Criminal record checks in the United Kingdom are not a single unified system. England and Wales use DBS checks, administered by the Disclosure and Barring Service. Scotland has a different framework, operated by Disclosure Scotland, which includes the PVG scheme for people working with protected groups. Northern Ireland uses the AccessNI system.
This guide explains how the three systems differ, which applies where, what each one discloses, and what this means for self-employed workers who may work across more than one part of the UK.
Why the UK Has Three Different Systems
Criminal record disclosure in the United Kingdom is a devolved matter. Following devolution, Scotland and Northern Ireland developed their own disclosure frameworks that operate independently of the DBS system in England and Wales. The three systems share a similar purpose, checking whether individuals are suitable to work in roles involving contact with vulnerable groups, but they are distinct organisations, governed by different legislation, and they produce different certificates that are not interchangeable.
For most people working in a single part of the UK, this distinction is straightforward: you use the system for the jurisdiction where you work. The complexity arises for workers who operate across borders or who relocate, and for self-employed workers who may take on clients in different parts of the country.
Self-employed-dbs.co.uk processes applications for England and Wales only. Workers based in or working in Scotland or Northern Ireland will need to use the appropriate service for those jurisdictions, as described below.
DBS Checks in England and Wales
The Disclosure and Barring Service administers criminal record checks for England and Wales. It provides three levels of check: Basic, Standard, and Enhanced. Enhanced checks can include a check of the Children’s Barred List, the Adults’ Barred List, or both, where the role involves regulated activity.
Before January 2026, self-employed workers in England and Wales could only apply for a Basic check independently. A Statutory Instrument amending Part V of the Police Act 1997 came into force on 21 January 2026, allowing paid self-employed workers who carry out regulated activity with children or vulnerable adults to apply for Standard and Enhanced checks through a registered platform.
The DBS also administers the DBS Update Service, an annual subscription costing £16 per year that allows a certificate to be kept current and shared with multiple clients without the need for a new application each time. The Update Service is specific to DBS certificates and does not apply to Scottish or Northern Irish disclosure certificates.
More detail on how the DBS check process works for self-employed workers in England and Wales is available through the self-employed DBS checks hub.
Disclosure Scotland and the PVG Scheme
Disclosure Scotland is the executive agency responsible for criminal record checks in Scotland. It provides Basic disclosure, Standard disclosure, and Enhanced disclosure certificates, broadly equivalent in scope to the DBS equivalents. It also administers the Protecting Vulnerable Groups (PVG) scheme, which is a more advanced framework for people working regularly with children or protected adults in Scotland.
The PVG scheme is unique to Scotland. Unlike a one-time DBS check, PVG scheme membership is continuous. Once someone joins the scheme, they hold a scheme record that is updated over time as new information is added. Employers and organisations can check a member’s scheme record at any point, receiving up-to-date information rather than a historical snapshot. This is conceptually similar to the DBS Update Service but is built into the structure of the scheme itself rather than being an optional add-on.
PVG scheme membership is required for anyone in Scotland who does regulated work with children or protected adults. The definition of regulated work in Scotland is set out in the Protection of Vulnerable Groups (Scotland) Act 2007 and differs in some respects from the regulated activity definition used in England and Wales.
Applications for Disclosure Scotland certificates and PVG scheme membership are made through Disclosure Scotland directly or through an approved body. More information is available at mygov.scot/disclosure-scotland.
For self-employed workers based in Scotland, Disclosure Scotland also administers Basic disclosures, which are the equivalent of a Basic DBS check in England and Wales. The fee and application process differ from the English system, and certificates are issued by Disclosure Scotland rather than the DBS.
AccessNI in Northern Ireland
AccessNI is the criminal record checking service for Northern Ireland, administered by the Department of Justice Northern Ireland. It provides Basic, Standard, and Enhanced disclosure certificates for roles in Northern Ireland.
The AccessNI system is governed by the Police Act 1997 (as it applies in Northern Ireland) and the Safeguarding Vulnerable Groups (Northern Ireland) Order 2007. The legislative framework is separate from both the DBS framework in England and Wales and the PVG framework in Scotland.
AccessNI Enhanced checks can include checks of the barred lists maintained by the Disclosure and Barring Service, but the application is made through AccessNI, not the DBS. The process and eligibility criteria reflect the Northern Irish legislative framework.
Applications for AccessNI certificates are made through registered bodies in Northern Ireland. More information is available at nidirect.gov.uk.
How the Three Systems Compare
At the basic level of disclosure, all three systems check criminal records held on national police databases and return information about convictions and, at higher levels, cautions and other information. The purpose is broadly the same across all three: to help employers and organisations make informed decisions about people working with children or vulnerable adults.
The key differences lie in the legislative frameworks, the structures of the systems, and the specific definitions of who is covered and under what circumstances. The PVG scheme in Scotland is the most distinctive, operating as a continuous membership scheme rather than a series of individual checks. The DBS Update Service in England and Wales provides a broadly similar ongoing status check function but is an optional subscription rather than a mandatory scheme feature.
Certificates from one jurisdiction are not accepted as substitutes by organisations in another. An employer in England is entitled to require a DBS certificate rather than a Scottish or Northern Irish certificate, even if the content would be similar. The reverse is equally true. If you work in multiple jurisdictions, you may need certificates from more than one system.
Despite these similarities, the systems are not interchangeable. A DBS certificate cannot be used to satisfy a Scottish PVG requirement, and a PVG certificate cannot replace a DBS certificate for a role in England. This is a common source of confusion for self-employed workers who assume a single check covers the whole of the UK.
