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- Jan 27, 2026
The Self-Employed DBS Change That Just Happened (And What It Actually Means for You)
21 January 2026.
Six days ago, a legislative change came into force that affects thousands of self-employed workers across the UK.
If you're a freelance care worker, a personal assistant, a tutor, or any self-employed person working with vulnerable groups, you can now apply for your own Enhanced DBS check.
Before this date? You couldn't.
You had to find an employer or organisation willing to process it for you. Many self-employed workers simply couldn't get the checks they needed to work legally.
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).
What Changed on 21 January 2026?
The Disclosure and Barring Service (DBS) updated its guidance to allow self-employed individuals and personal employees to apply directly for Enhanced DBS checks.
This includes Enhanced checks with Barred List checks.
Who does this affect?
Self-employed workers in regulated activity with children and/or adults. Personal assistants paid to provide care. Private tutors working one-to-one with vulnerable individuals. Freelance healthcare professionals. Anyone carrying out activities that would have been regulated activity before Section 66 of the Protection of Freedoms Act 2012.
The change specifically covers three scenarios:
Those in regulated activity with children and/or adults (Enhanced with Barred List check)
Those carrying out activities which would have been regulated activity before 2012 (Enhanced check)
Those carrying out activities with children infrequently which, if done frequently, would be regulated activity (Enhanced check)
What hasn't changed?
You still can't request a DBS check for someone you're planning to hire. That responsibility stays with the recruiting organisation.
Organisations can still apply for checks on behalf of self-employed contractors. Their existing processes remain valid.
Why This Matters Now
Since 2006, we ran screening companies and saw this problem repeatedly.
A self-employed carer leaves an agency. She wants to work privately with a family. The family wants to employ her. Both parties want a DBS check. Neither could get one processed.
The carer wasn't employed by an organisation. The family couldn't countersign the form. The work couldn't legally begin.
Some found workarounds. Many just worked without checks. The safeguarding gap was obvious.
From 21 January 2026, this changes.
But—and this is important—it's not automatic.
The Umbrella Body Requirement
You can't just log onto gov.uk and order your own Enhanced DBS check.
You need to go through an Umbrella Body.
An Umbrella Body is a DBS-registered organisation that:
Confirms your eligibility for the check level you're requesting
Verifies your identity documents
Countersigns your application
Advises whether your role meets legal criteria for Enhanced checks
Think of them as the administrative bridge between you and the DBS.
Why can't you apply directly?
Because Enhanced DBS checks require someone to confirm you're eligible. The DBS can't verify your work activities. An Umbrella Body can.
This prevents misuse. It stops people requesting Enhanced checks when they're only eligible for Basic checks.
The Three Steps to Get Your Check
Step 1: Confirm Eligibility
Use the DBS eligibility guidance on gov.uk or speak to an Umbrella Body.
Ask yourself: Am I in regulated activity? Do I work directly with children or vulnerable adults? Is my work frequent, intensive, or overnight?
If you're not sure, don't guess. Contact an Umbrella Body. They'll advise you.
Step 2: Find an Umbrella Body
Not all Umbrella Bodies offer services to individuals. Some only work with organisations.
You need to find one that processes applications for self-employed workers.
Ask them:
Do you process Enhanced DBS checks for individuals?
What's the cost?
What documents do I need?
How long does it take?
Do you offer Digital ID checks?
Step 3: Provide Your Information
You'll need:
Current personal details
Any name changes (including marriage or deed poll)
Five-year address history
Identity documents (must be verified by someone who isn't a spouse or relative)
Some Umbrella Bodies offer Digital ID checks. This removes the need for a manual identity check. Use this option if available.
Training Tip: Our Understanding DBS Checks (UK) Course (£49) covers eligibility, application processes, and the differences between check levels. It's CPD Certified and designed for employers and individuals navigating DBS requirements.
What If Your Role Isn't Eligible?
If you're not in regulated activity, you won't be eligible for an Enhanced check.
You can still get a Basic DBS check.
Basic checks show unspent convictions only. Anyone can apply for them. You don't need an Umbrella Body.
Apply directly through DBS or a Responsible Organisation.
Cost: £26 (as of January 2026)
Processing time: Usually 5-14 days
Basic checks are often sufficient for roles that involve working with the public but not in regulated activity.
The Digital ID Change (October 2025)
Whilst we're discussing recent changes, there's another update you should know about.
On 22 October 2025, the DBS updated its identity verification guidance.
The changes include:
Revised list of accepted documents
Separate processes for Right to Work checks and DBS checks (no longer combined)
Unified three-route process for all applicants
Digital ID checks now available through some providers
Why does this matter?
If you're applying for a DBS check now, make sure you're following the October 2025 guidance. Old lists of acceptable documents may no longer be valid.
Your Umbrella Body should guide you, but it's worth checking gov.uk for the most current ID requirements.
Read more about DBS ID changes
Common Questions (And Honest Answers)
Can I use my DBS certificate for multiple clients?
