The DBS change that caught your supervised volunteers, and what it actually takes to check them
Saturday morning, half nine, drizzle. The under-nines are doing passing drills and a mum in a hi-vis bib is moving cones about and shouting encouragement. She has helped every Saturday for five years. Everyone loves her.
Ask the club secretary whether she’s had a barred list check and you’ll get the answer I’ve heard more times than I can count: “She doesn’t need one. She’s always with the head coach.”
That answer stopped being true on 1 September 2026.
What changed
For years there was a get-out in the law called the supervision exemption. If a volunteer was coaching, teaching, caring for or supervising children, and someone properly checked was supervising them closely enough, the volunteer wasn’t in “regulated activity”. Your club could get them an enhanced DBS check, but it couldn’t check them against the children’s barred list. That’s the list of people the law says must not work with children.
From 1 September, the get-out is gone. Being supervised doesn’t take anyone out any more. The change applies in England, Wales and Northern Ireland, and it covers paid staff as well as volunteers. DBS names assistant coaches in children’s sports clubs as one of the groups it is aimed at, alongside youth groups, charities and community groups. You can read the official announcement on GOV.UK. Scotland runs its own scheme and isn’t covered here.
Once a week is enough
Someone is in regulated activity with children if they coach, teach, train, care for or supervise children:
- frequently, or
- on more than 3 days in any 30-day period, or
- overnight between 2am and 6am, even once.
Read the middle one again. Four Saturdays in a month is four days. Your weekly helper is in.
It counts across settings too. If the same person listens to readers at school on a Tuesday and helps at your club on a Saturday, both count towards the total. The overnight rule catches tournament weekends, residentials, camps and sleepovers, even as a one-off.
Who it doesn’t catch
The parent who runs the tea hut twice a season. The dad who drives to one away game. The helper on a day trip. Occasional help isn’t caught.
Neither is anyone on site who isn’t coaching, teaching or looking after the children. The groundsman, the bar volunteer and the treasurer counting subs in the clubhouse are not in regulated activity just because there are children nearby.
Your fourteen-year-old young leader can’t be checked at all, because DBS checks can’t be requested for anyone under 16. That doesn’t ban them from helping. It means you manage that risk another way, through supervision and sensible role design.
The bit everyone is getting wrong
Here’s what the change does in law. It doesn’t order you to carry out a DBS check, and DBS has said so in its myth-busting guidance. What the law does say is that it’s a criminal offence for a barred person to do regulated activity with children, and an offence for anyone to let them.
Think that through. Your weekly helper is now in regulated activity. If they were on the barred list, you would be committing an offence by letting them carry on. The only way a grassroots club can find out whether someone is barred is an enhanced DBS check with the children’s barred list.
“We weren’t legally required to check” is not a line anyone wants to try out on a parent.
One more thing, because I’ve already had panicked messages about it. You do not have to stand someone down the minute you realise they need a check. The law doesn’t require it. What you do need is a decision, made by the committee and written down, about what that person does while the check comes through. More supervision, no one-to-one time with children, no overnights. Write it down.
The tenner
“Now the bit that should end the excuses about DBS checks for volunteers. For volunteers, DBS charges nothing for an enhanced check with barred list. Nothing at all.
What you will pay is an admin fee to whoever processes the application for you. For a grassroots group that is usually somewhere between £10 and £17. The FA charges its clubs £10 for a volunteer.
To get the free check, the person has to be a genuine volunteer: no pay beyond out-of-pocket expenses, not on a work placement, and not doing it as part of a course that leads to a qualification. There’s one catch I know from the inside, as a foster carer. Paid foster carers, and anyone who lives in a fostering household, don’t qualify for the free volunteer check, so they pay the full fee. The full rules are on the DBS volunteer checks page.
For paid coaches, the DBS fee for an enhanced check dropped to £41 on 5 October 2026. The admin fee goes on top.
Don’t let anyone sell you a basic check for this. A basic check costs £20, isn’t free for volunteers and tells you nothing about the barred list. It’s the wrong product.