What This Means for Self-Employed Workers Who Work Across Borders
For self-employed workers who take on clients in different parts of the UK, the practical implication is that a single DBS certificate does not cover work in Scotland or Northern Ireland. If a client in Scotland requires disclosure for a role, they will expect a Disclosure Scotland certificate or PVG scheme membership record. A DBS certificate issued in England will not satisfy that requirement.
The reverse also applies. A self-employed worker based in Scotland taking on clients in England or Wales should obtain a DBS certificate for those engagements. Their Scottish PVG scheme membership is not a substitute for the DBS check that an English client is likely to expect.
Workers who operate regularly in multiple jurisdictions should plan for this. Holding both a current DBS certificate registered with the Update Service and a Disclosure Scotland or AccessNI certificate where relevant covers the practical requirements of a genuinely cross-border practice.
If you work only in England and Wales, the DBS route through self-employed-dbs.co.uk is the appropriate path. For any work in Scotland or Northern Ireland, contact the relevant service directly.
In practice, the need to hold certificates from multiple systems is most common among self-employed workers who travel to deliver services, such as tutors who take on clients on both sides of the English-Scottish border, or carers who provide cover across different regions. Planning ahead and applying in the relevant jurisdiction before a new engagement begins avoids delays at the start of work.
A Note on Channel Islands and Isle of Man
The Channel Islands and the Isle of Man are Crown dependencies and are not part of the United Kingdom. They have their own disclosure frameworks, separate from the DBS, Disclosure Scotland, and AccessNI.
Guernsey uses the Guernsey Police Disclosure Service. Jersey has its own Disclosure and Barring equivalent administered by the States of Jersey Police. The Isle of Man uses the Isle of Man Constabulary for disclosure purposes.
DBS certificates are not valid for roles in these jurisdictions, and certificates from these jurisdictions are not substitutes for DBS certificates in England and Wales. Self-employed workers taking on clients in the Crown dependencies should contact the relevant authority for that jurisdiction.
Practical Tips for Self-Employed Workers Operating Across Borders
If you work with clients in more than one UK nation, the simplest approach is to hold a current certificate from each relevant system. A DBS certificate covers England and Wales. A PVG scheme membership covers Scotland. An AccessNI certificate covers Northern Ireland.
For self-employed workers based in England or Wales who occasionally take on clients in Scotland, check whether a PVG scheme membership is required before the engagement begins. Some Scottish organisations will accept an Enhanced DBS certificate on a discretionary basis, but many will not, and there is no legal obligation for them to do so.
The self-employed DBS checks page covers the application process for England and Wales. For Scotland, start with the Disclosure Scotland website. For Northern Ireland, start with AccessNI. Each system has its own fees, processing times, and document requirements.
Common Questions About DBS Checks and UK Jurisdictions
- Can I use a DBS certificate if I move to Scotland?
No. A DBS certificate issued in England and Wales is not valid for the purposes of Scottish disclosure requirements. If you move to Scotland and need to demonstrate your criminal record status for a role there, you will need to apply through Disclosure Scotland, which operates a separate system. The DBS certificate remains valid as a historical document but cannot be used as a substitute for a Scottish disclosure certificate.
- Is a PVG scheme membership the same as an Enhanced DBS check?
They serve a similar purpose but are different systems. The PVG scheme is Scotland’s specific vetting framework for people working with protected groups. It is a lifetime scheme rather than a one-time check, and it is administered by Disclosure Scotland. An Enhanced DBS check from England and Wales and a PVG scheme membership are both Enhanced-level disclosures, but they are issued by different organisations and are valid in different jurisdictions.
- Can I work across England and Scotland with one certificate?
No single certificate covers both jurisdictions. If you regularly work in both England and Scotland, you may need both a DBS certificate and PVG scheme membership. The requirements will depend on the specific roles, the organisations engaging you, and whether work in each country constitutes regulated activity under the relevant legislation in each jurisdiction.
- What is the equivalent of the Children’s Barred List in Scotland?
Scotland maintains its own list of individuals barred from working with children and protected adults, administered through the PVG scheme and Disclosure Scotland. The barred lists are separate from the DBS Children’s Barred List and Adults’ Barred List used in England and Wales. Being barred in one jurisdiction does not automatically mean you are barred in another, although serious offences may trigger action in multiple systems.
- Does Northern Ireland use DBS checks?
No. Northern Ireland uses the AccessNI system, administered by the Department of Justice Northern Ireland. AccessNI provides Basic, Standard, and Enhanced disclosure certificates for roles in Northern Ireland. DBS certificates issued in England and Wales are not valid for AccessNI purposes.
- I have a certificate from Scotland. Can I use it for work in England?
A Scottish disclosure certificate or PVG scheme record is not the same as a DBS certificate and will not be accepted by English and Welsh employers or clients who specifically require a DBS check. If you are taking on work in England or Wales, you will need to apply for a DBS certificate through an appropriate registered platform.
This guide applies to self-employed workers in England and Wales only. Self-employed workers in Scotland should apply through Disclosure Scotland. In Northern Ireland, the equivalent service is AccessNI. This page is for guidance only and does not constitute legal advice. If you have questions about your specific circumstances, contact our support team or consult a qualified legal adviser.
Apply for Your DBS Check in England and Wales
Self-employed-dbs.co.uk processes Standard and Enhanced DBS applications for paid self-employed workers in England and Wales. No employer needed. Apply online with digital ID verification available.