Introduction:

The Disclosure and Barring Service (DBS) has introduced updated identity checking guidelines for Standard and Enhanced DBS check applications, mandatory from 1 November 2025.

These new guidelines, which become mandatory for all DBS applications from that date, aim to strengthen the identity verification process, enhance security, and prevent fraud.

This blog post outlines the key changes in the ID checking process and highlights the additional requirements placed on ID checkers.

Key Changes to the DBS Identity Checking Process

The new guidelines introduce several important changes designed to enhance security and prevent fraud in the DBS check process.

While the overall objective remains the same – to verify the applicant’s identity – the methods and requirements have been significantly enhanced.

Some key changes include:

• Streamlined List of Acceptable Identity Documents: The previous guidelines used specified lists of acceptable documents categorised into Group 1, Group 2a, and Group 2b. The new guidelines feature a streamlined list of acceptable identity documents. ID Checkers must now ensure that the document is valid, in date, and belongs to the applicant, with the photograph a true likeness (if applicable).

  • This change requires ID Checkers to have greater document knowledge to reduce fraudulent submissions.

• Emphasis on Options for Viewing Documents: Previously, there were no set options for how the documents should be viewed.

  • Now, there is an emphasis on In-Person verification, unless it is impossible to complete.

• Ensuring Name Consistency: Emphasis has been put in place, to ensure the names used match on all verification documents, “The names must match exactly as the applicant provides on their application form, and this must then be shown as accurately as possible on their DBS Certificate””.

• Addressing Discrepancies in Information: Emphasis has been put in place, to ensure the ID checkers; “Contact the applicant if there are errors or inconsistencies with the information they’ve given for their DBS application and on their supporting identity documents””.

Additional New Requirements of the ID Checker

The new guidelines place significant emphasis on the ID checker’s role and responsibilities.

Here are some of the key additional requirements:

• Checking Document Validity and Authenticity: ID checkers must now conduct more thorough checks to ensure that the documents presented are valid, in date, and belong to the applicant.

  • The ID checker should be able to identify fraudulent documentation.
    “Ensure that the document is valid and in date at the time you check it. Check that it belongs to the applicant and the photograph, if present, is a true likeness.”

• Verifying Photograph Likeness: ID checkers must compare the photograph on the document to the applicant’s appearance to ensure that it is a true likeness.
  “If you do not think the document photograph is a true likeness of the applicant, you must not accept the document.”

• Maintaining Accurate Records: The organisation needs to maintain detailed records.
  “Each case should be looked at individually. The evidence must be properly and lawfully considered and documented. It must be retained in line with GDPR, data protection laws, and the DBS Code of Practice.”

• Contacting the Applicant: If inconsistencies arise, contact the applicant to clarify.

How to View ID Documents

Based on the DBS Identity Checking Guidelines, these are the different options for viewing the ID documents for the applicant:

• Option One: In-Person Verification (Preferred)

  The ID check should be done in person, allowing the ID checker to view the physical documents, or eVisa, or digital PASS card, in the presence of the individual.

  If you cannot use option 1, please consider using digital identity verification before considering option 2.

• Option Two: Verification via Video Link with Documents in Possession of ID Checker

  The ID checker can conduct the ID check via video link – for example Google Meet or FaceTime. In these circumstances, the ID checker must be in possession of the physical documents. These can be posted to the ID checker in advance of the virtual call. Any risks identified when using live video must be assessed and mitigated by you. You must not rely on the inspection of the documents via a live video link, or by checking a faxed or scanned copy of the document.

  If option two is used, you must keep a record of why option one was impossible, along with a record of the documents used to validate the identity, for a minimum of 2 years. The rationale must be specific to the individual ID verification; it is not acceptable to default to the use of options two or three. You should also consider using digital identity verification.

• Option Three: Verification via Video Link with Documents Presented on First Day of Employment

  The ID check can be completed via video link – for example Google Meet or FaceTime – without the ID checker being in physical possession of the ID documents. The details of the documents, as set out above, must be recorded and stored at the time of the video link ID check. The documents must be presented to the ID checker on the first day of employment. The ID checker must record the date the ID check was completed in person and cross-reference the details recorded from the video link ID check. If there are any discrepancies, the DBS check may be invalid.

  If option three is used, you must keep a record of why options one and option two were impossible, along with a record of the documents used to validate the identity, for a minimum of 2 years. The rationale must be specific to the individual ID verification; it is not acceptable to default to the use of options two or three as part of your process.

Important Considerations When Choosing An Option:

If Option 1 (In-Person Verification) cannot be used, it is imperative that the ID checker keeps a clear record of the reasons why.

