Do contractors need DBS checks when working in schools?

The starting point: what activity will the contractor actually undertake?

The fact that someone is working on school premises does not, by itself, determine their DBS eligibility.

Schools should consider the contractor's actual role and circumstances, including:

• what activity the individual will undertake;
• whether their role involves teaching, training, instructing, caring for or supervising children;
• whether another category of regulated activity applies;
• how frequently the relevant activity will take place;
• whether any applicable period condition is met;
• where and when the work will take place;
• the level of contact or interaction with children inherent in the role; and
• whether the role meets the current eligibility criteria for a Basic, Standard, Enhanced or Enhanced with Children's Barred List DBS check.

DBS eligibility should be determined from the role and current statutory criteria rather than simply from the fact that the individual will be present in a school.

What changed on 1 September 2026?

Until 31 August 2026, certain activities involving children could fall outside regulated activity where the individual was sufficiently supervised by someone who was themselves in regulated activity.

That supervision exemption was removed from 1 September 2026.

This means that where someone teaches, trains, instructs, cares for or supervises children and the activity is carried out often enough to meet the relevant period condition, supervision no longer prevents that activity from being regulated activity.

For these specified activities, the current period condition includes activity taking place:

• on more than three days in any 30-day period; or
• overnight in circumstances falling within the regulated-activity criteria.

Schools should use current DBS and Department for Education guidance when determining whether a particular role meets the definition.

The change does not mean every contractor, volunteer or other adult who enters a school is now in regulated activity.

The nature of the activity and the relevant eligibility criteria still need to be considered.

Supervision is still important – but its legal effect has changed

Supervision remains an important safeguarding control for contractors working on occupied school sites.

For example, schools may use arrangements such as:

• restricting contractors to agreed work areas;
• preventing unnecessary access to pupil areas;
• providing escorts where appropriate;
• scheduling work outside pupil occupation where reasonably practicable;
• segregating construction work from occupied areas;
• controlling keys and access;
• briefing contractors on safeguarding expectations; and
• ensuring staff know who is responsible for monitoring access.

However, from 1 September 2026, supervision must not be relied upon as the reason why qualifying teaching, training, instruction, care or supervision of children is excluded from regulated activity where the relevant criteria are otherwise met.

This distinction is important.

Supervision can still be an appropriate safeguarding control. It is no longer the previous statutory exemption from regulated activity for the affected activities.

Four contractor situations – why the answer can differ

1. Contractor working within a segregated construction area

A contractor carrying out building work within a properly segregated compound, with controlled access and no role involving teaching, training, instruction, care or supervision of pupils, should not automatically be treated as being in regulated activity simply because the work is taking place on school premises.

The school still needs appropriate safeguarding arrangements, identity/access controls and contractor-management arrangements.

2. One-off maintenance or emergency repair

An engineer attending to repair a boiler, glazing, plumbing or other premises defect should not automatically be treated as being in regulated activity merely because pupils are elsewhere on the site.

The school should determine appropriate access and safeguarding controls based on the circumstances and should consider DBS eligibility against current guidance rather than assuming that either a DBS check or supervision is automatically required.

3. Regular role involving direct activity with children

Where an individual's role involves teaching, training, instructing, caring for or supervising children and the relevant frequency/period condition is met, the activity may constitute regulated activity.

From 1 September 2026, the fact that another person supervises the individual does not remove qualifying activity from regulated activity under the previous supervision exemption.

4. Work undertaken when pupils are not present

Where contractors undertake premises work outside school hours or during holidays when pupils are not present, the school's primary controls may relate to identity, security, lone working, competence, emergency arrangements and health and safety.

DBS eligibility should nevertheless be determined by the actual role and activity rather than relying solely on the time at which a particular visit takes place.

Safeguarding arrangements for contractors

DBS checks are only one part of contractor safeguarding.

Schools should have arrangements proportionate to the work and circumstances. These may include:

• identity verification;
• signing-in and visitor identification;
• controlled access;
• site induction;
• restricted areas;
• safeguarding expectations;
• segregation from pupils;
• escorts where appropriate;
• arrangements for keys or access-control systems;
• communication with relevant staff;
• procedures for substitute or subcontracted workers; and
• recording the safeguarding decision where appropriate.

These controls should integrate with the school's wider contractor management arrangements rather than operating as a completely separate process.

What about the Children's Barred List?

A Children's Barred List check is not something a school can simply request for every contractor.

