
A small change that will make a big difference: Important changes to regulated activity and DBS checks for volunteers from 1st September 2026

If you’re anything like the schools I support as an HR Consultant and certainly in my son’s school too, volunteers play a huge part in daily life. As a parent and volunteer myself, I see just how much of a difference that support makes, whether that’s listening to readers, helping in class, or supporting trips and events.
Which is why a change coming in from 1st September 2026 is worth having on your radar now.
On the face of it, this is a fairly technical update to the definition of regulated activity. In reality, it’s likely to affect a number of the volunteers you currently have in school, particularly how their roles are classified and the checks required.
As we head towards the new academic year, it’s an important safeguarding development to be aware of, even though the core principles themselves aren’t changing.
What is changing?
In simple terms, the law is removing what is known as the “supervision exemption.”
This change is introduced through the Crime and Policing Act 2026, which amends the definition of regulated activity set out in the Safeguarding Vulnerable Groups Act 2006 (as amended by the Protection of Freedoms Act 2012).
Until now, many volunteer roles (for example, helping in class or supporting trips) have not been classed as regulated activity if the volunteer was supervised by a member of staff already in regulated activity.
From September 2026, this will no longer apply.
Instead, the focus is much more straightforward: if a volunteer is regularly working with children even if they are supervised, their role may now fall within regulated activity.
That includes volunteers who:
- support teaching and learning
- supervise or care for children
- do this regularly (more than 3 days in a 30 day period) or take part in overnight activities
- an Enhanced DBS check, and
- this must include Children’s Barred List information
What does that mean for schools?
The key impact is that more volunteers are likely to meet the threshold for regulated activity than before.
Where that’s the case, schools will need to ensure those individuals have:
There’s no change for paid staff, this is really about how volunteers are treated within the safeguarding framework.
Why this matters?
This change is really about recognising the reality of school life.
Many volunteers are in school regularly, build relationships with children, and are trusted members of the community. The updated definition recognises that level of contact and responsibility more clearly.
It also closes a gap because without the barred list check, a school wouldn’t necessarily know if someone is not permitted to work with children.
My advice? Start thinking about this now
September will come around quickly, and a bit of early thinking can make a big difference!
This isn’t about making things more complicated, it’s about making sure your arrangements reflect what’s happening in practice, and that the right checks are in place.
Top 5 actions to consider before September 2026
- Review your volunteer roles
Look at what volunteers actually do in practice not just the role title. - Identify who may meet the new threshold
Focus on frequency (more than 3 days in 30) and any overnight activity. - Check current DBS arrangements
Do they already have an enhanced DBS, and does it include barred list information? - Plan ahead for September
You won’t be able to request barred list checks until eligibility applies, so being ready will help avoid delays. - Update your processes and guidance
This is a good opportunity to review your volunteer procedures, safer recruitment approach, and internal guidance to staff.
A final thought
Volunteers are hugely valued, and that doesn’t change.
If anything, this update reinforces just how important those roles are and why it’s right that the safeguarding framework keeps pace with that.
September may feel some way off, but experience tells us these changes arrive quickly once term starts. Schools that take a little time now to reflect and prepare are likely to find the transition much smoother.
Ultimately, this is a relatively small change in wording, but an important step in strengthening safeguarding ensuring that every adult working closely with children is appropriately checked, supported and trusted to do so.

