How to Meet the March 2026 Pharmacy Enhanced DBS Requirement Without Last-Minute Chaos

31st March 2026.

That's the deadline. Every registered pharmacy professional in your pharmacy must have a valid Enhanced DBS check issued within the last three years.

Miss it? You fail the Pharmacy Quality Scheme Patient Safety domain. No payment. No second chance until next year.

You've got 62 days.

About the Authors: Graham and Vivianne Johnson ran screening and vetting companies from 2006 to 2025. They launched Vetting Hub in 2025 to make their 19 years of operational knowledge accessible at cost-effective prices. All Vetting Hub courses are CPD Certified and VH Courses is listed on the UK Register of Learning Providers (UKRLP: 10006126).

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The Pharmacy Quality Scheme 2025/26 introduced this requirement to align pharmacy with wider NHS safeguarding standards. From 2006 to 2025, we ran screening companies and saw healthcare organisations scramble at the last minute. The pharmacies that get this right start now.

What the Requirement Actually Says

Let's be precise. The PQS Patient Safety domain states:

By 31st March 2026, all registered pharmacy professionals (pharmacists and pharmacy technicians) working at your pharmacy on the day of declaration must have:

• An Enhanced DBS check certificate issued between 1st April 2023 and 31st March 2026, OR

• A status check completed using the DBS Update Service showing the certificate is current

The certificate must show it was issued within the last three years. If someone has a certificate dated 15th March 2023, it's valid. If it's dated 31st March 2023, it's also valid.

If it's dated 30th March 2023? It's outside the window. You need a new check.

This includes locums working on declaration day. If they're working at your pharmacy when you make your PQS declaration, they need a valid Enhanced DBS check on file.

Step 1: Audit Who You Actually Need to Check

Don't assume you know who needs checking. Check.

Create a spreadsheet. List every registered pharmacy professional who works at your pharmacy:

• Full-time pharmacists

• Part-time pharmacists

• Regular locums

• Pharmacy technicians

• Anyone who might work a shift during declaration period (2nd-27th February 2026)

For each person, record:

• Name

• Role

• Current DBS certificate number (if they have one)

• Certificate issue date

• Certificate expiry status

Common mistake: Assuming your regular team is covered but forgetting about the locum who covers Saturdays or the pharmacy technician who only works Tuesdays and Thursdays.

Our Understanding DBS Checks (UK) course (£49) walks through exactly which roles require which level of DBS check and how to audit your current compliance position.

Step 2: Identify Your Gaps

Now you know who you need to check. Who's actually compliant?

Sort your list into three categories:

Category A: Compliant

• Has Enhanced DBS certificate dated between 1st April 2023 and today

• OR enrolled in DBS Update Service with valid status

Category B: Needs Urgent Action

• Has Enhanced DBS but certificate dated before 1st April 2023

• OR has Standard/Basic DBS (wrong level)

• OR has no DBS at all

Category C: In Progress

• Application submitted, awaiting certificate

• Application needs to be submitted this week

Category B is your priority. These people need new applications submitted immediately.

The timeline reality:

Most Enhanced DBS checks take 2-8 weeks. Some police forces (Hampshire, Kent, Sussex, Thames Valley) are experiencing backlogs. If you submit today, you're looking at late March for certificate arrival.

That's cutting it close.

Step 3: Submit Applications for Anyone Without Current Checks

If someone's in Category B, you need to act this week.

The application process:

1. Registered Body provides application form

2. Candidate completes personal details

3. Employer verifies identity documents in person

4. Application submitted to DBS

5. Certificate issued to candidate (who shows it to employer)

Identity verification is where applications fail.

The candidate needs to provide original documents from the approved list. Photocopies don't count. Scanned PDFs don't count. The physical document, in your hands.

Since October 2025, DBS updated their identity verification guidance. There are now three routes:

• Route 1: Passport or driving licence plus two further documents

• Route 2: Birth certificate plus three further documents

• Route 3: Five documents from the approved list

Most people use Route 1. It's fastest.

Common errors that delay applications:

• Checking a photocopy instead of original document

• Accepting documents with different names without seeing change documentation

• Failing to verify current address properly

• Incomplete application forms

We saw these mistakes repeatedly from 2006 to 2025. They add weeks to your timeline.

The Pre-Employment Screening & Vetting Essentials course (£79) covers the complete identity verification process and how to avoid the common errors that cause DBS applications to be rejected or delayed.

Step 4: Enrol Everyone in the DBS Update Service

Here's what most pharmacies miss: the Update Service.

For £16 per year, pharmacy professionals can subscribe to the DBS Update Service. Once subscribed, you can check their DBS status online instantly. No new application needed. No waiting weeks for certificates.

Why this matters for March 2026:

If someone's Enhanced DBS certificate was issued on 15th April 2023, it's valid until 14th April 2026. That's after your deadline. They're compliant.

But what if they got their certificate on 20th March 2023? They need a new check before 31st March 2026. That means submitting an application now and hoping it comes back in time.

Unless they're enrolled in the Update Service.