Yes. Once issued, your DBS certificate belongs to you. You can show it to multiple clients or organisations.
However, each organisation has the right to request their own check if they prefer.
How long does my certificate last?
DBS certificates don't expire. But they only show your criminal record status on the date of issue.
Many organisations have policies to renew checks every 1-3 years.
Should I join the Update Service?
Probably.
The DBS Update Service costs £16 per year (free for volunteers). It allows organisations to check your certificate status online.
You must subscribe within 30 days of your certificate being issued. If you request a reprint, the 30-day window still applies from the original certificate date (not the reprint date).
Learn more in our Pre-Employment Screening & Vetting Essentials Course (£79)
What if I've lived outside the UK?
DBS checks only cover England and Wales criminal records.
If you've lived abroad, you may need additional checks:
Northern Ireland: Access NI
Scotland: PVG (Protecting Vulnerable Groups) scheme
Overseas: Criminal record checks from relevant countries
Many organisations require both UK and overseas checks. Plan for this. Overseas checks can take months.
Can organisations still apply on my behalf?
Yes.
The 21 January 2026 change gives self-employed people the option to apply themselves. It doesn't remove the ability for organisations to apply on your behalf.
If you're working through an agency or for an organisation, they'll likely continue their existing DBS processes.
The Pharmacy Example
Here's a practical example of how this change works in practice.
From March 2026, all registered pharmacy professionals must hold a valid Enhanced DBS check under the Pharmacy Quality Scheme (PQS) 2025/26.
Locum pharmacists—often self-employed—previously struggled to obtain Enhanced checks. They worked through agencies or relied on organisations to process checks.
After 21 January 2026, locum pharmacists can apply directly through an Umbrella Body.
This speeds up the process. It gives them control. It ensures compliance before March 2026.
Have you checked whether your sector has similar upcoming requirements?
Training Tip: Our Global Background Screening Awareness Course (£69) covers international screening requirements, particularly useful if you work with overseas clients or have lived abroad.
What We're Seeing Now (Late January 2026)
It's been less than a week since the change.
Umbrella Bodies are adjusting their processes. Some are ready. Some aren't.
We're hearing reports of:
Inconsistent guidance from different providers
Confusion about eligibility criteria
Questions about Digital ID verification
Uncertainty about costs
This is normal for new legislation. Give it a few weeks. Processes will settle.
If you're applying now, expect some back-and-forth. Be patient. Keep records of all communications.
Five Things to Do This Week
1. Check Your Eligibility
Visit gov.uk and use the DBS eligibility tool. Confirm which level of check you actually need.
Don't assume. Many people think they need Enhanced checks when Basic checks are sufficient.
2. Research Umbrella Bodies
Make a list of three potential providers. Compare costs, processing times, and services offered.
Ask about Digital ID options. This can significantly speed up the process.
3. Gather Your Documents
Start collecting:
Proof of address (last five years)
Name change documents (if applicable)
Current identification
National Insurance number
Having these ready prevents delays.
4. Inform Current Clients
If you're self-employed, tell your clients about the change.
Explain that you're obtaining your own Enhanced DBS check. Ask if they need anything from you during the process.
5. Consider the Update Service
If you're planning to work with multiple clients, the Update Service makes sense.
Budget for the £16 annual fee. Subscribe within 30 days of receiving your certificate.
Our Understanding DBS Checks course walks through the entire Update Service process, including common pitfalls.
The Bigger Picture
This change aligns with broader shifts in UK employment.
More people work freelance. The gig economy continues to grow. Self-employment in care, education, and health sectors increases every year.
Traditional employment structures don't fit modern work patterns. Safeguarding systems need to adapt.
The 21 January 2026 change is part of that adaptation.
It's not perfect. Umbrella Bodies add cost and complexity. But it's significantly better than the previous system where self-employed workers simply couldn't get checks at all.
We launched Vetting Hub in 2025 specifically to address gaps like this. After 19 years running screening companies, we saw how regulation changes faster than understanding.
Our CPD Certified courses exist to bridge that gap. We keep them updated as legislation evolves.
What Happens Next?
More changes are coming.
The DBS launched its 2025-26 Business Plan in late 2025. Priorities include:
Embracing digital innovation
Improving safeguarding tools
Supporting employers with safer recruitment
Streamlining application processes
Digital ID verification is expanding. Expect this to become standard rather than optional within 12-18 months.
Cross-border checking may improve. Current systems for overseas criminal records are clunky. Reform is likely.
The Update Service may become mandatory for certain sectors. This is speculation, but the direction of travel is clear.
Take Action Today
The 21 January 2026 change creates opportunities.
If you're self-employed and working with vulnerable groups, you now have a path to proper checks.
If you're hiring self-employed contractors, you can require them to obtain their own checks.
If you're advising clients, you need to understand this change thoroughly.
Don't wait until you need a check. Start the process now.
Contact Umbrella Bodies this week. Understand costs. Gather documents. Be prepared.
The legislation is live. Use it.
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