When organisations talk about safer recruitment, the conversation almost always centres on paid staff. But safeguarding has never really been about payslips. It is about access. Who has it, how often, and under what conditions.
From 1 September 2026, one of the most significant changes to how regulated activity is defined in over a decade comes into force. The supervision exemption for volunteers is being removed. That means organisations working with children—schools, sports clubs, charities, activity providers, faith groups—need to look again at how they recruit, check, and manage their volunteer workforce.
What the supervision exemption was
Since 2012, volunteers working with children have been able to be excluded from regulated activity status if they were supervised by another adult already carrying out regulated activity. The thinking behind it was reasonable: avoid burdening low-risk, infrequent volunteering with the same requirements as paid roles.
In practice, the exemption created a gap. For ease, some organisations have used it as a way to avoid DBS checks altogether for volunteers who were, in truth, spending significant time with children in positions of trust.
The new regulation closes this gap
What changes from 1 September 2026
From that date, a volunteer is in regulated activity if they carry out qualifying activities with children and meet either of the following conditions:
They do so more than three days in any 30-day period
They do so on an overnight basis
Supervision by another regulated worker no longer changes that classification. If the activity and the frequency are there, regulated activity applies—full stop.
Qualifying activities include:
Teaching, training, or instructing children
Caring for children
Supervising children
For any volunteer who meets these thresholds, organisations must:
Obtain an Enhanced DBS check with Children's Barred List information before they start
Apply appropriate safer recruitment processes
Maintain ongoing safeguarding oversight
DBS checks for volunteers remain free, just like our own platform, so there is no financial barrier to compliance.
Who this does not affect
Not every volunteer falls under regulated activity. If someone helps out infrequently—fewer than three days in any 30-day period, and not overnight—they remain outside the regulated activity definition.
A parent who helps at a single sports day is not the same as a volunteer coach who trains the same group of children every week. The distinction matters. Organisations do not need to apply Enhanced DBS requirements to genuinely occasional helpers who stay below the threshold.
Volunteers who work across multiple organisations
If a person volunteers in multiple settings, each instance counts towards the ‘on more than 3 days in a 30-day period’ period condition.
If they volunteer for 4 days a month, even if each of the 4 days in that month is in a different setting, then they are considered to be in regulated activity.
Settings are encouraged to work together to decide who should apply for the DBS check. The volunteer can provide details of the check to each one.
At the point of applying for an enhanced DBS check with barred list information, the volunteer should also consider joining the DBS Update Service as that will help with multiple settings.
Overnight trips and residential activities
The overnight condition works slightly differently from the frequency condition. A single overnight stay with children is enough to place a volunteer in regulated activity—regardless of how rarely it happens.
If your organisation runs residential events, school trips, outdoor activities, or any programme involving overnight stays, every adult volunteer involved will need an Enhanced DBS check with Children's Barred List information. That applies even if it is a one-off.
Why this matters more than it might first appear
There is a tendency in many organisations—conscious or not—to treat volunteers as inherently lower risk than paid staff.
"They're supervised." "They're only helping out." "They give their time for free."
None of that changes what a child experiences in that relationship.
Risk does not come from whether someone is paid. It comes from access. The opportunity to build trust with a child. The relationships that develop over weeks and months of regular contact. Some of the adults who have caused the most serious harm to children were precisely the ones who seemed the most trustworthy—coaches, mentors, activity leaders, volunteers who were embedded in a community and well-regarded within it.
The removal of the supervision exemption is a legislative acknowledgement of something safeguarding professionals have long understood: being supervised is not the same as being vetted. A background check and a safer recruitment process do not become less important just because someone else is nearby.
What safeguarding leaders need to review now
If you manage volunteers in your organisation, this is the time to work through the following:
1. Map your volunteer base against the threshold: Who volunteers more than three days in any 30-day period? Who participates in overnight activities? These are your priority cohort under the new rules.
2. Check your safer recruitment process applies equally to volunteers: Many organisations have strong processes for paid staff and considerably weaker ones for volunteers. That gap needs closing. Application forms, references, induction—these should be consistent regardless of whether someone is paid.
3. Review how you record and track volunteer DBS checks: Do you know which volunteers currently hold an Enhanced DBS with Children's Barred List information? Do you know when those certificates were issued and whether your organisation has a process for renewal? If the answer to either question is "not really," that is worth sorting before September. And we can help with that!
4. Update your safeguarding policy: The legislative change needs to be reflected in your documentation. The updated definition of regulated activity should be clear in your policies and communicated to staff who oversee volunteers.
5. Do not wait until August: 1 September 2026 is not far away. An organisation with a large volunteer base—a sports club with 40 regular coaches, a charity running weekly youth activities—has a meaningful amount of work to do. Starting that work now is considerably less stressful than starting it in August.
Frequently asked questions
Does this apply to all four nations of the UK? The change introduced applies to England. Scotland, Wales, and Northern Ireland already have their own legislative frameworks for volunteers in regulated activity.
What if a volunteer refuses to consent to a DBS check? If a volunteer is in regulated activity and refuses a check, they cannot undertake that role. There is no discretion here. Organisations should make this clear in their volunteer agreements.
Can a volunteer use a DBS check they already have from another organisation Organisations can take into account an existing certificate through the DBS Update Service, provided the check was at the Enhanced level and included the Children's Barred List. However, it is the organisation's responsibility to satisfy itself that the check is appropriate and current.
What about volunteers who are just parents at a school event? If they are below the frequency threshold—fewer than three days in a 30-day period—and there is no overnight element, they are not in regulated activity under the updated definition.
Managing volunteer compliance at scale
Tracking DBS certificates, keeping records up to date, and knowing at a glance who is verified and who needs actioning is genuinely difficult when you are doing it manually—across spreadsheets, email chains, and photocopied documents.
Safeguard-Me was built specifically for this. Our digital safeguarding passports give every member of your workforce—paid or voluntary—a verified, portable record of their checks. As an organisation, you get a real-time compliance dashboard showing you exactly who is verified, who needs attention, and what is coming up for renewal.
If you are working through what the September 2026 changes mean for your volunteer management, create a free account or book a demo to see how Safeguard-Me handles this in practice.
Summary: the key facts
In force from: 1 September 2026
Legislation: Crime and Policing Act 2026
What changes: Supervision exemption removed; volunteers in qualifying roles meeting frequency/overnight conditions are now in regulated activity
Frequency threshold: More than 3 days in any 30-day period
Overnight threshold: Any overnight activity with children
Check required: Enhanced DBS with Children's Barred List information
Cost to organisation: DBS checks for volunteers remain free