Guidance

DBS checks in sport – working with children

Updated 5 July 2024

Please note: This is not legal advice. If you need help with making sure you are complying with the law, you should speak to a legal adviser.

This page addresses the eligibility of a range of roles across the sports sector based on generic descriptions of the roles and their responsibilities. This guidance would apply whether the individuals are paid or unpaid.

If your organisation employs people in these roles who have additional duties to those outlined in this leaflet, you will need to refer to our online eligibility tool and guidance. If your organisation employs people in different roles who perform similar duties to those in this leaflet, you should refer to our online guidance as they may be eligible for the same level of check.

Any changes to a role or the activities that a person carries out can affect the level of check that is available.

This information can be found on the eligibility guidance page of the Disclosure and Barring Service (DBS) website.

This guidance relates to obtaining criminal record checks in England, Wales, the Channel Islands, and the Isle of Man. Information on checks available in Scotland can be obtained from Disclosure Scotland. Information on checks available in Northern Ireland can be obtained from Access NI.

1. Children

The Safeguarding Vulnerable Groups Act 2006 specifies that when a child is aged 16-17 and is in any kind of paid or unpaid employment, those who teach, train, instruct, care for, or supervise them, or those who provide them with advice and guidance as part of their employment aren’t in regulated activity with children. This means that they are not eligible for a Standard or Enhanced DBS check. If the child is under 16 and in any kind of employment, then the person teaching, training etc. them would be in regulated activity (if the period condition is met).

2. Eligibility

Access to Standard and Enhanced DBS checks is controlled by the law.

As a general position, eligibility to apply for a Standard or Enhanced DBS check is not based on a person’s job title but is established by looking at the activities and responsibilities carried out by each individual role. It’s important to make sure that legislation allows a DBS check to be submitted to make sure the applicant’s data protection rights are not breached.

The organisation deciding whether the applicant is suitable for the role or not is also responsible for working out the level of check the role is eligible for.

Individuals can’t apply directly to DBS for their own Standard or Enhanced check. There must be an organisation making the decision about whether the individual is suitable for the role or not to submit an application for these levels of check.

Where eligibility for a Standard or Enhanced DBS check doesn’t exist, then a Basic check can be requested – there are no restrictions on who can apply for this.

Individuals can apply for their own Basic DBS check via our website. They can also apply via a Responsible Organisation. Basic checks provide details of unspent convictions and conditional cautions.

3. Specific roles in the sports sector

Below are some examples showing how eligibility can be applied to some roles in the sports sector. Legislation sets out what regulated activity with children is and what falls into the definition of ‘work with children’. To see more about what is meant by regulated activity with children, refer to the regulated activity with children leaflet on our website.

3.1 Regulated activity and meeting the period condition:

Certain roles in this guidance will only be classed as regulated activity if they are carried out often enough to meet the period condition. This makes them eligible for an Enhanced DBS check with a Children’s Barred List check. The period condition for regulated activity with children is:

• on more than 3 days in any period of 30 days, or
• once overnight between 2am and 6am with the opportunity for face-to-face contact with children.

4. Coaches

Anyone employed to be a coach or instructor of children’s sports whose duties include teaching, training, or instructing children, or providing advice or guidance to children relating to their physical, emotional, or educational well-being, is eligible for an Enhanced DBS check with a Children’s Barred List check.

This is because they are performing regulated activity with children if the period condition is met (see above).

If they do these activities more than once, but not often enough to meet the period condition, they are eligible for an Enhanced DBS check but without any Barred List check.

5. Referees, umpires and other officials

The role of a football ground steward is named in legislation and is automatically eligible for a Standard DBS check, regardless of whether they are dealing with children or adults in receipt of health and social care.

Other sports official roles are not specifically mentioned in legislation as eligible for a DBS check which means that each role must be considered on an individual basis to establish what the person is doing that could be eligible. This is because an official’s responsibilities can vary between sports and clubs.

If an official’s duties include teaching, training, instructing, caring for or supervising children, and they do this often enough to meet the period condition, they will be eligible for an Enhanced DBS check with a Children’s Barred List check.

For example, a referee for a children’s football team who instructs players on the correct way to undertake a goal kick or throw-in would be instructing children and would be eligible for an Enhanced DBS check with a Children’s Barred List check, if they are doing this often enough to meet the period condition. An official who is responsible for supervising children before or after a match, or during training, would also be eligible for an Enhanced DBS check with Children’s Barred List check, if the period condition is met.

If they do this more than once, but not often enough to meet the period condition, then they will be eligible for an Enhanced DBS check but without any Barred List check.

If they do not perform any of the activities mentioned above, then they can apply for a Basic DBS check.

