UPDATED: 19 August 2025
Regulated activity refers to specific roles and tasks that involve working with children and adults at risk. The definition includes what activity a person does as part of their role, the regularity that they do this with, where the work takes place and work that requires close and unsupervised contact with these groups. The legislation dictates that an individual can be barred from regulated activity and therefore should not work with these groups if this is the case. Regulated activity is managed by the Disclosure and Barring Service (DBS) and is managed in the form of DBS checks of those in roles with children and adults at risk.
This blog tracks the progress of key activities specifically on the definition of regulated activity for working with children.
25 February 2025: Crime and Policing Bill announced in House of Commons
On 25 February, Yvette Cooper (Home Secretary) announced the Crime and Policing Bill in the House of Commons.
The Crime and Policing Bill proposes the removal of the supervision exemption from the definition of regulated activity. This means that those who are eligible for a check issued by the Disclosure and Barring Service (DBS) and are supervised can now access this check. Previously, those who were eligible but were supervised in their roles would have been exempt from having to get a DBS check.
This bill is currently progressing through the House of Lords and therefore this measure is not currently in legislation.
Read the bill and factsheet here:
April 2024: Thirtyone:eight publishes a manifesto
Thirtyone:eight, the UK’s leading independent Christian safeguarding charity, published its first-ever manifesto setting out the key opportunities it has identified to improve policy, legislation and guidance to offer greater protection from harm and abuse to all children and adults living in the UK.
The manifesto, entitled ‘Together we can - a manifesto for a safer society for all’, contains a number of key recommendations grouped into three main themes. The recommendations aim to strengthen the safeguards that are already in place, better protect victims and survivors of abuse, and create safer environments for all. One of the key areas of focus in the manifesto is advocating for a review of the definition of regulated activity to ensure that all relevant roles in faith communities are covered and the frequency element of the regulated activity definition to be removed in order that the definition is based on the nature of contact with children.
Read the Thirtyone:eight manifesto.
Read about the work Thirtyone:eight is calling for
October 2022: Independent Inquiry into Child Sexual Abuse (IICSA) published
The Independent Inquiry into Child Sexual Abuse (IICSA) was established in 2015 as a statutory inquiry for England and Wales and took seven years to complete. It was independent and was therefore not led by any specific government department. The inquiry heard 7,000 personal testimonies, 15 investigations, public hearings and considered two million pages of evidence.
The final report was published in October 2022 and made 20 specific recommendations based on the evidence considered as part of the inquiry.
One of the recommendations of the inquiry was to improve access to the barred list and the suggestion was made that a way to do this would be to remove the supervision exemption. This would mean that those in role that have close contact with children who are supervised would still be expected to get the relevant DBS check rather than being exempt.
Read the report and recommendations here:
Read the full report of the Independent Inquiry into Sexual Abuse (IICSA).
Read the 20 recommendations of the Independent Inquiry into Sexual Abuse (IICSA).
2012: The Protection of Freedoms Act and the establishment of the Disclosure and Barring Service (DBS)
The Disclosure and Barring Service was also established by merging the Criminal Records Bureau (CRB) and the Independent Safeguarding Authority (ISA).
The Protection of Freedoms Act (2012) narrowed the regulated activity definition to focus on roles which involves close and unsupervised contact with children and vulnerable adults. The definition now focuses on the activity undertaken alongside the regularity. DBS started operating on 1 December 2012. Its equivalent agencies are Disclosure Scotland in Scotland (for PVG Checks) and Access Northern Ireland in Northern Ireland (for AccessNI checks), although it covers convictions from every part of the UK.
A DBS check/PVG check/AccessNI check gives information held by the police and government departments on a person’s criminal record, which enables an organisation to assess the suitability of a person applying for a paid or volunteer role with them. It's a requirement of charity regulators that organisations will check anyone whose role makes them eligible for a check.
You can read the definition and guidance on regulated activity here:
Safeguarding Vulnerable Groups Act (2006)
The Safeguarding Vulnerable Groups Act was introduced in 2006 in response to the Soham murders 2002 which drew to attention significant gaps in the vetting and barring system for individuals working with children and vulnerable adults.
The act created the Independent Safeguarding Authority which was established in 2007. The Authority managed the lists of individuals barred from working with children and vulnerable adults.
The act defined “regulated activity” as including anyone working closely with children or vulnerable adults, either paid or unpaid, not part of a family or personal arrangement, on a frequent, intensive or overnight basis. Frequent was defined as means once a week or more (except in health or personal care services where frequent means once a month or more); intensive means on four days or more in a single month.
The act required employers to check the lists before hiring individuals for regulated activities. This is to protect against unsuitable individuals gaining access to vulnerable groups. Under this legislation, a legal duty was introduced for organisations to refer relevant information to the Independent Safeguarding Authority (ISA) relating to concerns about an individual’s suitability. An offense was also introduced under this legislation for any individual who is barred to seek to engage, offer or engage in regulated activity.
June 2004: Bichard Inquiry was published
In June 2004, the Bichard Inquiry was published. This inquiry was undertaken by Lord Michael Bichard. The inquiry recommended that there should be a mandatory registration system where anyone working with children and vulnerable adults should be vetted before working with them and a national system to be implemented for police forces to share intelligence information (such systems were missing in the case of the Soham murders).
You can read the inquiry here:
August 2002: Soham Murders
In August 2002, two 10-year-old girls, Holly Well and Jessica Chapman were murdered by their school caretaker, Ian Huntly in Sohan, Cambridgeshire.
After the murders, it transpired that Ian Huntley had a range of previous sexual offenses relating to underaged teenage girls. By 2001 (one year before the murders), he had been reported to the police on ten occasions and to social services on five occasions. However, he did not have any criminal convictions.
2002: Police Act (1997) established the Criminal Records Bureau (CRB), launched in 2002.
The Criminal Records Bureau (CRB) was established in 2002 as part of the Passport and Records Agency and later became an Executive Agency of the Home Office in its own right. The CRB provided wider access to criminal record information through its Disclosure service for England and Wales. Before its introduction applicants were only checked against List 99 (the then barred list centrally monitored by the Department for Education) or by requesting details of a criminal history at a local police station.