When your volunteers apply, get them to join the DBS Update Service as well. It’s free for volunteers, it keeps their certificate current, and it means the next club, school or group can check it online instead of starting from scratch.
Where you get one
Your volunteer can’t apply for this check on their own. The application has to come through the organisation they volunteer for. Most small clubs and groups aren’t registered with DBS themselves, so they go through an umbrella body. Try them in this order:
- Your governing body. The FA, the ECB, UK Athletics, the RYA and plenty of others run checks for their affiliated clubs. Start there.
- Your local council or CVS. Many councils and councils for voluntary service act as umbrella bodies. Ring and ask what they charge.
- The GOV.UK umbrella body finder, which lists organisations registered to process checks for others.
- A commercial umbrella body. Perfectly fine, but compare admin fees and check what’s included before you sign up.
The three bits of ID
This is where applications stall, so get it right first time. Most people use what DBS calls Route 1:
- One main document: a passport (a UK one can be up to six months out of date), a UK photocard driving licence (full or provisional), a birth certificate issued within 12 months of birth, an adoption certificate, an e-Visa or a biometric residence permit.
- Two more, either from that list or from things like a council tax statement, a bank statement or utility bill from the last three months, a P45 or P60, a marriage certificate or a benefits letter.
Between them the documents must show name and date of birth. The applicant will also need every address they’ve lived at in the last five years and every name they’ve ever used.
Three things trip people up.
Originals only. No photocopies, no scans, and no bank statement printed off from the app. A printout stamped and signed by the bank in branch is fine.
Mobile phone bills don’t count.
The person checking the ID cannot be the applicant’s relative, partner, housemate or personal friend. In a club where the secretary is the head coach’s sister and everyone went to school together, this is the one that will catch you. Find someone neutral, or use your umbrella body’s digital ID check, which usually costs a few pounds. Whoever does check the ID has to keep a record of what they saw for two years.
The full document list is in the DBS ID checking guidelines.
The awkward questions
Answer these before somebody asks you.
What about the helper who steps in because someone’s poorly? A one-off is fine. If the one-off is happening every fortnight, it isn’t a one-off.
Who is keeping track of the person who helps at two clubs, or at your club and a school? Ask them. The days count across both.
What happens if a check comes back with something on it? A record isn’t automatically a no. Decide now who on the committee looks at it, in confidence, and how. Your governing body will have a process you can follow.
Who holds this information, where, and for how long? It’s sensitive personal data. It does not live in the coaches’ WhatsApp group.
If you’re still unsure about a role, DBS runs free eligibility workshops and has a regional outreach team. Both are linked from the myth-busting page above.
Work experience is a different beast
If you’re a school or college, or a business that hosts work experience students, the same law change raises different questions, and the answers aren’t the same as a football club’s. Most work experience students are under 16, for a start.
The Association of Education Business Professionals (AEBP), the national network of education business partnerships, has been working through exactly this. Education business partnerships across the country pulled the evidence together at speed, and I helped write it up into guidance. Follow the AEBP on LinkedIn for it, and don’t try to work out work experience from a blog post about sports clubs. Including this one.
The thirty-minute committee job
Put this on the next agenda. It takes half an hour.
- List every role where someone coaches, teaches, cares for or supervises children.
- Mark the ones that happen more than 3 days in 30, or overnight.
- For each person in those roles, check whether their current certificate includes the children’s barred list. The certificate says so. If it doesn’t, they need a new check.
- Find out who your umbrella body is and what they charge.
- Agree what people do while their check is in progress.
- Decide who looks at a check that comes back with information.
Then minute it. Something like: “The committee reviewed all roles against the change to regulated activity from 1 September 2026, identified those now in regulated activity, and agreed the checking and interim arrangements above.”
I wrote about why DBS checks are the most basic fail back in November 2025. The rules have moved since. The point hasn’t.
Nobody is saying your five-year helper is dangerous. You just don’t get to assume it any more.
DBS checks for volunteers: the one-page crib sheet
Who now needs a barred list check, what it costs, where to apply and which ID to bring. One page. Free.