Before 1 September 2026, people who teach, train, instruct, care for or supervise children do not require a barred list check if someone else supervises them sufficiently.
From 1 September 2026, this supervision rule will no longer apply, and if the frequency test is met, an organisation will need to check the Children’s Barred List. The frequency test is met if the activity occurs on 4 days or more in any 30-day period (or overnight, between 2am and 6am).
NB - This affects DBS checks made from 1st September 2026 and only impacts activity with children. There is no change to the required DBS checks for activity with adults.
Example 1 – weekly Sunday school volunteer
A volunteer at a church Sunday school helps to teach and instruct children. They do this every Sunday morning, except during school holiday periods. Because a Sunday school leader (supervisor) is always nearby and supervises them, the church decided that the volunteer is sufficiently supervised and asked the volunteer to apply for an Enhanced DBS check without a check of the Children’s Barred List.
The volunteer did not previously require a children’s barred list check because the leader supervised them. As a result of the legislation change, from 1st September 2026, the volunteer will require an Enhanced DBS with Children’s Barred List check, as they meet the frequency test, i.e. the activity is carried out on 4 days or more in a 30-day period.
Example 2 – monthly messy church volunteer
Another volunteer helps once a month at the church to help with messy church activities. There is not always an activity leader present to supervise them. This volunteer is not carrying out the role often enough, so was only asked to apply for an Enhanced DBS check without a Children’s Barred List check.
From 1st September, the church does not need to consider the supervision changes and apply for a barred list check for this role as the frequency test is not met, i.e. the activity is not being carried out on 4 days or more in a 30-day period.
What you need to do
- identify roles where people teach, train, instruct, care for, or supervise children and are currently supervised by someone else
- check if the activity meets the frequency test, and therefore from 1st September 2026, requires a children’s barred list check
- check if the person’s current DBS certificate included a Children’s Barred List check. If not, from 1st September 2026, they must apply for a new Enhanced DBS with Children’s Barred List check.
Remember - It is against the law for:
- a barred person to engage in regulated activity with children;
- someone to allow a barred person to do regulated activity with children