6. Drivers

There may be eligibility in some situations for drivers who transport children to and from sports activities or events. If someone drives a vehicle that is being used only for the purpose of conveying children, including anyone supervising or caring for the children, to sports activities or other arranged events then they will be eligible for an Enhanced DBS check with a Children’s Barred List check as long as they are doing it often enough to meet the period condition.

If they do it more than once but not often enough to meet the period condition, then they will be eligible for an Enhanced DBS check but without a Barred List check.

This does not apply to individuals who are driving children as part of a private arrangement or an arrangement between parents. The driving must be done on behalf of the sports club.

7. Pool Lifeguards

Pool lifeguards are eligible for DBS checks because, based on guidance from the Royal Life Saving Society in collaboration with National Society for the Prevention of Cruelty to Children (NSPCC), their duties mean that they are expected to supervise the users of a pool which will include children. This is regardless of whether the children are accompanied by an adult.

Because of the expectation that supervision is part of their duties, as long as the period condition is met, lifeguards are eligible for an Enhanced DBS check with a Children’s Barred List check, as they will be carrying out regulated activity with children.

If they perform this role more than once but not often enough to meet the period condition, they will be eligible for an Enhanced DBS check but without a Children’s Barred List check.

8. Leisure and Sports Centre staff

There may be eligibility in some situations for certain leisure or sports centre staff who carry out specific duties or activities.

If a member of staff simply has contact with children due to working in an area where children may be, then there is no eligibility for a Standard or Enhanced DBS check. These would be roles such as administrators, cleaners and changing room attendants. These staff can be asked to apply for a Basic DBS check.

Roles that meet the following criteria are eligible for an Enhanced DBS check with a Children’s Barred List check:

• any work involving teaching, training, instruction, caring for or supervising children if
• the work is done for groups that are expected to include children (i.e., it’s not something that is being done for an adult-only group where a child unexpectedly attends) and
• where the period condition is met

This could include roles like children’s swimming instructors and gymnastics instructors.

Gym staff could be eligible as above if the gym runs sessions for children and they provide instructions on how to use the equipment.

Staff working in a crèche based within a leisure centre are eligible for an Enhanced DBS check with a Children’s Barred List check in the same way as staff working in any nursery or crèche would be. It is not appropriate for all other leisure centre staff to be DBS checked because the crèche facility exists within a leisure centre building.

9. Healthcare professionals in sports

There are a number of roles in the sports sector that provide healthcare, such as physiotherapists, psychotherapists, first aid organisations, club doctors/nurses etc, where eligibility exists for these individuals to be asked to apply for a DBS check.

Anyone who is providing healthcare to children and is a regulated healthcare professional or working under the direction or supervision of a regulated healthcare professional is carrying out regulated activity with children. It doesn’t matter how often this healthcare is being provided for the eligibility criteria to be met.

This means that someone providing healthcare to children in the circumstances described can be asked to apply for an Enhanced DBS check with a Children’s Barred List check.

To be working under the direction of a healthcare professional, the individual would need to be receiving direct instructions from the healthcare professional about how to treat the client whilst the healthcare is being provided.

To be working under the supervision of a healthcare professional would require the individual to have the healthcare professional with them at the point that they are providing the treatment to the client.

Healthcare provided by first aiders is only regulated activity if it is provided on behalf of an organisation set up for the purpose of providing first aid, e.g., St John’s Ambulance.

This does not apply to people who volunteer to be first aiders alongside their primary role.

10. Sports therapists

If a sports club employs someone who isn’t a registered healthcare professional to provide sports massages or physical manipulation for children’s teams, or any individual child, the sports club could ask that they apply for an Enhanced DBS check with a Children’s Barred List check if they meet the period condition. This is because the individual is performing work that is a form of care for children.

If they do this more than once but not often enough to meet the period condition, they are eligible for an Enhanced DBS check but without a Barred List check.

If sports massage/manipulation is being provided by a healthcare professional (e.g., a registered physiotherapist), then it would be regulated activity and eligible for an Enhanced DBS with a Children’s Barred List check, even if it is only done on one occasion.

11. Running groups

Public or private running groups that include children sometimes appoint a run leader to organise or supervise events held by the group. If there is no organisation providing approval for the individual to perform this role, then they would not be able to apply for a Standard or Enhanced DBS check. The run leader could only apply for a Basic check.

If there is an organisation deciding if the individual is suitable to perform this role, then there may be eligibility depending on what activities the run leader is performing and who they are doing this with.

Run leaders that meet the following criteria are eligible for an Enhanced DBS check with a Children’s Barred List check:

• the run/event is not set up just for adults i.e., children are expected to attend and
• they are responsible for teaching, training, instructing, caring for or supervising children and
• the period condition is met

If they do this more than once but not often enough to meet the period condition, they are eligible for an Enhanced DBS check but without a Barred List check. If the above criteria aren’t met, the run leader can only be asked to apply for a Basic DBS check.

