Enhanced DBS Checks for Self-Employed People: What Changed in 2026?
significant change to the Disclosure and Barring Service process came into force on 21 January 2026.
Eligible self-employed people and personal employees can now apply for Enhanced and Enhanced with Barred List(s) DBS checks through an approved DBS Umbrella Body.
The change removes a long-standing practical difficulty for people working directly for private individuals rather than through a conventional employer.
It does not, however, mean that every self-employed person can obtain an Enhanced DBS check.
Eligibility remains determined by the actual work being carried out.
What Changed on 21 January 2026?
Before the 2026 change, self-employed individuals could generally apply for a Basic DBS check themselves, but could not independently initiate an Enhanced application simply because their work might otherwise have been eligible.
An employing or contracting organisation would normally need to request the appropriate higher-level check.
From 21 January 2026, eligible paid self-employed people and personal employees can apply for:
- an Enhanced DBS check; or
- an Enhanced DBS check with the relevant Barred List or Lists,
through a DBS Umbrella Body.
A DBS Umbrella Body is a registered organisation authorised to process DBS applications on behalf of other organisations or eligible applicants.
The individual must still establish that the work they are undertaking is legally eligible for the level of check requested.
Who Does the Change Apply To?
The new route is intended for people who are paid for work that is eligible for an Enhanced DBS check but who may not have a conventional employer able to submit the application on their behalf.
This can include some:
- self-employed tutors
- personal carers
- therapists
- coaches
- instructors
- healthcare professionals
- childcare providers
- other self-employed professionals undertaking eligible work
A personal employee may also be covered.
This is someone employed directly by a private individual rather than by a company or organisation, for example a carer employed through a personal health budget or direct-payment arrangement.
The key issue is not whether somebody describes themselves as self-employed.
The work itself must meet the relevant DBS eligibility requirements.
How Does a Self-Employed Person Apply?
An eligible self-employed person or personal employee must apply through a DBS Umbrella Body that processes applications for this category of applicant.
The general process involves:
- Establishing whether the work is eligible for an Enhanced or Enhanced with Barred List(s) DBS check.
- Selecting an appropriate DBS Umbrella Body.
- Providing the required identity information and documentation.
- Completing the application through the Umbrella Body.
- Receiving the DBS certificate once the application has been processed.
The Umbrella Body may charge an administration fee in addition to the applicable DBS fee.
For a broader explanation of the different DBS levels and eligibility rules, read our guide to DBS checks.
Eligibility Has Not Been Expanded to Every Self-Employed Role
The 2026 change affects the application route, not the legal test that determines whether a role is eligible for an Enhanced DBS check.
A self-employed professional cannot obtain an Enhanced DBS check merely because they work in clients' homes or believe a higher-level certificate would be commercially useful.
The work must fall within the categories permitted by the relevant legislation.
Where the role is not eligible for a Standard or Enhanced check, a Basic DBS check may still be available.
This distinction is important because requesting or processing a higher-level check without the necessary eligibility may be unlawful.
What About Barred List Checks?
Some roles are eligible not only for an Enhanced DBS check but also for a check of the Children's Barred List, Adults' Barred List or both.
That does not mean every Enhanced application automatically includes a Barred List check.
The duties of the position must meet the separate eligibility requirements for the relevant list.
For example, certain regulated activities involving children or adults may qualify.
Applicants and organisations should therefore establish the correct level of check before an application is submitted.
What If the Self-Employed Person Works for an Organisation?
The new self-application route does not replace the existing process used where a self-employed professional is contracted by an organisation.
If a self-employed person provides services to a school, care provider, healthcare organisation or another business, the contracting organisation may still be able to request the relevant DBS check on their behalf.
The organisation's own safeguarding or recruitment process may therefore determine how the application is handled.
The 2026 change is particularly important for eligible people working directly for private clients where there may previously have been no recruiting organisation able to initiate the application.
What Does This Mean for Private Individuals Hiring Someone?
A private individual employing or engaging an eligible self-employed person cannot normally submit the Enhanced DBS application themselves.
Instead, the worker applies through an appropriate Umbrella Body.
Once the certificate has been issued, the person considering employing or engaging them can ask to see the DBS certificate and consider the information as part of their recruitment decision.
Where the applicant has joined the DBS Update Service, an eligible organisation or private employer may also be able to check whether the certificate remains current, subject to the applicable requirements.
A DBS Certificate Is Not a Guarantee of Suitability
The ability to obtain a higher-level DBS certificate should not be treated as proof that an individual presents no risk.
A DBS check reports criminal-record and other information according to the level of disclosure requested and the applicable rules.
It does not assess:
- professional competence
- qualifications
- employment history
- references
- future behaviour
- overall suitability for a particular role
Where appropriate, DBS screening should therefore form part of a wider recruitment or safeguarding process.
DBS Screening as Part of Wider Pre-Employment Checks
For employers and organisations, DBS checks can be incorporated into a broader screening programme where other verification is relevant to the position.
This may include:
- identity verification
- Right to Work checks
- employment-history verification
- qualifications
- professional credentials
- BPSS screening
- SMCR screening
- international background checks
- other proportionate role-specific checks
Conflict International provides DBS Check Services for organisations requiring Basic, Standard or Enhanced screening where the appropriate eligibility requirements are met.
What the 2026 Change Means in Practice
The change gives eligible self-employed professionals and personal employees a clearer route to obtain an Enhanced DBS certificate where their work genuinely qualifies.
It does not create a universal right to Enhanced screening.
The practical questions remain:
- Is the work eligible?
- Is an Enhanced check the correct level?
- Is a Barred List check legally available?
- Who should submit the application?
- How should the information be considered once the certificate is issued?
Establishing those points before applying helps avoid unnecessary or inappropriate checks.
Discuss Your DBS Requirements
Conflict International supports employers and organisations requiring DBS screening as part of recruitment, safeguarding or wider pre-employment screening.
We can coordinate individual applications as well as ongoing or higher-volume requirements and help clients determine the appropriate application route based on the roles being screened.
Complete the enquiry form below to discuss your DBS Check requirements.