If they enrolled within 30 days of their original certificate being issued, you can run a status check instead. The status check counts towards your PQS requirement.

Action: Every pharmacy professional who gets a DBS check between now and March should enrol in the Update Service within 30 days. It costs £16. It saves you from this exact situation in 2029.

Step 5: Understand What Evidence You Must Keep

The PQS requirement isn't just about having the checks. It's about proving you have them.

You must retain evidence that demonstrates:

• All registered pharmacy professionals working on declaration day have valid Enhanced DBS checks

• Certificates were issued between 1st April 2023 and 31st March 2026

• OR status checks were completed using the Update Service

This evidence must be:

• Available for inspection from 31st March 2026

• Kept for three years (until 31st March 2029)

• Available at premises level for post-payment verification

What counts as evidence:

• Copy of DBS certificate (front page showing issue date and certificate number)

• Printout of DBS Update Service status check result

• Record showing which staff were working on declaration day

What doesn't count:

• "We definitely checked everyone" (not documented)

• Email from staff member saying "I have a DBS" (no certificate copy)

• Certificate dated before 1st April 2023

Create a physical or digital file for each pharmacy professional. When they show you their certificate, photocopy it immediately. File it. Date it. Note who verified it.

Our Creating a Screening Policy & Framework course (£89) includes templates for record-keeping systems that meet regulatory requirements and makes audit preparation straightforward.

Step 6: Plan for Locum Cover

This is where pharmacies get caught out.

You've checked your regular team. Everyone's compliant. Then on 15th February (during declaration period), your usual Saturday pharmacist calls in sick. You book a locum.

Does that locum have a valid Enhanced DBS check?

The requirement states: "all registered pharmacy professionals working at the pharmacy on the day of the declaration."

If you make your declaration on 20th February, and the locum works on 20th February, they must have a valid Enhanced DBS.

Your options:

1. Only use locums who can provide proof of current Enhanced DBS

2. Keep a pre-approved list of locums you've already verified

3. Schedule your declaration for a day when only verified staff are working

Most pharmacies choose option 3. They pick a quiet Monday or Tuesday, ensure only verified staff are scheduled, and make the declaration that day.

Document this decision. Note in your records: "Declaration made on [date]. The following registered pharmacy professionals were working: [names]. All hold valid Enhanced DBS checks issued [dates]."

Step 7: Handle the "In Progress" Applications

What if you submit applications now but certificates haven't arrived by 31st March?

The PQS allows for this. When making your declaration, you'll report:

• Number of registered pharmacy professionals who have completed Enhanced DBS and received certificate since 1st April 2023

• Number who have not yet completed but will undertake this requirement between declaration day and 31st March 2026

The second category is your safety net. You can declare that applications are in progress.

But you must have evidence:

• Proof the application was submitted

• Application reference number

• Reasonable expectation certificate will arrive by 31st March

If it's 25th February and you haven't even submitted the application yet, you can't claim it's "in progress."

Submit applications immediately. Track reference numbers. Follow up if certificates haven't arrived within four weeks.

What Happens If You Don't Meet the Requirement

You fail the Patient Safety domain. You receive no PQS payment for that domain.

The PQS 2025/26 operates on a points system:

• Gateway criterion: Must be met (registered for Pharmacy First and Pharmacy Contraception services)

• Domain 1: Medicines Optimisation (points available)

• Domain 2: Patient Safety (points available)

The Enhanced DBS requirement is part of Domain 2. If you fail any criterion within a domain, you fail the entire domain.

The scheme has £30 million in total funding. Payments per point range from £57.50 to £115 depending on your prescription volume band.

Missing this requirement costs you real money.

Beyond the financial penalty, you're also non-compliant with NHS safeguarding standards. If your local NHS team or CQC inspects and finds gaps in your DBS checking, that's a separate compliance issue.

Common Questions Pharmacy Owners Ask

"Can I accept a Standard DBS instead of Enhanced?"

No. The requirement specifically states Enhanced DBS. Standard checks don't include local police information. They're not equivalent.

"What if my pharmacy technician refuses to get a DBS check?"

Then they can't work at your pharmacy during the declaration period. The requirement is mandatory for registered pharmacy professionals.

If someone refuses, you either:

• Don't schedule them during declaration period, OR

• Accept you won't meet the PQS requirement

"Do dispensers and counter staff need Enhanced DBS checks?"

For PQS purposes, no. The requirement applies only to registered pharmacy professionals (pharmacists and pharmacy technicians registered with the GPhC).

However, you might still want Enhanced DBS checks for other staff as part of broader safeguarding. That's a separate decision.

The CQC Screening Standard course (£79) explains screening requirements for healthcare settings beyond just the PQS mandate.

"Can I use a DBS certificate from another healthcare employer?"

Yes, if it meets the requirements (Enhanced level, issued between 1st April 2023 and 31st March 2026). The pharmacy professional can show you their certificate from their other role.

Better still: if they're enrolled in the Update Service, you can check their status online with their permission. You don't need to see the physical certificate.

"What if someone's certificate is dated 1st April 2023 but we're now at 31st March 2026?"

