Changes to enhanced disclosure applications

5 April 2019

The Disclosure and Barring Service (DBS) has announced that changes to be introduced from 6 May 2019 will affect both applicants and Registered Bodies.

From that date, the DBS will no longer be able to amend enhanced applications that have been submitted with missing or incorrect information regarding a number of sections.

With regard to applicants, the changes affect the section relating to addresses at which they have resided within the last five years, that have not been declared on the application.

Applications found to have this missing address information will be withdrawn and a new application will need to be submitted.

As for Registered Bodies, the sections that are being amended are:

  • Question X61 — Position applied for (incorrect workforce selected)

  • Questions X64 and X65 — Barred list checks

  • Question X66 — Home-based checks.

If incorrect information is provided as part of these questions from Section X, the application will be withdrawn, and a new application will be required. It should be noted that, if an application is withdrawn for the above reasons, then a refund will not be given.

Registered Bodies are registered with DBS to submit standard and enhanced disclosure checks either via the paper application route or electronically.

If submitting via the paper route they must submit a minimum of 100 applications and, if submitting electronically, they must submit a minimum of 1500 applications, both in a 12-month rolling period.

See for more information on the roles of Responsible Organisations, Registered Bodies and Umbrella Bodies.

Comment by Andy Willis, Head of Legal at Croner

These changes could be frustrating for employers who have made conditional offers subject to a DBS check and may therefore find themselves waiting longer to take on a strong applicant because of a delay caused by a mistake.

It could also cause issues if the employer pays for the check as part of its recruitment process; if an application is withdrawn, it will have to foot the bill again if it still wishes to hire the candidate.

Despite this, employers are reminded that DBS checking can help bring to light details about individuals that could cause issues when they are taken on as employees. These developments may make it harder for applicants to submit false information, or deter them from doing so.