Eligibility depends upon the role meeting the relevant statutory criteria.

Where an individual will undertake regulated activity with children, schools should follow current statutory safeguarding and DBS guidance regarding the appropriate check and Children's Barred List information.

It is unlawful for a barred person to engage in regulated activity with children, and organisations must not knowingly permit a barred person to undertake regulated activity.

Schools should use current DBS eligibility guidance when deciding the level of check appropriate to a particular contractor role.

What should schools record?

Schools should maintain appropriate evidence of the checks and safeguarding arrangements relevant to the contractor's role.

The precise record will depend upon the type of contractor and the applicable requirements.

Information might include:

• contractor/company;
• identity of individuals attending;
• nature and location of work;
• identity verification;
• DBS information where the role requires it;
• who verified relevant information;
• date of verification;
• access or segregation arrangements;
• safeguarding instructions provided;
• substitute or subcontractor arrangements; and
• relevant sign-in and sign-out information.

Schools should ensure that information required by Keeping Children Safe in Education 2026 and the applicable school regulations is recorded on the Single Central Record where required.

Not every site contractor must appear on the Single Central Record. Where additional contractor information is useful but is not required on the SCR, schools may maintain an appropriate contractor-management or visitor record as part of their local assurance arrangements.

Can schools rely on a contractor company's assurance?

Schools frequently use contractors employed by larger companies or framework providers.

The school's arrangements should distinguish between reasonable reliance on contractual/provider assurance and situations where the school itself is required to verify or record particular information.

Schools should not create unnecessary duplicate checking arrangements, but equally should not assume that a generic statement such as "all our staff are DBS checked" establishes that every individual attending has the correct level of check for the role they will undertake.

The school should understand:

• what checks the provider carries out;
• what level of DBS check applies where relevant;
• whether Children's Barred List information is included where required;
• how identity is matched to the individual attending;
• how substitute personnel are controlled; and
• what evidence the school needs to retain under its own safeguarding arrangements.

Where safeguarding and health and safety meet

A DBS certificate does not demonstrate that a contractor can carry out technical work safely.

Likewise, competent technical contractors still need appropriate safeguarding arrangements when working in an occupied school.

Effective contractor management should therefore bring together:

• competence and contractor selection;
• safeguarding;
• identity and access control;
• RAMS where appropriate;
• asbestos information;
• fire precautions;
• permits or authorisations where required;
• site induction;
• monitoring; and
• completion/handover.

A contractor can have the appropriate safeguarding checks and still create significant risk by disturbing asbestos-containing materials, compromising fire compartmentation or failing to segregate hazardous work from pupils. See contractor management in schools for how these controls fit together.

Common mistakes schools should avoid

Assuming every contractor needs an Enhanced DBS check

DBS eligibility depends on the role and applicable statutory criteria. School premises alone do not determine eligibility.

Using outdated supervision guidance

From 1 September 2026, the previous supervision exemption from regulated activity has been removed for the affected activities. Older procedures that rely on supervision to prevent qualifying activity from becoming regulated activity should be reviewed.

Treating DBS as the whole safeguarding system

Identity, access, segregation, site rules and monitoring remain important regardless of whether a DBS check applies.

Failing to control substitute contractors

The individual who arrives may not be the person originally expected. Schools should have a process for identifying and appropriately managing replacement or subcontracted personnel.

Asking for a level of DBS check without establishing eligibility

Schools should determine the appropriate level of check from the actual role and current DBS eligibility guidance rather than adopting a blanket policy.

Failing to record the decision

Where safeguarding arrangements or checks have been determined for a contractor role, appropriate evidence should be retained so that the school's reasoning and controls can subsequently be demonstrated.

A workable school approach

A practical contractor-safeguarding process should answer:

1. What will this person actually be doing?
2. Does the role meet the current eligibility criteria for a DBS check and, if so, what level?
3. Does the activity constitute regulated activity with children?
4. What safeguarding and access controls are required while the contractor is on site?
5. What information must the school verify and record?

This provides a more reliable approach than simply dividing contractors into "DBS checked" and "supervised".

Schools should ensure the process is understood by safeguarding staff, estates/site teams and reception staff, as all three may be involved in controlling contractor access.

How SchoolSafe Systems helps

Contractor control is one of the areas reviewed in the SchoolSafe school health and safety audit and in ongoing school compliance services. The output is a written contractor arrangement your site team can actually run, and evidence governors can see.