Guidance on the PVG Scheme Changes for Community-Based Youth Work
Following a period of consultation within the voluntary sector and beyond, Disclosure Scotland is introducing significant changes to the Protecting Vulnerable Groups (PVG) scheme, effective from 1 April 2025.
The following guidance will help you and your youth group:
- Understand what the key changes are.
- Know what steps will be needed to be ready for 1 April.
These updates aim to strengthen safeguarding, improve efficiency, and ensure compliance across the youth work sector. We have summarised the key changes and what they mean for community-based youth work organisations, youth workers, and volunteers.
Key Changes to the PVG Scheme
Legal Requirement for PVG Membership
From 1 April 2025, it will be a legal requirement for anyone aged 16 or over carrying out a regulated role (see below) with children (individuals under 18) or protected adults to be a member of the PVG Scheme.
What this means: anyone working or volunteering in regulated youth work roles must apply for PVG membership if they haven’t already.
Transition from ‘Regulated Work’ to ‘Regulated Roles’
The term ‘regulated work’ will be replaced by ‘regulated roles’ with eligibility criteria.
What this means: youth work roles already considered ‘regulated work’ are expected to still require PVG membership under the new terminology.
A regulated role with children applies to paid staff and volunteers working with those under 18 where their normal duties involve:
- Teaching, instructing, training, or supervising children
- Being in sole charge of children
- Providing advice or guidance relating to a child’s physical or emotional well-being, education, or training
For a role to be regulated, these activities must be a regular and expected part of the role—not incidental.
If you’re unsure whether a role qualifies as regulated, Volunteer Scotland provides a basic checklist.
New Offences and Compliance Requirements
From 1 July 2025, it will be an offence to:
- Work in a regulated role without PVG membership.
- Recruit someone into a regulated role if they are not a PVG member.
Penalties for non-compliance include fines, imprisonment (up to five years), or both.
A three-month grace period (1 April – 1 July 2025) will allow individuals to continue working while their PVG application is being processed.
As before it is an offence to request a PVG check for someone who is not undertaking a regulated role.
What this means: organisations must ensure all relevant staff and volunteers are PVG members before the deadline.
Online PVG Applications
The PVG application process is now fully online, replacing paper-based forms We are also moving our application process online, replacing the previous Word & Excel documents. You will be sent a link to the new form when you next enquire about PVG applications. If you access the PVG scheme through an Area Association, please contact them for any questions or variances in their process.
Applicants must create an account with Disclosure Scotland to apply. They will be guided through account creation as part of the usual ID confirmation process.
What this means: organisations will need to familiarise themselves with and support their staff/volunteers to navigating the new digital system.
Live PVG Scheme (Continuous Updates)
A new feature ‘Live PVG’ provides continuous updates to an individual’s PVG record.
If new information (e.g. a criminal conviction) is added to a record, the employer will automatically be notified. This reduces the need for repeat PVG checks.
What this means: organisations must be prepared to act on notifications and should update safeguarding procedures accordingly.
Applicant Control Over Disclosure Information
From 1 April 2025, applicants will have more control over their PVG records.
They must share their disclosure certificate with the accredited body that signed their application. They will have 10 working days to do this once their application is processed.
What this means: organisations will no longer receive disclosure information automatically—applicants must log in to their Disclosure Scotland accounts and click to share their certificate. You cannot allow staff/volunteers to work in a regulated role if they have not shared their disclosure certificate.
Fee Structure Updates
The fees for PVG applications have not changed.
Volunteers in qualifying roles should still be eligible for free PVG checks.
What this means: organisations should check whether their volunteers qualify for free checks and ensure they apply correctly.
Board members, Committee members and Charity Trustees guidance (from Volunteer Scotland)
The introduction of the activity relating to Board members, Committee members and Charity Trustees.
They must carry out the following activity:
- Holding a position of responsibility in an organisation which has as one of its main purposes the provision of benefits for or to children (regardless of whether the organisation has an additional purpose of providing benefits for or to another group of persons).
AND/OR
- Holding a position of responsibility in an organisation which has as one of its main purposes the provision of benefits for or to protected adults (regardless of whether the organisation has an additional purpose of providing benefits for or to another group of persons).
