Westminster Policy News & Legislative Analysis

Police can share DBS barred status for overseas child roles

Home Office regulations made on 25 November 2025 prescribe a new purpose under section 50A(1)(d) of the Safeguarding Vulnerable Groups Act 2006. The Safeguarding Vulnerable Groups Act 2006 (Prescribed Purposes) Regulations 2025 (SI 2025/1239) extend to England and Wales, were laid before Parliament on 27 November 2025 and come into force on 18 December 2025. The instrument is signed by Parliamentary Under-Secretary of State Jess Phillips.

In practical terms, a chief officer of police may disclose information supplied by the Disclosure and Barring Service to assist a person outside the UK who is assessing someone’s suitability for a role working with children. That disclosure can include confirmation of whether the individual is on the children’s barred list. This change clarifies a lawful route to share barred‑status information where the recruitment decision is made overseas.

The statutory gateway sits within section 50A of the 2006 Act, which allows DBS to provide information to a chief officer of police for crime prevention and investigation, for appointments under that officer’s direction and control, and for any purpose prescribed by regulations. The 2025 Regulations prescribe the overseas child‑suitability purpose under section 50A(1)(d). Earlier in 2025, a separate Order updated section 50A(3) so that non‑territorial UK forces and Crown Dependency forces are expressly included in the definition of “chief officer of police”. Together, these measures firm up who can receive DBS data and for what uses.

The measure is narrowly framed. It covers information sharing to support assessments for roles working with children and applies to England and Wales only. It does not create a general right for overseas employers to obtain full DBS certificates, nor does it give DBS access to criminal records held abroad; UK government guidance continues to stress that DBS checks do not routinely include overseas records.

For overseas recruitment, the operational touchpoint remains police‑run services such as the International Child Protection Certificate, used by international schools and NGOs to evidence UK conviction and relevant police information. The new Regulations provide a clear legal basis for police to include DBS barred‑status data when assisting overseas decision‑makers alongside those existing routes.

DBS and policing bodies will still be expected to apply established disclosure safeguards. The Home Office’s statutory disclosure guidance to chief officers underscores relevance, necessity and proportionality tests for any police‑held information disclosed for enhanced checks; while the new purpose authorises sharing, professional judgement and data‑protection duties continue to govern what is released.

For UK‑based organisations recruiting to posts overseas where the decision is taken domestically, existing DBS routes remain available. Where the decision is taken overseas, DBS advises using local criminal record regimes, certificates of good conduct or ICPCs to supplement any UK barred‑status confirmation provided under these Regulations.

The Home Office states that no full impact assessment has been produced because no significant effect on the private, voluntary or public sectors is foreseen. For most employers, this is a legal clarification rather than a new administrative scheme, but it should shorten conversations about whether police can confirm a UK barred status for overseas child‑safeguarding recruitment.

Key dates are immediate for planning purposes: made on 25 November 2025, laid on 27 November 2025, and commencement on 18 December 2025. HR teams, safeguarding leads and international hiring partners should adjust templates and guidance to reflect that police may now disclose DBS‑provided barred‑status information to overseas decision‑makers assessing child‑contact roles.