For running groups that are open to both children and adults, see the Children in Adults’ Sports section.

12. Sports academies

In certain circumstances, sports academies such as Youth Football Academies, can be classed as Alternative Provision Academies. This only applies if they are based in England. These are establishments that provide full-time education for students alongside training in a specific sport or skill. Alternative Provision Academies in England are referred to as a specified establishment for the purposes of DBS checks. This means that individuals working for the academy can be carrying out regulated activity with children because of where they’re working.

If a sports academy provides full-time education under the instruction of a local authority alongside sports training, then it will be a specified establishment for the purposes of carrying out regulated activity with children. This means that anyone working for the purposes of the academy, who also has the chance to have contact with children whilst working there, is eligible for an Enhanced DBS check with a Children’s Barred List check, as long as the period condition is met. This does not apply to temporary or occasional workers at the academy.

For example, cleaners and administration staff working in a Football Youth Academy, who have the chance to have contact with children whilst working there, would be eligible for an Enhanced DBS check with a Children’s Barred List check. This is because they will be in regulated activity if the period condition is met, as they are working in a specified establishment.

Any staff that work at the academy on more than one occasion but do not meet the period condition are eligible for an Enhanced DBS check but without a Barred List check.

13. Overnight stays

For some sports activities, it may be necessary for teams or groups to stay overnight at certain venues or events. Many sports, particularly at high-performance level, provide accommodation where young athletes may stay for various lengths of time (without the provision of education) for training or selection purposes.

When this is done with children’s teams, the person responsible for supervising the children is doing so overnight with the opportunity for face-to-face contact with them. As there is opportunity for contact between 2am and 6am, the period condition is met even if this supervision happens on just one occasion.

This means that this person is eligible for an Enhanced DBS check with a Children’s Barred List check.

This does not apply to individuals who are staying with children as part of a private arrangement or arrangements between parents. It must be done on behalf of the sports club or activity provider.

14. Children in adults’ sports

For anyone carrying out the sports roles mentioned already, but for open aged sports teams, there may be eligibility to apply for the same level of check that they could get for performing the role just with children. This would apply to a coach for a football team that is open to adults as well as 16- and 17-year-olds. Eligibility here will depend on how likely it is that children would be present at these teams or events.

If it’s anticipated that children are likely to join an open-aged sports team and there is a good chance of this happening, then the person performing any of the roles mentioned would be eligible for the same level of check as previously explained for that role. This would be where children have been part of the team during the previous season or have already registered to join the team.

If it’s unlikely that children would be a part of these sports teams or events, i.e., no children have previously been on a team and none are expected to join, then people in these roles could only be asked to apply for a Basic DBS check. This is because a Standard or Enhanced DBS check cannot be applied for just in case a person ends up doing an eligible type of work.

15. Managers and supervisors

If an individual is employed with duties including the day-today management or supervision of someone who is carrying out regulated activity with children, then this individual is also in regulated activity with children and is eligible for an Enhanced DBS check with a Children’s Barred List check.

For example, if a lifeguard is eligible for an Enhanced DBS check with a Children’s Barred List check for being in regulated activity with children, then any person who is employed to manage or supervise that lifeguard on a day-to-day basis will also be eligible for the same level of check.

Providing healthcare or personal care to children only needs to happen once to be regulated activity, therefore day-to-day managers or supervisors of people doing this work will also be in regulated activity with children and are eligible for an Enhanced DBS check with a Children’s Barred List check.

If the member of staff was carrying out any other relevant activity with children more than once but not often enough to meet the period condition, then their supervisor would be eligible for an Enhanced DBS check but without a Children’s Barred List check.

This only applies to direct management/supervisor positions and does not extend to cover the complete line management chain.

16. Reporting concerns to DBS

When you request an Enhanced DBS check with a Barred List check to assess someone to carry out regulated activity with children (see Annexe A), this means that you are a regulated activity provider (RAP). Being a RAP means that as an organisation you have a legal duty to make barring referrals to DBS where relevant conditions are met. Please see the DBS leaflet on Barring Referrals for more information.

17. ANNEXE A – Definition of regulated activity with children

Regulated activity with children is something that must not be carried out by people who are included on the Children’s Barred List.

If someone who knows they are barred from regulated activity with children applies for any kind of work that meets the definition of regulated activity below, they are committing an offence, as is anyone who employs them in a paid or unpaid role involving regulated activity knowing that they are barred. Both could be liable for up to 5 years imprisonment and/or a fine. 

Anyone carrying out an activity that is covered by the definition of regulated activity with children can be asked to apply for an Enhanced DBS check, including a Children’s Barred List check.

