When people search for DBS changes 2023, they are usually referring to the last significant set of updates to how Disclosure and Barring Service checks were administered and interpreted.
The Last Major Update for DBS was 2023
The 2023 changes focused primarily on clarification rather than structural reform. They reinforced existing eligibility rules, tightened guidance around workforce categories, and reaffirmed that Enhanced and Barred List checks must only be used where roles are legally eligible.
What the DBS changes 2023 did not do was solve a long-standing structural problem for self-employed individuals. Despite clearer guidance, the system still assumed an employment relationship. Enhanced DBS checks continued to require an organisation to act as the applicant’s sponsor.
For self-employed professionals working with children or vulnerable adults, that limitation remained firmly in place.
As a result, 2023 became known as the last major guidance-led update to the DBS framework. The next significant shift would require legislation. That shift arrived in January 2026.
Why This DBS Changes in 2026 Update Is Fundamentally Different
The DBS changes 2026 represent the most substantial reform since before 2023. Unlike the earlier update, the 2026 changes introduce a formal legal mechanism that directly affects how self-employed individuals access Enhanced and Enhanced with Barred List DBS checks.
From January 2026, self-employed individuals can lawfully apply for Enhanced DBS checks through a DBS-registered Umbrella Body. This route is no longer informal, discretionary, or reliant on interpretation of guidance. It is now explicitly supported by legislation.
The difference between DBS changes 2023 and DBS changes 2026 is simple but critical:
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2023 clarified who should have Enhanced checks
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2026 changes who is allowed to apply for them
That distinction matters for safeguarding, compliance, and commercial credibility.
What the DBS Changes in 2026 Introduce
The January 2026 legislation formally establishes a statutory route for self-employed individuals to apply for:
Enhanced DBS checks
Often, the contracting client will cover the cost as part of their own vetting requirements.
Children’s Barred List
In some cases, the expectation is that you arrive ready to work with a valid certificate. It is treated as a business expense.
Adults’ Barred List
If you operate through an agency or registered body, they may manage both the application and payment.
Both Barred Lists
If you operate through an agency or registered body, they may manage both the application and payment.
Applications are made through a DBS-registered Umbrella Body, which acts as the sponsoring and countersigning organisation.
This is not a new type of DBS check. The check levels remain unchanged. What has changed is access. The DBS changes 2026 remove the employment-only barrier that previously prevented self-employed professionals from applying.
Why the Pre-2026 System Failed the Self-Employed
Before the DBS changes 2026, the DBS framework created a practical dead end for self-employed professionals.
Basic DBS checks were always available to individuals directly. Standard and Enhanced checks were not. They required an organisation to submit and countersign the application. This made sense in a traditional employment model, where an employer had responsibility for vetting staff.
Self-employed individuals had no employer. No countersignatory. No organisation to submit the application. Even where the work clearly required an Enhanced check, there was no consistent lawful route to obtain one.
A self-employed tutor working with children, a freelance therapist operating in schools, or a personal care assistant supporting adults at home could all be performing regulated activity. Yet they were structurally blocked from accessing the correct level of DBS check.
Some Umbrella Bodies offered limited workarounds, but these relied on guidance rather than statute. They were inconsistent, cautious, and often unavailable. The DBS changes made in 2023 did not resolve this. The DBS changes in 2026 do.
How to apply for a self-employed DBS check
Applying for an individual DBS check as a self-employed person follows five steps. The process is the same whether you need a Standard, Enhanced, or Enhanced with Barred List check.Â
Check eligibility
You must be paid and in a qualifying role. Volunteers are not covered.
Register an account
Self-employed applicants cannot submit directly to the DBS.
Complete application
Personal details, 5 years of addresses, and your role information.
Verify your identity
Digitally via biometric passport or EU ID card, or with standard documents.
Receive your certificate
Posted directly to you. Show the original to your client or parent.
Enhanced DBS Eligibility After the DBS Changes 2026
The DBS changes 2026 do not lower eligibility thresholds. Enhanced checks are still restricted to roles that legally qualify.
Eligibility continues to depend on the nature of the work, not employment status. To qualify for an Enhanced DBS check, a self-employed individual must be undertaking work that involves:
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Regular contact with children or vulnerable adults
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Regulated activity in sectors such as education, healthcare, childcare, or personal care
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A role that would require an Enhanced check if carried out by an employee
The eligibility test itself is unchanged from the DBS changes 2023. What has changed is that self-employed individuals can now lawfully submit an application via an Umbrella Body.
For Enhanced DBS checks with Barred List information, the role must constitute Regulated Activity as defined under the Safeguarding Vulnerable Groups Act 2006. Children’s and Adults’ Barred Lists can be requested separately or together, depending on the role.
Ready to apply for your DBS check as a sole trader?Â
Self-employed-dbs.co.uk processes Enhanced and Standard DBS applications for self-employed workers in England and Wales. No employer needed.