All Registered Bodies will soon have their level of DBS compliance assessed by the Government via a self assessment questionnaire. Upon completion of your self-assessment you will then be asked to complete a more detailed questionnaire and provide evidence showing how you have adhered to the code of practice.

The data and responses gathered from the self-assessment, alongside inspection visits, will help to identify any non-compliance issues. If you are found to be non-compliant there will be support and guidance available to you to help rectify the situation, but, where necessary, the DBS will takes steps to suspend or cancel Registered Bodies who are unable to comply with their obligations within the code of practice.

The 6 key areas are:

  • Registration Details
  • Eligibility
  • ID verification
  • Application Process
  • Suitability Policies
  • Data Handling

To date, inspections have apparently flagged the following 3 issues as the top areas where Registered Bodies are not adhering to the code of practice:

    1. Checking ID
      Some Registered Bodies haven’t followed the ID checking guidelines and were failing to obtain sufficient valid documents to verify the applicant’s identity.
    2. ID Training
      Some Registered Bodies were found to not provide training on what to do should a suspected fraudulent document be identified. There is information on how to recognise fraudulent documentation here.
    3. Ineligible barred list and enhanced checks
      Some Registered Bodies have been found to request inappropriate barred list checks for the wrong workforce. This is an offence, and could result in a Registered Body receiving information that are not legally entitled to.

The advice from the DBS is to ensure that the counter-signatory is legally responsible for the making sure the job role is eligible before asking a person to apply for a DBS check. You can access the eligibility tool and guidance for more support or if you have any questions you can email the DBS on