Charity trustees and committee or board members who are carrying out the activity above must also have contact with children and/or protected adults. Contact includes physical, visual, written or verbal communication or exercising power or influence over children and/or protected adults.
Exercising power or Influence” means either:
(a) assisting, facilitating, permitting or impeding progress towards a desirable objective or outcome for a particular child or protected adult.
(b) making decisions of an operational or strategic nature that could have an impact on a number of children, or protected adult.
(c) persuading or putting pressure on a particular child or protected adult to behave or act in a certain manner for the financial gain or personal gratification of a person other than the child or protected adult.
This activity allows PVG membership for children and/or protected adults where the above criteria is met.
If you were unable to access a PVG for your charity trustees and committee or board members for both work groups previously, and they now meet the criteria above for both, you must apply for a PVG scheme membership.
From 1 April 2025 it becomes legal requirement for anyone carrying out a regulated role to be a member of the PVG Scheme for that type of work.
Organisations not based in Scotland:
Board members, committee members and charity trustees of UK charities must be carrying out a regulated role in Scotland to some extent.
Board members, committee members and charity trustees of UK charities not carrying out a regulated role in Scotland should contact Disclosure and Barring Service for advice.
Originally available here: Board members, Committee members and Charity Trustees guidance
Next Steps for Groups to be Ready for 1 April
The previous section outlines what the changes to the PVG scheme are, this section suggests steps you and your Board can take to be prepared for the upcoming changes.
Actions Required for Organisations
- Review all roles within your organisation to determine if they qualify as ‘regulated roles.’
- Ensure that all individuals in regulated roles apply for PVG membership before 1 April 2025.
- Update recruitment and safeguarding policies to reflect these changes.
- Communicate with staff and volunteers about their responsibilities under the new legislation.
- Familiarise your team with the new online PVG application system.
- Prepare for notifications under the Live PVG scheme and ensure safeguarding processes are in place.
Actions Required for Individuals (Youth Workers & Volunteers)
- Create an online account with Disclosure Scotland to complete your PVG applications.
- Ensure personal information is up to date with Disclosure Scotland using your online account.
- Be aware that PVG records will be continuously updated, and employers may be notified of any changes.
- Remember to share your PVG disclosure with your organisation within 10 days of being notified by Disclosure Scotland that your PVG check has been completed. You will not be able to work/volunteer if you do not do this.
Disclosure (Scotland) Act 2020 (Disclosure Act) – Regulated roles online ‘guidance’ tool
Disclosure Scotland has just launched an online tool that can provide guidance on whether a role requires PVG membership:
This tool is designed to help you get ready for the changes to the disclosure system that come into force on 1 April. You should submit PVG applications as normal until then.
The Protecting Vulnerable Groups (PVG) scheme is a membership scheme for people working with children or protected adults.
It’s a legal requirement to join the scheme if you’re doing a regulated role with these groups. For example, teachers or nurses.
There are other types of disclosure, depending on the work you’re doing.
You can use their tool to check if a role needs PVG scheme membership
Future Changes to the PVG Scheme
After 1 April 2026 new PVG checks will last for five years before expiring. This will formalise re-checking your workforce and will replace previous guidance to re-check staff/volunteers every three years. Disclosure Scotland are yet to announce how the transition non-expiring to five-year certificates will be handled.
What this means: There is no action needed now but be aware that a further change is coming and watch out for announcements from Disclosure Scotland and Youth Scotland.
Support and Further Information
Disclosure Scotland are running online training to help prepare you for the changes. You can check their Eventbrite for listings
Disclosure Scotland maintain a mailing list that you can subscribe to here
For official details, visit: https://www.disclosure.gov.scot/changes
If you are a member with any questions, you can contact Youth Scotland at office@youthscotland.org.uk or call 0131 554 2561.
If you access the PVG scheme via one of our Area Association partners, you should contact their PVG lead officer:
Gayle Brown Youth 1st |
Jemma Laidlaw Youth Borders |
Coral Allan Youth Highland |
 Alison McCallumLAYCpvgenquiries@layc.org.uk |
Thank you for your continued commitment to safeguarding young people in community-based youth work.