Regulated activity with children can be separated into 4 parts as explained below:

17.1 Part 1

These activities only need to be done once to be regulated activity with children:

• Providing personal care – which is:
  • physical help with, or prompting and then supervising a child with eating or drinking because the child needs it because of their illness or a disability; or
  • providing any form of training, instruction or guidance to a child to do with eating or drinking because the child needs it because of their illness or a disability; or
  • physical help with, or prompting and then supervising a child going to the toilet, washing or dressing because the child needs it because of their age, illness or a disability; or
  • providing any form of training, instruction, advice or guidance to a child going to the toilet, washing or dressing because the child needs it because of their age, illness or disability
• Providing healthcare by, or under the direction or supervision of a regulated healthcare professional:
• to be working under the direction of a healthcare professional, the individual would need to be receiving direct instructions from the healthcare professional about how to treat the client whilst the healthcare is being provided
• under the supervision of a healthcare professional would require the individual to have the healthcare professional with them at the point that they are providing the treatment to the client

17.2 Part 2

These activities must be done more than 3 times in any 30-day period, or once overnight between 2am and 6am (with the opportunity for face-to-face contact with children) to be regulated activity with children:

• teaching, training or instructing children, unless this is being done specifically for adults, and a child attends unexpectedly. If the individual doing these activities is supervised* by someone else who is in regulated activity with children, then they are not in regulated activity themselves so are only eligible for an Enhanced DBS check without a Children’s Barred List check
• caring for or supervising children, unless this is being done specifically for adults and a child needs this unexpectedly
• providing any form of advice or guidance wholly or mainly for children relating to their physical, emotional or educational well-being; this does not include legal advice

Individuals do not need to be in contact with the same children over this timeframe – it can be with any number of different groups/individuals.

*Department for Education statutory guidance states that supervision must be:

• provided by a person who is in regulated activity
• regular and day-to-day
• reasonable in all the circumstances to ensure the protection of children

17.3 Part 3

These activities need to be done more than 3 times in any 30-day period to be regulated activity with children:

• moderating an internet chat room which is likely to be used wholly or mainly by children
• driving a vehicle specifically for children, including anyone supervising or caring for the children, as part of a third-party arrangement

These activities are also regulated activity with children and don’t have any requirement to carry them out a specific number of times:

• day-to-day management or supervision of someone carrying out regulated activity
• being a foster carer

17.4 Part 4

If people in sports roles aren’t carrying out any of the activities explained in Parts 1-3, they could still be carrying out regulated activity with children if they do their work in certain establishments and meet certain other specific criteria.

The establishments are:

• an educational institution exclusively or mainly for the provision or full-time education of children
• a pupil referral unit
• an alternative provision Academy in England only
• a provider of nursery education
• a detention centre for children
• secure accommodation for children provided under the Regulation and Inspection of Social Care (Wales) Act 2016 in Wales only
• a children’s home in England only
• a home provided under the Children Act 1989
• a care home wholly or mainly for children provided under the Regulation and Inspection of Social Care (Wales) Act 2016 in Wales only
• a children’s centre (managed by or on behalf of, or under arrangements made with, an English local authority, through which early childhood services is made available, and at which activities for young children are provided, by way of early years provision or otherwise)
• relevant childcare premises

If sports workers are working in any of the establishments listed above, they must also meet all the criteria below:

• they work there more than 3 times in a 30-day period, or once overnight between 2am and 6am with the opportunity for face-to-face contact with the children; and
• they have the opportunity, because of their job/role, to have contact with the children in the establishment; and
• they work there for the purpose of the establishment; and
• it is not temporary or occasional work; and
• if they are unpaid, to be in regulated activity they must not be supervised by someone else who is in regulated activity. If they are in a paid role, they can be supervised by someone else and still be in regulated activity

These criteria are aimed at ancillary roles e.g., admin staff, cleaners, caterers etc.

18. What if the activities are not done frequently enough?

If any of the activities within Parts 2–4 above are carried out, but not frequently enough to meet the definition of regulated activity with children, then the post holder is not carrying out regulated activity. Organisations can still request Enhanced DBS checks in the child workforce, but they can’t request a Children’s Barred List check.

18.1 Further information can be found on the DBS website. The following sites may be useful.

www.gov.uk/find-out-dbs-check (Our eligibility tool)

https://www.gov.uk/request-copy-criminal-record (how to apply for a Basic DBS check)

https://www.gov.uk/guidance/barring-referrals (information on barring referrals)

Information about regulated activity with children is also available from the Department for Education (DfE):

www.gov.uk/government/uploads/system/uploads/attachment_data/file/550197/Regulated_activity_in_relation_to_children.pdf

Information about the Child Workforce guide:

https://www.gov.uk/government/publications/dbs-workforce-guidance