DBS Update Service Guidance Updated: What UK Employers Need to Know

The Disclosure and Barring Service (DBS) has updated its guidance for employers and organisations using the DBS Update Service, providing greater clarity around status checks, consent, checking frequency and the role of the service within safer recruitment.

The revised guidance follows recommendations from a Home Office review of the Update Service and is intended to help organisations understand both what the service can provide and its limitations.

For employers recruiting into roles where criminal record checks are appropriate, the guidance reinforces an important principle: a DBS Update Service status check can support workforce assurance, but it should form part of a wider, proportionate screening and safeguarding process.

What Has Changed in the DBS Update Service Guidance?

DBS announced the revised guidance on 25 August 2026, with the employer guide subsequently updated on 28 August.

The guidance provides clearer information on how employers can legally use the Update Service, how status results should be interpreted and how organisations should decide when subsequent status checks may be appropriate.

It also reinforces that the Update Service should not be relied upon in isolation.

Depending on the role, a broader screening programme may include:

• Identity verification.
• Right to Work verification.
• Employment history checks.
• Investigation of material employment gaps or inconsistencies.
• Qualification and professional registration verification.
• Employment references.
• Appropriate criminal record screening.

Conflict International provides Pre-Employment Screening Services for organisations requiring a wider programme of candidate verification alongside role-appropriate criminal record checks.

What Is the DBS Update Service?

The DBS Update Service is an online subscription service available to individuals with eligible Standard or Enhanced DBS certificates.

Where the relevant conditions are satisfied, an employer or organisation can carry out an online status check to establish whether new information has been identified since the certificate was issued.

This can reduce the need for an individual to obtain a completely new certificate every time they change jobs, provided the existing DBS certificate remains appropriate for the new role.

However, portability is not automatic.

The employer must still establish that the certificate is suitable for the position, including whether it covers the correct level of check and relevant workforce.

The Update Service applies to Standard and Enhanced DBS certificates. It cannot be used for Basic DBS checks.

Employers requiring a new certificate can find more information about Basic, Standard and Enhanced DBS Checks.

Employers Must Have the Individual's Consent

The updated guidance places clear emphasis on consent and lawful access.

An organisation cannot simply check an individual's DBS status because it employs them or has previously obtained a DBS certificate.

Before carrying out a status check, the organisation must have the individual's consent and must be legally entitled to request the same level of DBS information for the role concerned.

Employers must also ensure that the certificate relates to the appropriate workforce and level of check.

DBS identifies three workforces:

• Child.
• Adult.
• Other.

An existing certificate cannot necessarily be used for a new position simply because both roles require DBS screening.

Where a different workforce, level of certificate or barred-list information is required, a new DBS application may be necessary.

Consent must also remain valid. If an individual leaves the organisation, moves into a position where the employer no longer has legal entitlement to the information, or withdraws consent, further status checks should not be undertaken.

There Is No Fixed DBS Update Service Checking Frequency

Another important clarification concerns how frequently employers should carry out status checks.

DBS does not prescribe a universal timetable.

Instead, organisations are advised to determine an appropriate risk-based checking schedule, taking into account factors such as:

• The nature of the employee's role.
• The potential level of risk.
• Applicable regulatory requirements.
• The organisation's safeguarding policies.

This can be particularly relevant for employers operating in sectors where staff work with children, vulnerable adults or in other positions involving significant responsibility or trust.

A proportionate approach may mean that some positions justify more frequent checks than others.

Employers should therefore be able to explain why they have adopted a particular checking schedule rather than automatically applying the same frequency across every position.

The Update Service Is Not Automatic Employer Monitoring

Employers should also understand what happens behind the scenes.

DBS carries out searches for certain categories of new information relating to certificates registered with the Update Service.

However, employers are not automatically alerted simply because the status of an individual's certificate changes.

An organisation must carry out an appropriate status check, with the individual's consent, to establish whether the certificate remains current.

This is an important distinction when designing employment screening procedures.

An employee being subscribed to the Update Service should not be treated as an automatic monitoring or alert system, nor as a substitute for an organisation's wider safeguarding and employment responsibilities.

What Does a Change in DBS Status Mean?

A status check helps establish whether a certificate remains current or whether new information has been identified that could be disclosed on a new certificate of the same type and level.

If the certificate is no longer current, employers should not attempt to infer what the underlying information might be.

Instead, an appropriate next step may be to obtain a new DBS certificate so that any relevant information can be considered properly and fairly in accordance with the organisation's recruitment, safeguarding and employment procedures.

A change in status should not automatically be treated as proof that an individual is unsuitable for employment.

Employment decisions should be based on information the organisation is legally entitled to consider and its relevance to the responsibilities of the particular role.

Why DBS Checks Should Form Part of Wider Pre-Employment Screening

Criminal record checking provides only one part of the information an employer may need when making a recruitment decision.

Depending on the position, a proportionate screening programme could also include verification of:

• Identity.
• Right to Work.
• Employment history.
• Academic qualifications.
• Professional registrations.
• References.
• Regulatory information.

International candidates can require additional consideration where they have previously lived or worked outside the UK, as a UK DBS certificate does not provide a complete record of criminal history held in other jurisdictions.

Conflict International's Pre-Employment Screening Services can combine appropriate criminal record screening with other candidate verification checks according to the role, jurisdiction and employer's requirements.

What Should Employers Do Now?

Organisations using the DBS Update Service should review the latest guidance and consider whether their existing procedures remain appropriate.

Employers should ensure that:

• Status checks are only undertaken where there is appropriate legal entitlement.
• Candidate or employee consent has been obtained.
• The certificate is at the correct level and relates to the appropriate workforce.
• The individual's identity and original certificate have been appropriately verified.
• The organisation has a documented, risk-based approach to subsequent checks.
• Update Service checks form part of wider recruitment and safeguarding procedures rather than being relied upon in isolation.

The August 2026 guidance provides employers with greater clarity about how the Update Service should be incorporated into recruitment and ongoing employment procedures.

For organisations requiring a new criminal record check, Conflict International provides DBS Checks at the appropriate level where eligibility requirements are met, alongside wider Pre-Employment Screening Services for UK and international recruitment.