An update from Disclosure Scotland

Disclosure (Scotland) Act 2020 update - November 2025

An update on the Disclosure (Scotland) Act 2020 and what's coming next.

Five-year Protecting Vulnerable Groups (PVG) scheme

Regulations laid in the Scottish Parliament confirm that the five-year PVG scheme membership will come into force on 1 April 2026.

Important information

• Organisations should continue to submit PVG scheme applications as normal, including payment of any fees associated with your applications. From now, or once the five-year membership starts (1 April 2026), do not change how often or when you apply for the PVG scheme.

• If you are a PVG scheme member who joined before 1 April 2026, you do not need to do anything now. We:

  • will contact you to tell you when you will move to the five-year PVG scheme membership

  • expect this to happen in phases

  • are working with stakeholders to understand the requirements for this transition

  • will tell you more about this as soon as possible

In the meantime, PVG scheme members should ensure that their details are up to date. For information on how to update your PVG details, timescales and legal requirements please visit our website.

• From 1 April 2026, individuals who join the PVG scheme will automatically be part of the five-year PVG scheme membership. Every five years, renewal will be required. For example:

  • Andrew joins the PVG scheme on 2 April 2026 and will be required to renew their membership by 2 April 2031. Andrew will be contacted about their renewal no later than 2 January 2031. The ‘interested parties’ on Andrew’s PVG scheme membership are notified that Andrew’s membership is due for renewal. The interested parties do not need to take any action.

  • Charlotte joins the PVG scheme on 31 January 2027 and will be required to renew their membership by 31 January 2032. Charlotte will be contacted about their renewal no later than 31 October 2031. The ‘interested parties’ on Charlotte’s PVG scheme membership are notified that Charlotte’s membership is due for renewal. The interested parties do not need to take any action.

Andrew and Charlotte must renew their membership if they are carrying out a regulated role. This ensures that they meet their legal requirement.

If Andrew or Charlotte were not carrying out a regulated role, and did not plan to in the future, they should tell us they will not renew their membership. If Andrew or Charlotte stop carrying out a regulated role after they start their five-year membership, they, and the organisation, must notify us at dsupdate@disclosurescotland.gov.scot

​

What organisations can do now

You should notify us when a PVG scheme member stops carrying out a regulated role for you. This will:

• reduce unnecessary admin

• ensure you do not receive updates you are no longer entitled to

• prevent you from receiving notifications relating to five-year PVG scheme renewal or transition from 1 April 2026 onwards 

To do this, please email dsupdate@disclosurescotland.gov.scot with the individual’s name, date of birth and PVG scheme number. Our team will then remove your interest in the PVG scheme member. 

If you are an accredited body with Disclosure Scotland and you are unsure which PVG scheme members you are linked with, we can provide you with a record of PVG scheme members that your organisation is linked to. Please request this by contacting our dedicated team at dsupdate@disclosurescotland.gov.scot and provide your countersignatory and accredited body codes in your request. 

Conditions on scheme members under consideration for listing

The Disclosure (Scotland) Act 2020 gave us new powers to impose conditions on people while we investigate whether the person may be unsuitable to carry out a regulated role. The conditions will end when we reach a decision to bar them or not. These provisions will enhance an already effective barring service and will only be used when necessary, not in every case.

Introducing this change is complex, and it is important that these new powers are used in a necessary and proportionate way. Therefore, this change will not come into force in 2025.

We will continue our work to engage with major stakeholders, such as professional regulators and other agencies, to develop our implementation plans.

In the meantime, our existing safeguarding functions will remain in place. Where an individual is under consideration for listing, it is the responsibility of the recruiting organisation, in all cases, to assess an individual’s suitability for regulated roles, based on what is contained in the disclosure information, and to mitigate any risks accordingly.

We will tell you more about this when we can.

Disclosure Scotland turnaround times

You can view our latest application performance stats on our website.

Our service level agreement is to complete 90% of applications within 14 calendar days from the date we receive them. In some cases, additional checks, often with external agencies, are required to process an application, which may mean they take longer. These checks can be triggered by circumstances unrelated to the applicant. In most cases, they do not affect the outcome of an application but are essential and legally required parts of our safeguarding process. Due to the nature of these checks and the procedures of the organisations involved, we are unable to provide specific details. However, we work proactively with the external organisations to support the timely return of the required information.

Feedback

We will continue to provide you with regular updates on implementation of the rest of the Disclosure (Scotland) Act 2020. Please let us know what you would like to see in future updates by contacting our Communications Team directly via email (dswebteam@disclosurescotland.gov.scot).