Last reviewed 19 May 2020

In response to the COVID-19 crisis, the Care Quality Commission (CQC) has provided interim advice following the temporary changes made by the Disclosure and Barring Service (DBS) to DBS applications and processes.

The CQC has issued interim guidance on DBS and other recruitment checks, for providers recruiting staff and volunteers to health and social care services in response to the COVID-19 outbreak. This follows temporary changes being made by the DBS to applications and processes.

The guidance applies to paid staff and volunteers being recruited as a consequence of and during the COVID-19 pandemic, and where providers need to start staff urgently, where waiting for a full DBS check could cause undue delay, and where this delay could lead to risks to the continuity of service, impacting the safety and wellbeing of people using the service.

Providers are being offered free DBS checks for eligible roles being recruited in response to COVID-19. Those who are eligible for and applying for a check of the barred list for emergency roles will be fast tracked. This barred list check applies to staff working with children and adults.

The regulator said that, if providers take reasonable steps to ensure new staff are recruited in line with its new DBS guidance, and staff are adequately supported and sufficiently supervised so that people are safe, the CQC will not take a punitive approach. However, it advised that providers should record the decisions they have made, and any risks identified along with the mitigations they will put in place.

As an example, the CQC said that, as part of recruitment for these emergency roles, providers might consider accepting an existing relevant DBS check from a previous employer provided it is less than three years old and for a similar role. The CQC will take a "pragmatic view" on the portability of certificates for those being employed in emergency roles.

Providers are responsible for risk assessing their situation and making decisions based on the needs of their service and people using that service during this emergency.

The regulator stressed that all other appointments and applications for DBS checks that are not linked to COVID-19 must be processed according to existing DBS and CQC guidance.

The interim guidance will be in operation for the period the Coronavirus Act 2020 is in force and will be reviewed on a regular basis.

The CQC interim advice on DBS is available at:

Other emergency changes to the CQC's guidance for registered providers are listed on the CQC website at: