If you run an alternative provision or tuition centre, you have probably been asked “is everyone’s DBS in date?” by a commissioning school, a local authority officer or a parent. The trouble is that the question assumes certificates expire, and the honest answer is more nuanced than a yes or no.
Most tutors and AP staff who teach or supervise children frequently need an enhanced DBS check with a children’s barred list check. DBS certificates have no official expiry date, so you set your own re-check policy, for example every three years or through the DBS Update Service, and record every check and date.
What are the different levels of DBS check?
The Disclosure and Barring Service offers four levels of DBS check:
- Basic: unspent convictions and conditional cautions. Anyone can ask for one for any job.
- Standard: spent and unspent convictions, cautions, reprimands and final warnings, subject to filtering rules.
- Enhanced: everything in a standard check plus any information local police consider relevant.
- Enhanced with barred list(s): an enhanced check plus a check of the children’s and/or adults’ barred list.
You cannot simply pick the highest level. Standard and enhanced checks are only available for roles that meet the eligibility rules, and barred list information must only be requested for people who are in, or seeking to be in, regulated activity.
What counts as regulated activity with children?
Regulated activity is defined in law, and the DBS guidance on regulated activity with children explains it in plain terms. In an education context it broadly includes teaching, training, instructing, caring for or supervising children, or giving advice on their wellbeing, when it is done frequently. The “period condition” is met on more than three days in any 30-day period, or overnight between 2am and 6am with a chance of face-to-face contact.
For most AP providers and tuition centres, that means core teaching staff, key workers and regular tutors are in regulated activity. Office staff, cleaners or occasional visitors may not be, and may need a different level of check or none at all. If you are unsure about a role, work through the DBS eligibility guidance rather than guessing.
Do DBS certificates expire?
No. The DBS is clear in its guidance for employers that a certificate has no official expiry date. It shows what was on record on the day it was issued, nothing more. It is the employer’s decision whether to accept a previously issued certificate, looking at the date of issue, whether circumstances could have changed and whether the level of check suits the new role.
That is why settings write their own re-check policy. Common approaches are:
- a fresh enhanced check every three years for everyone in regulated activity
- requiring staff to join the Update Service and checking status annually, or at set points such as the start of each term
- a new check whenever someone moves into a role with a different level of eligibility
None of these is a legal requirement for most settings. The point is to choose one, write it down and follow it.
How does the DBS Update Service work?
The DBS Update Service lets someone keep their standard or enhanced certificate up to date. They must join when they apply, or within 30 days of the certificate being issued. It currently costs £16 a year, and is free for volunteers.
With the person’s consent, you can then run a free online status check at any time. The result tells you whether any new information has been added since the certificate was issued. Before relying on it, Keeping children safe in education expects schools to see the original certificate, confirm it matches the person’s identity and make sure the level of check is right for the job.
What does KCSIE expect, and does it apply to you?
Keeping children safe in education (KCSIE) is statutory guidance for schools and colleges in England. It applies to maintained schools, academies (including alternative provision academies), independent schools, non-maintained special schools and pupil referral units. The 2026 edition came into force on 1 September 2026.
For those settings, KCSIE sets out safer recruitment checks and requires a single central record showing, with dates, the identity check, enhanced DBS (with barred list where relevant), prohibition from teaching check, right to work, qualifications and any overseas checks. It does not set a renewal period for existing staff.
Unregistered AP providers and tuition businesses are not directly bound by KCSIE, but it still reaches you. KCSIE says schools that place pupils in AP should get written confirmation that the provider has carried out the checks the school would do on its own staff, and that the provider will tell them about staff changes. For tuition centres, the DfE’s out-of-school settings safeguarding guidance recommends DBS checks for relevant staff and warns against relying on a DBS check alone.
Where do TRNs and EWC registration fit in?
A teacher reference number (TRN) is issued by the Department for Education to qualified teachers in England, and to some trainees. You can use it with the DfE’s Check a teacher’s record service to confirm qualified teacher status and look for prohibition orders. Schools must carry out a prohibition check for anyone doing teaching work.
In Wales, the Education Workforce Council registers education practitioners. Registration is a legal requirement for teachers and learning support workers in both maintained and independent schools, and both the employer and the individual must make sure it is in place before work starts. It is a separate check from the DBS, so record the EWC registration number alongside it.
What should your records show?
Whatever your setting, keep a clear record for each person of:
- the level of check, certificate number and issue date
- whether they subscribe to the Update Service, and the date of your last status check
- the date your policy says the next check is due
- references, identity and right-to-work checks, and TRN or EWC number where relevant
KCSIE notes that settings do not need to keep copies of DBS certificates, and if you do keep one, it should be for a valid reason and for no longer than six months. Record the number, date and outcome instead.
Take a fictional example: a small AP provider in Bristol that commissions eight sessional tutors. The manager asks each tutor to join the Update Service, runs a status check every September and January, and notes the date on each tutor’s record. When a partner school asks for written confirmation of checks, she can answer the same afternoon.
How PupilDB helps
PupilDB’s staff records hold each person’s DBS number, DBS date and renewal year, two references, TRN, EWC number, and safeguarding and first-aid certificates, alongside their contract and policies. That gives you one place to see who is due for a re-check when a school or local authority asks. PupilDB does not connect to the DBS Update Service or send automatic DBS alerts. Status checks are still done on the DBS website.
If you are building compliance records for an alternative provision setting, get in touch and we will show you how it works.
