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When can charities request an enhanced DBS check?
Short answer: a charity can request an enhanced DBS check only when the role is legally eligible for that level of check. It is not something charities can request for every volunteer, trustee, fundraiser, or helper as a blanket safeguarding measure.
GOV.UK guidance is clear that organisations are legally responsible for checking eligibility before they countersign an application, and that submitting a standard, enhanced, or enhanced with barred list(s) DBS check for an ineligible role is unlawful[1][2]. This guide explains the main charity scenarios in England and Wales, based on official DBS and GOV.UK documentation.
Important: this is a practical guide, not legal advice. When a role is close to the boundary, use the official DBS eligibility guidance or seek specialist advice before submitting the check.
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The Basic Rule
An enhanced DBS check is available only for specific duties, positions, licences, and activities set out in law. The role must usually fall within both the Rehabilitation of Offenders Act 1974 (Exceptions) Order 1975 and the Police Act 1997 criminal records regulations[2].
A charity should ask three questions before requesting an enhanced check:
What will the person actually do? Eligibility is based on the activities in the role, not the charity's good intentions or the role title.
Who will they work with? Different rules apply to the child workforce and adult workforce.
Is barred list information allowed? A barred list check is not automatically included with every enhanced check. It is usually available only where the person is carrying out regulated activity, or one of a small number of listed roles[2].
If the role is not eligible for an enhanced check, the charity may still be able to ask for a basic DBS check. Basic checks can be used for any position or purpose and show unspent convictions and conditional cautions[7].
Enhanced checks are also only one part of safer recruitment. GOV.UK notes that DBS checks assist safer recruitment decisions, but organisations should use all available information, such as role design, supervision, references, training, and safeguarding procedures[2].
Charity Roles Involving Children
For charity roles involving children, the key distinction is between work with children and regulated activity with children.
If a role falls within the legal definition of work with children, it can be eligible for an enhanced DBS check in the child workforce[5]. If it is regulated activity with children, the charity can request an enhanced DBS check with a check of the Children's Barred List[4].
Examples from GOV.UK charity guidance include:
School volunteers: volunteers in schools may be eligible for standard or enhanced DBS checks depending on what they do and whether they are supervised. If they carry out regulated activity, the charity or school can request an enhanced check with a Children's Barred List check. If they do relevant work but are sufficiently supervised, they may still be eligible for an enhanced check without the barred list check[3].
Care, healthcare, counselling, or mentoring: personal care or healthcare for children is regulated activity regardless of frequency. Counselling or mentoring children about physical, emotional, or educational wellbeing can be regulated activity if carried out frequently enough, giving eligibility for an enhanced check with a Children's Barred List check[3].
Children's charity trustees: trustees of children's charities are listed as eligible for an enhanced DBS check without a Children's Barred List check[5].
Fundraising: fundraising itself generally does not make someone eligible for a standard or enhanced DBS check. Eligibility may exist only if the fundraiser also carries out activities that meet the relevant criteria. Event participants are not volunteering for or employed by the charity, so the charity cannot request standard or enhanced checks on them[3].
A useful warning sign: if the reason for the check is only "children may be nearby", that is usually not enough. The charity must identify the specific activity, setting, frequency, and supervision arrangement that creates eligibility.
Charity Roles Involving Adults
For roles involving adults, eligibility depends on the legal definitions of work with adults and regulated activity with adults. The rules are more activity-specific than simply asking whether the charity supports "vulnerable adults".
GOV.UK charity guidance gives several useful examples:
Adult charity trustees: trustees can be asked to apply for an enhanced DBS check in the adult workforce if the charity's workers or volunteers include people carrying out work that falls within the legal definition of work with adults. If the trustee's own additional duties amount to regulated activity with adults, the charity may be able to request an enhanced check with an Adults' Barred List check[6].
Care to adults: people providing care to adults as set out in the GOV.UK annexe can be eligible for an enhanced DBS check in the adult workforce without an Adults' Barred List check. If the care falls within regulated activity with adults, the role is eligible for an enhanced check with an Adults' Barred List check[6].
