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Section 128 Checks Explained
Who Needs Them and How to Stay Compliant

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Jay Ashcroft

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Co-founder

Last updated: 4th April, 2025

When it comes to Safer Recruitment in English state schools, Section 128 checks are a vital part of ensuring that those in leadership and management roles are suitable to work in education. Yet despite their importance, these checks are often misunderstood or overlooked, particularly by schools struggling to keep up with recruitment compliance. In this blog, we’ll break down what Section 128 checks are, who needs them, and how School SCR can take the hassle out of managing the vetting process.

What is a Section 128 Check?

A Section 128 check refers to a direction made under Section 128 of the Education and Skills Act 2008, which bars individuals from taking part in the management of schools if they are deemed unsuitable.

The check reveals whether someone has been prohibited from:

  • Managing an independent school
  • Holding a directorial role in an academy trust
  • Acting as a governor or senior leader

A Section 128 direction is typically issued where an individual has committed misconduct serious enough to question their fitness to lead or manage in education. The reasons could include financial misconduct, safeguarding failures, or other professional concerns.

Who Needs a Section 128 Check?

While not everyone working in a school requires a Section 128 check, anyone involved in management positions must be vetted. This includes:

  • Headteachers
  • Deputy or assistant headteachers
  • Members of the senior leadership team (SLT)
  • Governors
  • Trustees or directors of academy trusts
  • Anyone involved in the management of an independent school

For academies and free schools, Section 128 checks are especially critical, as trustees and members often sit outside the day-to-day school operations but still have legal and strategic oversight.

In maintained schools, while there is less structural complexity, the same rule applies for governors and senior leaders.

For teaching staff who aren’t in management roles, Section 128 checks are not usually required, but this depends on job responsibilities.

How is a Section 128 Check Carried Out?

Section 128 directions can be checked in one of two ways:

  1. Through the Teaching Regulation Agency (TRA) via the Employer Access Service (EAS) – for qualified teachers or individuals with a Teacher Reference Number (TRN).
  2. Through an enhanced DBS check with children’s barred list and management responsibilities indicated – where the Section 128 status will show if relevant.

Schools must record the outcome of the check on their Single Central Record (SCR).

And here’s where many schools run into problems.

The Pain Points of Managing Section 128 Checks

Even with good intentions, schools often struggle to keep their vetting procedures up to date. Here are a few common issues:

  • Manual errors: Schools relying on spreadsheets or paper records can easily make mistakes in recording or following up on checks.
  • Lack of clarity: Staff aren’t always clear on who needs a Section 128 check or how to interpret results.
  • Delayed onboarding: Waiting for checks to come through or confusion about where to access them can slow down recruitment.
  • Ofsted pressure: During inspections, any missing or incorrect SCR entries, especially for leadership roles, can raise safeguarding red flags.

These problems are made worse in MATs or larger schools where multiple appointments happen frequently.

How School SCR Helps Streamline the Section 128 Process

School SCR is a digital solution built to simplify compliance with SCR and Safer Recruitment requirements, including Section 128 checks. Here’s how it works, and why it significantly improves school safeguarding:

1. Automated Role-Based Checks

School SCR automatically identifies which vetting checks are required based on a staff member’s role. If someone is in a management or leadership position, the platform prompts the admin to complete a Section 128 check and logs it once done. No second-guessing. No forgetting.

2. Smart Integration With DBS and TRA

School SCR integrates with vetting providers and pulls in results directly when available. For those checked through the TRA, School SCR can log results seamlessly. For DBS-based checks, you can attach confirmation of the Section 128 clearance to the person’s profile.

3. Real-Time Status Monitoring

You can see at a glance which checks are complete, pending, or overdue. This means that if a Section 128 check hasn’t been done, or needs updating, you’ll know right away. No more scrambling during inspections or audits.

4. Built-In Audit Trail

Every action in School SCR is logged. If Ofsted or the local authority asks for proof of compliance, you can produce a full digital audit trail in seconds. This reduces anxiety around inspections and improves accountability.

5. Multi-Site Management for MATs

For multi-academy trusts, School SCR lets you manage vetting across all your schools from one central dashboard. So if a governor sits on multiple boards or a senior leader works across sites, their checks only need to be verified once and can be shared across schools.

6. Alerts and Compliance Reporting

Custom alerts notify you when rechecks are needed, or if a record is incomplete. You also get compliance reports that highlight gaps before they become issues. It’s proactive compliance, not reactive firefighting.

Why This Matters

Section 128 checks aren’t optional, they’re part of the statutory guidance set out in Keeping Children Safe in Education (KCSiE). Getting them wrong can lead to failed inspections and, more importantly, put students at risk.

By using a system like School SCR, schools can move beyond spreadsheets and manual systems that leave too much room for error. Instead, they can build a robust, efficient vetting process that keeps staff records up to date, inspection-ready, and fully compliant.

Final Thoughts

Every school wants to keep children safe and meet its statutory obligations. But the admin burden of Safer Recruitment can be overwhelming, especially when it comes to things like Section 128 checks, which aren't always clearly understood.

School SCR removes the guesswork and streamlines the entire process. Whether you're onboarding a new headteacher or adding a governor to your MAT board, you’ll know exactly what’s needed, and when. More importantly, you’ll be confident your SCR is accurate, complete, and ready for inspection at any time. Book your demo today.


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