That's exactly three years. It's valid. The requirement states "within the last three years" and defines that as between 1st April 2023 and 31st March 2026.

1st April 2023 is within that window. You're compliant.

"Should I pay for my staff's DBS checks?"

That's your decision. Many employers cover the cost (£52.20 for Enhanced DBS) as part of compliance costs. Some ask employees to pay and reimburse on receipt of certificate.

What you can't do is make employment conditional on someone paying for their own DBS and then not reimburse them. That potentially breaches employment law around deductions from wages.

Why This Matters Beyond PQS Compliance

The Enhanced DBS requirement isn't just about ticking a box for PQS funding.

Pharmacy services are expanding. You're delivering more clinical services. Vaccinations. Contraception consultations. Blood pressure checks. Pharmacy First consultations.

You're providing healthcare directly to vulnerable people.

Enhanced DBS checks include local police information that might be relevant to someone's suitability for healthcare work. A Standard check only shows convictions. An Enhanced check might include soft intelligence about behaviour, allegations, or concerns that didn't result in conviction but are relevant to safeguarding.

From 2006 to 2025, we processed thousands of DBS checks for healthcare employers. The Enhanced checks revealed information that Standard checks missed. Not often. But when it happened, it mattered.

We launched Vetting Hub in 2025 specifically to help organisations like yours understand why these requirements exist and how to meet them properly.

The GDPR Training Course (£45) covers how to handle DBS certificates as sensitive personal data, including retention limits, secure storage, and data subject rights.

Your 62-Day Action Plan

This week (28th January - 3rd February):

• Complete audit of all registered pharmacy professionals

• Identify who needs new DBS checks

• Submit urgent applications

Week of 3rd February:

• Follow up on any pending applications

• Enrol all new certificate holders in Update Service

• Create evidence files for each professional

Week of 10th February:

• Chase any applications submitted in late January

• Verify locum cover arrangements

• Decide declaration date

Week of 17th February (Declaration Period):

• Choose declaration date with only verified staff working

• Complete PQS declaration on MYS portal

• File evidence securely

Through March:

• Receive remaining certificates

• Complete evidence files

• Prepare for potential PPV inspection

By 31st March 2026:

• All certificates received and filed

• Evidence ready for inspection

• Compliance achieved

What Happens After March 2026

You'll need to repeat this process.

The requirement is for certificates issued "within the last three years." That means:

• Certificates issued April 2023 will expire April 2026

• Certificates issued January 2024 will expire January 2027

• And so on

If you want to avoid this exact situation in 2029, get everyone enrolled in the DBS Update Service now. Then you can run status checks instead of full new applications.

The Update Service costs £16 per year per person. For a pharmacy with five registered professionals, that's £80 annually.

Compare that to the cost of five new Enhanced DBS checks every three years: £261. Plus the administrative time. Plus the stress of managing five applications and hoping they all arrive before deadline.

The Update Service pays for itself.

Training Tip: When you receive a DBS certificate, verify it immediately. Check the issue date, certificate number, and level of check. Make a copy for your records. Then ask the person to enrol in the Update Service within 30 days. The 30-day window starts from the certificate issue date, not from when you receive it. If they miss the window, they can't enrol until they get a new check.

Getting This Right

62 days is enough time if you start now.

It's not enough time if you start in mid-March.

The pharmacies that meet this requirement are the ones that treat it as a priority project. They assign someone to own it. They track progress weekly. They don't assume it's being handled by someone else.

You've built your pharmacy into a valued community service. You've expanded into clinical services. You've registered for Pharmacy First and Pharmacy Contraception because you want to provide better care.

Don't lose your PQS payment because you missed a DBS deadline.

All VH Courses are CPD Certified and delivered through our UKRLP-registered platform (UKRLP: 10006126). The training we provide now comes from the 19 years we spent running operational screening companies before launching Vetting Hub in 2025.

Learn more about our approach →

Related Training

Understanding DBS Checks (UK) - £49
Complete guide to DBS levels, eligibility, application process, and common errors that delay certificates.

Pre-Employment Screening & Vetting Essentials - £79
Comprehensive screening processes including identity verification, document checking, and record-keeping requirements.

Creating a Screening Policy & Framework - £89
Develop organisation-wide screening policies with templates for documentation, evidence retention, and audit preparation.

Digital ID & GPG45 Compliance - £59
Modern identity verification methods including digital ID, GPG45 standards, and right to work integration.

GDPR Training Course - £45
Handle DBS certificates as sensitive personal data with proper retention, security, and data subject rights.

Risk Assessment in Background Screening Employees - £59
Make informed decisions about DBS disclosure results and assess suitability for specific roles.

UK Employment Screening & Legal Compliance Essentials Bundle
Complete bundle covering DBS, right to work, screening policies, and GDPR compliance for healthcare employers.

Further Reading

Complete Guide to Employee Screening & Vetting Training in the UK

BS7858 Training Guide for UK Employers

Published: Wednesday, 28th January 2026
Category: Right to Work & Identity Training
Authors: Graham and Vivianne Johnson, Vetting Hub