Meals-on-wheels and deliveries: pure delivery, even into someone's home, is generally basic-check territory only. If the role also includes activities such as prompting, supervising, or physically helping an adult to eat, eligibility can change[6].
Befriending and companionship: GOV.UK says befriending someone, or providing companionship, is not one of the listed activities for work with adults, so people in this role can only be asked to apply for a basic DBS check[6].
Shopping arranged by an organisation: where an organisation arranges shopping for adults who cannot shop themselves because of age, illness, or disability, the role is regulated activity with adults and can be eligible for an enhanced check with an Adults' Barred List check[6].
Helplines: helpline call handlers may be eligible for standard, enhanced, or barred-list checks depending on whether they provide advice or guidance, who receives it, and how often. A general public listening service that is not aimed specifically at children or adults can only ask call handlers to apply for a basic check[6].
When Should The Enhanced Check Include Barred Lists?
An enhanced DBS check with barred list information is a higher threshold than an enhanced check alone. GOV.UK employer guidance says it is only available for people carrying out regulated activity and a small number of listed positions[2].
For children, regulated activity is work that a barred person must not do, defined under the Safeguarding Vulnerable Groups Act 2006 as amended by the Protection of Freedoms Act 2012[4]. It can depend on the activity, the setting, how often the work is done, and whether an unpaid volunteer is sufficiently supervised.
For adults, regulated activity is tied to specific activities rather than a general idea of vulnerability. A charity should map the role against the GOV.UK adult charity guidance before deciding whether the Adults' Barred List can be checked[6].
If a barred list check is not legally available, do not include it. Requesting too high a level of check can be unlawful and may also create data protection risk[1][2].
Common Charity Examples
Role or scenario | Likely DBS position |
|---|---|
General fundraiser or sponsored-event participant | Usually not eligible for standard or enhanced checks; basic check only if appropriate[3][6]. |
Volunteer in a school, supervised while helping children read | May be eligible for enhanced child workforce check without Children's Barred List check[3][5]. |
Unsupervised, frequent teaching, training, care, or supervision of children | May be regulated activity and eligible for enhanced child workforce check with Children's Barred List check[4]. |
Trustee of a children's charity | Eligible for enhanced child workforce check without Children's Barred List check[5]. |
Trustee of an adult charity whose volunteers carry out work with adults | May be eligible for enhanced adult workforce check; barred list depends on the trustee's own activities[6]. |
Befriender providing companionship to an adult | GOV.UK says this can only be a basic DBS check[6]. |
Organisation-arranged shopping for adults unable to shop because of age, illness, or disability | Regulated activity with adults; enhanced adult workforce check with Adults' Barred List check may be requested[6]. |
Practical Process For Charities
Write down the role activities. Include who the person works with, whether the role is paid or unpaid, where it happens, how often, and what supervision exists.
Check eligibility before applying. Use the GOV.UK DBS eligibility guidance and the charity-sector leaflets. The charity is responsible for making sure the requested level is lawful[1].
Choose the right level. Do not add a barred list check unless the role meets the criteria for barred list access[2].
Use the right application route. Standard, enhanced, and enhanced with barred list checks for volunteers must be provided through the organisation or a registered/umbrella body; volunteers do not apply for these checks on themselves[7].
Check volunteer fee rules. Volunteer standard/enhanced checks are free from DBS only where the applicant is unpaid except approved out-of-pocket expenses, does not benefit financially, and is not in a work placement, trainee role, or course of study leading to a qualification or full-time role[7].
Handle certificates carefully. DBS certificate information should be used only for the purpose obtained and destroyed after a suitable period, usually no longer than six months[2].
Remember the duty to refer. Organisations with volunteers carrying out regulated activity have a legal duty to refer to DBS if the relevant conditions are met, including removal from regulated activity because of relevant conduct or harm-test concerns[8].
