Westminster Policy News & Legislative Analysis

DBS-police sharing for overseas child roles starts 18 Dec 2025

Home Office ministers have introduced a narrow change to the safeguarding information regime. The Safeguarding Vulnerable Groups Act 2006 (Prescribed Purposes) Regulations 2025 (S.I. 2025/1239) were made on 25 November, laid before Parliament on 27 November, and come into force on 18 December 2025. Signed by Jess Phillips as Parliamentary Under Secretary of State, the instrument extends to England and Wales.

Regulation 2 prescribes, under section 50A(1)(d) of the Safeguarding Vulnerable Groups Act 2006, a new purpose for which the Disclosure and Barring Service (DBS) may share information with a chief officer of police. The prescribed purpose is to enable that chief officer to disclose information in order to assist a person located outside the United Kingdom to assess an individual’s suitability for work with children.

According to the explanatory note published on legislation.gov.uk, information disclosed may include whether the individual appears on the children’s barred list. The instrument limits what may be passed on to information supplied by DBS to the police; it does not create a direct access route for overseas organisations to the barred lists themselves.

The policy intent is focused on recruitment decisions made outside the United Kingdom. The recipients envisaged are employers or prospective employers overseas who need to assess suitability for roles involving contact with children, complementing but not replacing existing domestic DBS routes for appointments made in the UK.

The legal mechanism remains unchanged. DBS may provide information to a chief officer of police; any onward disclosure is then made by that chief officer for the prescribed purpose. Section 50A already covers crime-related purposes and police staffing decisions; this regulation adds an overseas child‑safeguarding recruitment purpose to that list of permissible reasons.

The change does not amend the criteria for inclusion on barred lists, nor does it expand the scope of routine DBS checks. Decisions to disclose will continue to be taken within existing statutory duties and data protection requirements, with relevance and proportionality to the stated purpose determining the content of any disclosure.

Territorially, the instrument applies to England and Wales, reflecting DBS’s core remit. Scotland’s Protecting Vulnerable Groups Scheme and Northern Ireland’s AccessNI remain distinct arrangements and are unaffected by this regulation.

The Home Office notes that no full impact assessment has been produced, stating that no, or no significant, impact on the private, voluntary or public sectors is expected. Operational handling will sit within established arrangements for police forces and DBS when responding to requests originating from outside the UK.

For safeguarding leads in international schools, charities and other organisations recruiting outside the UK, the practical effect is clarity on a lawful route to request DBS‑sourced information through the relevant chief officer of police. From 18 December 2025, that route can be used to inform suitability assessments for roles involving children.