The rationale must be specific to the individual ID verification, and not a generic reason. Additionally, organizations should seriously consider using digital identity verification as a robust alternative to Options 2 and 3.

Addressing Document Discrepancies

If there are any discrepancies in the information provided by the applicant and/or the identity documents supplied, and fraud is not suspected, you must ask the applicant to clarify. You must be satisfied that the discrepancies are legitimate and all name and address information is captured on the form in the current or previous name/address section. If you do not do this, it may compromise the integrity of the DBS service and introduce risk to your recruitment or licensing arrangements and may cause delays in processing certificates. Discrepancies in information can include:

• Long names and/or initials on passports: UK passports have an ‘observations’ section that should contain the full name. ID checkers should check examples of documents presented on the public register of authentic identity and travel documents online (PRADO) to establish if non-UK issued documents presented should have a similar section.

• Different spelling of a name: For example, an umlaut over the letter ‘U’, a common alternative spelling of a name (Katherine instead of Kathryn) or a hyphenated name. In these circumstances, the correct spelling as identified by the applicant should be used as the current name. Common alternative spellings and missing umlauts or hyphens do not need to be entered as previous names. Materially different names should be entered as previous names on the application form.

• Missing or additional names on identity documents: For example, a driving licence with a missing middle name. This should only be the case where an individual has changed their paper driving licence to a photocard driving licence. To apply for a photocard licence for the first time a passport, EEA identity card or birth certificate need to be presented to DVLA so any middle names would be recorded. If a document with a missing or additional name is accepted, the current name on the application form should be the applicant’s full name, including the missing or additional name.

• Applicant is not currently living at their primary address: Junior doctors or students for example. These applicants may have a driving licence or letters in an address in a different part of the country. Students who live on campus during term time but still reside at their parents’ address, or junior doctors who are on a placement in a different county but retain a permanent address in the city they are usually employed in. Both their permanent address and their term-time or temporary address must be included on the application form. The current address should be the address to which the applicant wishes to have their DBS certificate issued.

Preparing for the New Guidelines: A Step-by-Step Approach

To ensure a smooth transition to the new DBS identity checking guidelines, organisations should take the following steps:

1. Familiarise Yourself with the New Guidelines: Carefully review the full text of the new DBS identity checking guidelines (effective 22 April 2025). Ensure that all staff involved in the DBS check process are fully aware of the changes. https://www.gov.uk/government/publications/dbs-identity-checking-guidelines/id-checking-guidelines-for-standardenhanced-dbs-check-applications-from-22-april-2025

2. Update Your Policies and Procedures: Review and update your organisation’s policies and procedures for DBS checks to reflect the new guidelines. This includes updating the list of acceptable documents, incorporating the new requirements for verifying document authenticity, and establishing procedures for addressing name discrepancies. Review the documentation that needs to be kept for reasons if Option 1 cannot be carried out.

3. Train Your Staff: Provide comprehensive training to all staff involved in the DBS check process on the new identity checking guidelines. This training should cover:

   • The new list of acceptable documents.

   • How to verify document authenticity.

   • How to address name discrepancies.

   • How to support vulnerable applicants.

   • Data protection requirements related to handling identity documents.

   • Protocols to ensure all the details to see the identity documents are followed and ensure reasons are kept for 2 years, if required.

4. Communicate with Applicants: Clearly communicate the new identity checking requirements to applicants and provide them with guidance on what documents they will need to provide.

Resources:

• New DBS Identity Checking Guidelines (Effective 22 April 2025): https://www.gov.uk/government/publications/dbs-identity-checking-guidelines/id-checking-guidelines-for-standardenhanced-dbs-check-applications-from-22-april-2025

• DBS Website: https://www.gov.uk/dbs

Conclusion:

The updated DBS identity checking guidelines are designed to enhance security and prevent fraud in the DBS check process.

By understanding the changes and ensuring ID checkers are well-trained and equipped to meet the new requirements, organisations can ensure a smooth transition and continue to protect vulnerable individuals.

Things to remember:

• Bookmark the new DBS identity checking guidelines:
   https://www.gov.uk/government/publications/dbs-identity-checking-guidelines/id-checking-guidelines-for-standardenhanced-dbs-check-applications-from-22-april-2025

• Ensure ID checkers are fully trained on the new requirements.

• Update your organisation’s policies and procedures.

Disclaimer: This blog post provides general information only and should not be considered legal advice.
Always consult with the official DBS guidance on the GOV.UK website for specific guidance related to your organisation.