DBS Checks for Care Staff: Levels, Renewal, Update Service and CQC Rules
Which DBS check care workers need, what it costs, whether it expires, how the Update Service makes it portable, when someone can start before the certificate arrives, what CQC expects, and how CQC-countersigned checks for managers differ.
Care workers who provide regulated activity with adults are eligible for an Enhanced DBS check with an Adults’ Barred List check, and CQC’s Regulation 19 guidance says the information in Schedule 3 must be confirmed before a person is employed. A DBS certificate has no official expiry date, so whether and when to recheck is your policy decision. The DBS Update Service lets a worker keep an enhanced certificate portable for £16 a year if they join within 30 days of issue. Registered managers, partners and individual providers applying to CQC need a different check: a CQC-countersigned enhanced DBS.
DBS checks are a routine part of care recruitment and one of the most misunderstood. Providers mix up levels, assume certificates expire, or confuse the check care staff need with the CQC-countersigned check managers need for registration. This guide sets out the rules from GOV.UK, CQC and the regulations, so your policy matches what is actually required.
Key takeaways
- Adult care roles that are regulated activity are eligible for an Enhanced DBS with an Adults’ Barred List check.
- There is no official expiry date for a DBS certificate. You decide whether to recheck, and should have a written policy.
- The Update Service costs £16 a year, must be joined within 30 days of the certificate being issued, and only works for the same workforce and level.
- An Adult First check (£6) can allow a supervised start before the certificate arrives, but CQC expects Schedule 3 information to be confirmed before employment.
- CQC-countersigned DBS checks are for people applying to CQC as managers, partners or individual providers. CQC does not accept Update Service checks for registration.
In this guide
- Which DBS Check Do Care Staff Need?
- What CQC Expects: Regulation 19 and Schedule 3
- CQC-Countersigned DBS: For Managers and Providers, Not Care Staff
- Can Someone Start Before the Certificate Arrives? Adult First
- Does a DBS Certificate Expire? Renewal Rules
- The DBS Update Service and Portability
- Convictions, Barring and Making the Decision
- DBS Checklist for a Care Provider
- Frequently asked questions
Which DBS Check Do Care Staff Need?
GOV.UK says that if you are employing someone to do regulated activity with adults, you can ask them to apply for an Enhanced DBS check with an Adults’ Barred List check. Regulated activity with adults includes providing personal care such as help with eating, drinking, toileting, washing, dressing and oral care when the person cannot do this for themselves, providing healthcare under the direction or supervision of a healthcare professional, social work, some help with an adult’s cash, bills and shopping, and conveying adults to care services (GOV.UK: Regulated activity with adults). When you request a check for someone doing regulated activity you are a “regulated activity provider”, which carries a legal duty to refer an individual to the DBS where the conditions are met.
Fees quoted by GOV.UK for the DBS checks themselves are below. They are set by the DBS and can change, and organisations that submit applications for you may add their own charges (GOV.UK: DBS check requests, guidance for employers).
| Check | DBS fee | For care staff |
|---|---|---|
| Basic | £21.50 | Not enough for roles doing regulated activity |
| Standard | £21.50 | Not enough for roles doing regulated activity |
| Enhanced | £49.50 | Includes police information but no barred list check |
| Enhanced with Barred List(s) | £49.50 | The check for regulated activity with adults, with the Adults’ Barred List |
| Adult First | £6 | Quick Adults’ Barred List check, see below |
The Enhanced with Barred Lists check is only available for people carrying out regulated activity and a small number of listed positions, and the employer must be legally entitled to ask the “exempted question”. Using the wrong level or workforce is a gap you can be asked about.
