The DBS Update Service is one of those tools that sounds straightforward in theory but causes a surprising number of compliance problems in practice.

The idea is simple: a member of staff registers their DBS certificate with the Update Service, you check it online rather than requesting a new DBS application, and everyone saves time. In reality, many schools are using the Update Service in ways that do not actually create a valid check, recording it in ways that would not satisfy inspectors, and making assumptions about what it replaces that are simply incorrect.

This guide sets out exactly how the DBS Update Service works, the seven mistakes we see most often in schools, and how to structure your process so it is genuinely inspection-ready.

What the DBS Update Service actually is

The DBS Update Service allows individuals to keep their DBS certificate live so that future employers can check its current status online, without submitting a new application. Subscription costs £16 per year (as of 2026) and must be set up within 30 days of the DBS certificate being issued.

As an employer, you can check an individual's subscription status online, with their consent, and see one of three possible outcomes:

• The certificate is valid and unchanged
• The certificate is valid but new information has been added
• The certificate is no longer current and a new check is required

Crucially, the Update Service is only valid for the same check level and workforce category as the original DBS certificate. An Enhanced DBS for the child workforce on the Update Service confirms status against the Children's Barred List. A standard DBS on the Update Service does not.

Who can use the DBS Update Service?

Not all DBS certificates are eligible for the Update Service. To use it, the individual must have:

• Registered their certificate with the DBS Update Service within 30 days of the certificate being issued
• Maintained an active annual subscription
• An Enhanced DBS certificate for the correct workforce category

If any of these conditions are not met, the Update Service check is not valid. Schools must verify subscription status before relying on it, not simply take the individual's word for it.

7 DBS Update Service mistakes schools make

Mistake 1: Relying on verbal confirmation rather than checking online

A new staff member says they are registered on the Update Service. The school marks the DBS as valid without actually running the online check. This is not a compliant check and provides no statutory protection.

Fix: Always run the online status check yourself through the official DBS Update Service portal. Do not rely on what the individual tells you. Record the check date and outcome.

Mistake 2: Not verifying the original certificate first

The Update Service confirms whether a certificate is still current, it does not repeat the verification of the original document. Before relying on an Update Service check, schools must see the original DBS certificate, confirm the DBS number, check the level and workforce category, and confirm the individual is registered on the Update Service with that certificate number.

Fix: Make the verification of the original certificate a mandatory step before running any Update Service check. Record the certificate number, level, and workforce category in your SCR.

Mistake 3: Not obtaining consent before running the check

Running a DBS Update Service check without the individual's explicit consent is unlawful. Many schools skip this step or treat it as implicit. It is not, consent must be obtained and documented.

Fix: Include a consent clause in your staff DBS policy and obtain a signed consent form (or digital equivalent) before running any Update Service check. Retain this alongside the SCR entry.

Mistake 4: Misunderstanding the three possible outcomes

Some schools treat 'valid but changed' as acceptable without investigating what has changed. This is a significant compliance risk. The three outcomes require different responses:

• No changes: record the check date and outcome, file the result, proceed
• Valid but changed: a new full Enhanced DBS must be requested. Do not allow the individual to continue in regulated activity until the new DBS is reviewed
• No longer current: a new Enhanced DBS must be requested immediately

Fix: Establish a clear decision rule for each outcome and ensure everyone with responsibility for running Update Service checks understands it.

Mistake 5: Recording outcomes too vaguely in the SCR

'Update Service checked, OK' is not a sufficient SCR entry. If an inspector asks to see evidence of the check, this tells them almost nothing about whether the process was followed correctly.

Fix: Your SCR entry for an Update Service check should include: the date of the check, the outcome, who ran the check, the DBS certificate number, and where the evidence screenshot is stored.

Mistake 6: Assuming the Update Service replaces other required checks

The DBS Update Service confirms whether an Enhanced DBS certificate remains current. It does not replace any other statutory check. Schools must still complete all of the following separately:

• Identity verification
• Right to work check
• Prohibition from teaching check
• Section 128 check (for those in management roles in independent schools)
• QTS verification (where applicable)
• Overseas criminal record checks (where applicable)

Fix: Treat the Update Service as one element of a complete vetting process, not a shortcut that replaces it.

Mistake 7: Not running repeat checks regularly

Some schools check the Update Service once when a staff member joins and never again. Best practice is to check annually, or whenever there is a significant change in a staff member's role.

Fix: Build annual Update Service checks into your SCR review cycle. Set calendar reminders or use a platform like School SCR that can automate the scheduling and alerting process.

How to structure your DBS Update Service process

A compliant and defensible DBS Update Service process for schools follows these steps in order:

1. See the original DBS certificate. Check the number, level, and workforce category.
2. Confirm the individual is registered on the Update Service with that certificate.
3. Obtain explicit consent from the individual.
4. Run the online status check through the official DBS portal.
5. Record the outcome and save a screenshot or printout as evidence.
6. Update the SCR with the check date, outcome, checker name, and evidence location.
7. Schedule the next annual check or set an alert for follow-up.

This process takes less than ten minutes per person when it is set up correctly. The problem is that without a structured system, it rarely happens systematically, and gaps accumulate.

What inspectors expect to see

During an Ofsted or ISI inspection, the DBS Update Service entries on your SCR will be sampled alongside other vetting records. Inspectors expect to see:

• Clear evidence that Update Service checks were completed, not just that the original DBS exists
• Accurate recording of the check date and outcome
• Evidence that the original certificate was verified before the Update Service was used
• Consent documented for each check
• Appropriate escalation where the outcome indicated changes or that the certificate was no longer current

The most common weaknesses inspectors find are vague SCR entries and no evidence that consent was obtained. Both are straightforward to fix with a consistent process.

DBS Update Service and MATs: the additional challenge

For Multi-Academy Trusts managing multiple schools, the DBS Update Service creates an additional layer of complexity. If schools are each running their own checks using different processes and recording in different ways, Trust-level oversight is nearly impossible.

The risk is not just that one school might miss a check, it is that the Trust cannot see across all its schools to identify where the gaps are. A consistent, centralised platform resolves this. School SCR provides MAT-wide visibility of DBS Update Service check status, so central teams can see at a glance which schools are up to date and which need attention.

School SCR includes automated annual check reminders, and MAT-wide compliance dashboards. Book a free demo to see how we help schools and trusts stay on top of every check without the manual effort.