ensuring checks are completed before someone starts in a relevant role.

Check renewal

DBS checks do not have a formal expiry date: DBS says "There is no official expiry date for a criminal record check issued by DBS." The Charity Commission's safeguarding guidance says trustees should consider "carrying out further DBS checks on a regular basis" or asking applicants to register with the Update Service, but it does not set an interval. Decide a re-check interval that fits your risks, write it into your safeguarding policy and diarise it. Some charities use the DBS Update Service — an annual subscription (currently £15/year) that lets employers check whether a certificate has been updated since issue, reducing the need for new applications.

Practical points for small charity boards

Allow lead time. DBS applications can take several weeks to process, particularly for enhanced checks. Build this into your safer recruitment timeline — no one should start in a regulated role before their DBS result is received.

Use a registered body or umbrella. Most small charities cannot apply directly to the DBS — you need to apply through a registered body or umbrella body (the two terms are used interchangeably in guidance). Some umbrella bodies charge an administration fee on top of the DBS fee; others process for free. Your local CVS (Council for Voluntary Service) or county voluntary action body may offer a free or subsidised service. Compare before committing.

Keep a DBS log. Record which roles require which level of check, when each trustee's and volunteer's check was completed, the certificate reference number, and the renewal due date. With annual trustee recruitment and volunteer turnover, tracking this across a spreadsheet is one of the most common compliance gaps flagged in governance reviews. Our free Compliance Checklist Generator gives you an indicative list of policies and checks based on your charity's income and activities, and our guide to charity management software covers what to look for if you outgrow the spreadsheet.

Disclosure policy. Consider what process applies if a DBS result reveals something. The policy should explain who sees the certificate, how the information is assessed against the role requirements, and who makes the decision about whether the person can proceed. A blanket "any conviction = exclusion" approach is not appropriate — the Rehabilitation of Offenders Act 1974 and DBS guidance expect a proportionate, role-specific assessment.

For a complete picture of your charity's safeguarding obligations — including what your safeguarding policy must cover and how DBS requirements fit within your wider vetting framework — see our safeguarding policy guide. For a broader overview of which policies UK charities are required to have, including those with a statutory basis, see our guide on what policies are required by law for UK charities.

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This guide covers the DBS system in England and Wales. Scotland uses Disclosure Scotland (PVG scheme); Northern Ireland uses AccessNI. This is general guidance, not legal advice — consult a solicitor for advice specific to your charity's circumstances.

Sources

• DBS eligibility guidance collection — GOV.UK
• DBS check requests: guidance for employers — GOV.UK (current fees + volunteer section)
• DBS check: application process for volunteers — GOV.UK
• DBS Update Service — GOV.UK (annual subscription fee)
• Change to the definition of regulated activity with children from 1 September 2026 — GOV.UK
• Regulated activity with children: myth busting the September 2026 Supervision Exemption changes — GOV.UK (DBS)
• Regulated activity with adults in England and Wales — DBS guidance leaflet, GOV.UK
• The Police Act 1997 (Criminal Records) (Amendment) Regulations 2026 (SI 2026/985) — legislation.gov.uk (fee reduction in force 5 October 2026)