What CQC Expects: Regulation 19 and Schedule 3
Regulation 19 requires providers to employ people of good character and to run effective recruitment procedures. CQC’s guidance says the information in Schedule 3 of the regulations must be confirmed before people are employed, that providers should record their reasons if they consider a candidate suitable despite information within Schedule 3, and that where checks are done by another party the provider must assure itself they are complete and satisfactory (CQC: Regulation 19). Schedule 3 includes proof of identity with a recent photograph, and, where required, an enhanced criminal record certificate with barring information, alongside satisfactory evidence of conduct in previous employment, references, qualifications, a full employment history with explained gaps, and information about health conditions relevant to the role (legislation.gov.uk: Schedule 3). For a full list, see our care staff recruitment file checklist and the fit and proper persons requirement.
CQC-Countersigned DBS: For Managers and Providers, Not Care Staff
A different check applies to people applying to register with CQC. CQC says anyone applying as an individual provider, registered partner or registered manager must include an enhanced DBS check with the appropriate barred list information, and if they are not a registered healthcare professional it must be CQC countersigned. CQC also says (CQC: DBS checks for CQC registration):
- the DBS check must be no more than 12 months old, or the application is rejected without further review;
- it cannot accept certificates from the DBS Update Service, or from third-party services, unless they meet its criteria;
- it can take up to 60 working days to receive the certificate, and you cannot submit your application until you have it;
- registered healthcare professionals with certain regulators still need an enhanced DBS with barred list information, but it need not be CQC countersigned.
See how to register with CQC and changing a registered manager.
Can Someone Start Before the Certificate Arrives? Adult First
GOV.UK describes DBS Adult First as a service that lets organisations request a check of the Adults’ Barred List so that, depending on the result, a person can be permitted to start work under supervision with vulnerable adults before a DBS certificate has been obtained. The strict criteria are that the position must legally require a criminal record check, must be eligible for the Adults’ Barred List, and the application form must request the barred list check. The reply says either that the registered body must wait for the certificate, or that no match exists on the current Adults’ Barred List, and it forms only the first part of the check, with further information to follow (GOV.UK employer guidance).
Because CQC’s Regulation 19 guidance says Schedule 3 information must be confirmed before employment, you should be able to show how any supervised start meets that requirement, and keep the risk assessment. Our advice is to treat it as an exception and never leave the person unsupervised with residents until the full certificate is back.
Risky vs defensible
Risky: a new starter works shifts alone because “the DBS is probably fine”. Defensible: Adult First result recorded, full application pending, risk assessment written, worker always paired with a checked colleague, reviewed daily.
Does a DBS Certificate Expire? Renewal Rules
GOV.UK says there is no official expiry date for a criminal record check issued by the DBS. Information on a certificate is accurate at the time of issue, so you should check the date of issue to decide whether to request a newer one, and in certain sectors a new check may be required periodically. It also says you may be required by law to carry out a fresh check of the Barred Lists under sector-specific guidance, and that it is the employer’s decision whether to accept a previously issued certificate (GOV.UK).
So there is no fixed legal renewal period to quote. Many providers choose to recheck periodically and to use the Update Service, but that is a policy choice. Write down your rule, apply it to everyone, and audit it as part of staff file checks. See how to carry out a care home audit.
The DBS Update Service and Portability
The Update Service lets applicants keep standard and enhanced certificates up to date and lets employers check them (GOV.UK: DBS Update Service). Key rules:
| Point | What GOV.UK says |
|---|---|
| Cost | £16 a year; free for volunteers who meet the conditions |
| When to join | Within 30 days of the certificate being issued (a reprint does not restart the 30 days) |
| Which checks | Standard and enhanced only, not basic |
| Subscription | Lasts one year. If not renewed you need a new DBS check and must register again |
| Employer status check | You must be legally entitled to do the check and have the worker’s permission. There is no charge and results show straight away |
| Portability limits | Works from one role to the next unless the organisation asks for a new certificate, the workforce differs (adult vs child), or the level differs (standard vs enhanced) |
The 30-day rule comes from the DBS employer guidance too. A status check tells you whether anything has changed, and the employer still decides whether to accept a previously issued certificate. Remember CQC does not accept Update Service checks for registration applications.
