The latest Keeping Children Safe in Education guidance (KCSiE 2026) confirms that from 1 September 2026, the supervision exemption for volunteers is removed. 

Any volunteer who regularly helps in your school or joins a residential trip is likely to be in regulated activity and will need an enhanced DBS check with children's barred list information. 

Here's what that means in practice, and what you should be doing now to prepare.

What has changed?

The Crime and Policing Act 2026 has removed the supervision exemption from regulated activity. Previously, volunteers supervised by a member of staff weren't considered to be in regulated activity. From 1 September 2026, that exemption no longer applies.

What is regulated activity?

A person is in regulated activity with children if they:

• Work on a frequent basis in a school or other specified establishment where their work gives them the opportunity for contact with children.
• Are responsible, on a frequent basis, for teaching, training, instructing, caring for or supervising children, providing advice or guidance on their physical, emotional or educational wellbeing, or driving a vehicle used only for children.
• Engage in intimate or personal care, healthcare, or any overnight activity with children, even if this occurs on only one occasion.

Who is now in regulated activity?

A volunteer is now in regulated activity if they teach, train, instruct, care for or supervise children:

• On more than three days in a 30-day period, whether at one school or across multiple settings combined.
• Overnight, between 2am and 6am.

The overnight rule will mean that a volunteer who helps on a single residential trip is in regulated activity, regardless of how often they otherwise come into school.

All such volunteers will require an enhanced DBS check with children's barred list information. 

Checking barred list status

All schools must obtain (via the individual) an enhanced DBS check including children’s barred list information for any volunteer who will be working in regulated activity.

Where an existing volunteer will now be in regulated activity from 1 September 2026, the school must obtain an enhanced DBS check with children's barred list information. If the school wishes to allow the volunteer to continue before the full check is processed, a standalone barred list check is available as an interim measure.

Volunteers across multiple settings

Where a volunteer works across several schools, all days count cumulatively towards the period condition (more than three days in a 30-day period). Schools should coordinate to agree who applies for the check, and the volunteer then provides the result to each setting. The DBS Update Service, which is free for volunteers, is strongly recommended as it allows the check to be reused across settings.

Checking your volunteers

Audit your volunteer list now. Think about the parent who comes in every Tuesday to listen to children read. The sports coach who gives up their afternoons. The volunteer who helps run the residential trip. Any breakfast or after-school club volunteers.

For each regular volunteer, ask: Do they volunteer for more than three days in any 30-day period? Do they participate in any overnight activity? If the answer is yes to either, ensure enhanced DBS checks with children's barred list information are in place before 1 September 2026. It is a criminal offence to permit a barred person to engage in regulated activity.

Volunteers in regulated activity must also be added to the Single Central Record. 

Who is not affected?

Occasional volunteers, such as parents helping at a one-off PTA event or accompanying a day trip, are not affected. All paid staff are already in regulated activity and are unaffected by this change.

Volunteers not in regulated activity

KCSiE 2026 remains clear that under no circumstances should a volunteer on whom no checks have been obtained be left unsupervised or allowed to work in regulated activity.

Where a volunteer is not in regulated activity, schools and colleges should carry out a written risk assessment, using professional judgement to decide what checks, if any, are required. The assessment should consider:

• The nature of the role.
• What the school knows about the volunteer, including any formal or informal information from staff, parents or other volunteers.
• Whether the volunteer's other work or activities can provide references as to their suitability.

Where appropriate, schools should also consider whether a lower-level DBS check is warranted. For example, an enhanced DBS without barred list information may be suitable for infrequent volunteers who would otherwise be in regulated activity, or a basic DBS check for any volunteer who may have access to children. The outcome of the risk assessment must be recorded.

Put simply, 'not in regulated activity' doesn't mean 'no checks required.' Schools must actively assess the risk and document their decision.

KCSiE 2026 remains clear that under no circumstances should a volunteer on whom no checks have been obtained be left unsupervised or allowed to work in regulated activity.

Where no checks have been carried out on a volunteer who is not in regulated activity, supervision must be maintained at all times. Although Annex E of KCSiE 2025 no longer applies and the statutory supervision requirement has been removed, the standards previously set out in that guidance remain a useful benchmark. Those standards required that:

• The supervisor must themselves be in regulated activity.
• Supervision must be regular and ongoing, rather than concentrated at the outset of an arrangement.
• The level of supervision must be reasonable in all the circumstances for the protection of children.

What is reasonable will vary depending on factors such as the ages and vulnerability of the children concerned, the number of children involved, the nature of the volunteering role, and the ratio of adults to children.

What should schools be doing now?

The changes to regulated activity come into force on 1 September 2026, and the summer term is the time to prepare. That means reviewing your policies in light of the revised thresholds and updated expectations for volunteer checks, testing whether your operational practice reflects those changes, and updating staff training.

Brief your governors and review your safer recruitment processes to ensure they're fit for purpose from the start of the autumn term. Begin DBS checks for affected volunteers without delay so that they can continue in their roles from the start of the new academic year.

If you'd like support reviewing your volunteer arrangements ahead of September, please get in touch, we’re happy to help.