DBS checks for charities, volunteers and trustees

Which roles can be checked

The DBS charity leaflets say:

• Anyone can apply for their own Basic DBS check. There are no eligibility criteria.
• Access to Standard and Enhanced checks is controlled by law. The law does not say when a Standard or Enhanced check must be carried out, but it does specify when one can be applied for. Organisations may set their own guidance on when they want checks, but it must comply with the law on when a check can be applied for.
• Standard and Enhanced checks should only be applied for when the person will carry out the activities that make them eligible as part of their everyday responsibilities, not because they might at some point.
• Not all charity roles are eligible. Eligibility depends on who the person works with, what they do for them and how often.

The Charity Commission says trustees should risk assess all roles, taking account of the working environment, to decide whether a role is eligible for a check and at what level. It says to always get a standard, enhanced or enhanced-with-barred-list check from the DBS when a role is eligible, and that a Basic check should be obtained if the risk assessment says that is appropriate for a role that is not eligible. The DBS publishes an eligibility checker and guidance leaflets.

What counts as a volunteer

The DBS leaflets say the definition comes from the Police Act 1997 (Criminal Records) Regulations 2002: a person engaged in an activity that involves spending time, unpaid (except for travel and other approved out-of-pocket expenses), doing something that aims to benefit some third party other than, or in addition to, a close relative.

• If the role is eligible for a Standard or Enhanced check and satisfies both parts of the definition, the "volunteer" box can be marked and the application is free of charge.
• Unpaid work as part of a course of study that leads to a qualification is not volunteering for DBS purposes. Work experience intended to make someone more employable is not classed as voluntary work.
• Someone taking part in a charity event is not volunteering for or employed by the charity, so the charity cannot request Standard or Enhanced checks on participants. Fundraising does not generally make a person eligible for a Standard or Enhanced check unless the criteria in the leaflet are met.
• The leaflets do not give any fee other than saying qualifying volunteer applications are free of charge.

Trustees

• Children's charities. The DBS treats a charity as a children's charity if its workers or volunteers include people who carry out regulated activity with children. Any trustee of a children's charity can be asked to apply for an Enhanced DBS check in the child workforce. The trustee role alone gives no eligibility for a Children's Barred List check. If a trustee also carries out regulated activity with children in another role, both roles should be stated in the "position applied for" field, and the check can include the Children's Barred List.
• Adults' charities. Charity trustees can be asked to apply for an Enhanced DBS check in the adult workforce if the charity's workers or volunteers include people who carry out work that falls within the legal definition of work with adults. If a trustee also carries out regulated activity with adults in another role, the check can include the Adults' Barred List.

The Charity Commission adds that some people are disqualified from being a trustee or holding a chief executive or finance director-level role, and links to guidance on disqualification.

The Update Service for volunteers

The Update Service is free for volunteers. To qualify, the DBS says a person must not be paid for the role apart from approved travel and out-of-pocket expenses, must not benefit financially from the role, must not be on a work placement, must not be a trainee or studying for a qualification that leads to a full-time role, and must not be a paid foster or kinship carer or a member of their household. The Update Service is for Standard and Enhanced checks only. The DBS employer guide gives an example of a voluntary organisation whose recruiting manager runs a status check, because the certificate's level and workforce match what he is entitled to request. See How to check a DBS on the Update Service.

A change from 1 September 2026

The Charity Commission says that from 1 September 2026 the supervision exemption for regulated work with children no longer applies. Some staff and volunteers who teach, train, instruct, care for or supervise children often or overnight will now be classed as carrying out regulated activity, even if supervised. It says trustees should ensure the charity reviews affected roles and updates DBS checking arrangements where necessary.

What the Charity Commission says about trustees' duties

The Commission uses "must" for a legal or regulatory requirement and "should" for good practice it expects trustees to follow. On DBS checks and suitability it says:

• You must make sure that trustees, staff and volunteers are suitable and legally able to act in their positions. It lists DBS checks, references and checks on gaps in work history, confirmation that staff can work in the UK, and health checks as things you may need to get.
• You should consider whether to use DBS checks as part of your range of checks, alongside references and interviews, and review what checks are needed as roles change.
• If you ask applicants about their criminal records, you must have a policy that sets out a lawful basis and condition of processing, to comply with data protection law.
• A charity that uses information from the DBS must also have a policy on the recruitment of ex-offenders, to comply with the DBS Code of Practice.
• You must refer to the DBS if you provide regulated activity, stop someone working with children or adults at risk, and certain criteria are met.
• Consider asking DBS applicants to register with the Update Service, or consider carrying out further DBS checks on a regular basis. See Do you have to re-check DBS certificates for existing staff?

Sources

• Safeguarding and protecting people for charities and trustees, Charity Commission, GOV.UK, last updated 8 October 2026
• DBS guidance leaflet: working with children in the charity sector and overseas aid organisations, GOV.UK, updated 17 September 2026
• DBS guidance leaflet: working with adults in the charity sector and overseas aid organisations, GOV.UK, updated 17 September 2026
• DBS Update Service, GOV.UK
• DBS Update Service: employer guide, GOV.UK, updated 5 October 2026

Daily DBS is independent of the DBS and UK Government. This guide summarises published guidance. Eligibility depends on the exact role: the DBS eligibility checker is the authority. Checked against these sources on 10 November 2026.