Change to the definition of regulated activity with children from 1 September 2026
From 1 September 2026, the UK government will remove the supervision exemption for regulated activity with children, expanding DBS checks to include the Children’s Barred List for more roles.
The useful question is what changes for users, developers or buyers, and whether the announcement stays industry context or becomes something people can actually use.
The UK government announced that from 1 September 2026, the legal exemption allowing supervised staff or volunteers to avoid regulated activity status with children will be removed. Previously, individuals performing activities such as teaching or caring for children were not considered in regulated activity if sufficiently supervised by someone else. The change means these individuals will now be classified as in regulated activity with children if they perform such roles frequently or overnight, regardless of supervision levels.
Organisations employing or engaging volunteers in roles involving children will be affected by this change. Activities such as teaching, training, instructing, or supervising children, performed regularly or overnight, will now fall under regulated activity with children. This includes paid staff and volunteers in schools, clubs, or community settings who previously relied on supervision exemptions to avoid stricter vetting requirements.
The removal of the supervision exemption means organisations must now request Enhanced DBS checks with access to the Children’s Barred List for individuals in regulated activity with children. Previously, Enhanced DBS checks without the barred list check were sufficient for supervised roles. The change applies only to regulated activity with children; no alterations are made to the definition for regulated activity with adults.
Examples provided by the Department for Education illustrate the impact. A parent volunteering weekly to listen to children read will now require an Enhanced DBS check with barred list access, whereas a parent volunteering monthly for art activities will not. Similarly, volunteers instructing children twice weekly at a music club or paid instructors leading daily outdoor activities will now be subject to the stricter vetting process from September 2026.