Convictions, Barring and Making the Decision
An Enhanced with Barred Lists check includes police information and a check against the Adults’ Barred List, and the DBS has a statutory duty to consider any information suggesting a person may pose a risk of harm. Beyond barring, disclosed convictions call for a judgement. The DBS code of practice says information on a certificate should only be used in the context of a policy on the recruitment of ex-offenders, designed to protect applicants from unfair discrimination based on non-relevant past convictions (GOV.UK). Under CQC’s Regulation 19 guidance you should record your reasons where you decide a candidate is suitable despite information in Schedule 3.
In practice, have a written, consistent approach that considers relevance to the role, how long ago, and any pattern, rather than a blanket rule either way. The code of practice also says certificate information should be kept only for the purpose it was obtained and destroyed after a suitable period, usually no longer than 6 months, so record your decision and the check details rather than keeping the disclosure itself. See GDPR and care home records.
DBS Checklist for a Care Provider
- Enhanced DBS with Adults’ Barred List for every role that is regulated activity with adults.
- Schedule 3 information confirmed and filed before employment, with reasons recorded where a disclosure was judged not to prevent employment.
- A written policy on recruiting people with convictions, following the DBS code of practice.
- A written rule for rechecks and use of the Update Service, applied to everyone.
- Any Adult First or supervised start risk-assessed and time-limited.
- CQC-countersigned checks ready for registered managers, partners and individual providers applying to CQC, within 12 months.
- Certificate information stored and destroyed in line with the code of practice.
Keep recruitment and governance evidence in one place
CQCLogic’s policy register holds your recruitment and DBS policies with owners and review dates, and its supervision and training logs sit alongside. Get started free or view a sample improvement plan. See also how to hire a registered manager.
Frequently Asked Questions
What DBS check does a care worker need?
A care worker doing regulated activity with adults is eligible for an Enhanced DBS check with an Adults’ Barred List check. Basic and standard checks do not include barred list information.
How often do DBS checks need to be renewed for care staff?
GOV.UK says there is no official expiry date for a DBS certificate, so there is no fixed legal renewal period. It is your policy decision, and you should write down when you recheck and apply it consistently.
What is the DBS Update Service and how does portability work?
It lets a certificate holder keep a standard or enhanced certificate up to date for £16 a year and lets employers check its status online with the worker’s permission. It can be reused for similar roles unless the workforce or level differs or the employer asks for a new certificate.
How long do you have to join the DBS Update Service?
Within 30 days of the certificate being issued. A reprint does not restart the 30 days.
Can a care worker start work before their DBS check comes back?
GOV.UK says an Adult First check (£6) can allow a person to start under supervision depending on the result. CQC’s Regulation 19 guidance says Schedule 3 information must be confirmed before employment, so keep a risk assessment and never leave them unsupervised with residents until the certificate is back.
What is a CQC-countersigned DBS check?
It is the enhanced DBS with barred list information that individuals, partners and registered managers applying to CQC need, unless they are certain registered healthcare professionals. It must be no more than 12 months old and CQC does not accept Update Service checks for registration.
Does a criminal conviction automatically stop someone working in care?
Not necessarily. Barring is a separate matter shown by the barred list check. For other convictions the DBS code of practice expects you to use a policy on recruiting ex-offenders, and CQC expects reasons recorded where you judge someone suitable despite Schedule 3 information.
How much does a DBS check cost for care staff?
GOV.UK lists £49.50 for an Enhanced check with Barred List(s), £6 for Adult First and £16 a year for the Update Service. Organisations that process applications may add their own charges, and fees can change.
Sources: GOV.UK: DBS check requests, guidance for employers · GOV.UK: DBS Update Service · GOV.UK: Regulated activity with adults in England and Wales · CQC: DBS checks for CQC registration · CQC: Regulation 19, fit and proper persons employed · legislation.gov.uk: Schedule 3, information required for persons employed