Introduction:

The Disclosure and Barring Service (DBS) plays a vital role in safeguarding by ensuring that individuals working with vulnerable groups are suitable for their roles.
A crucial part of the DBS check process is verifying the applicant’s identity.
The DBS has updated its identity checking guidelines, effective from 22 April 2025 (not mandatory until Nov 2025).
This blog post compares the new guidelines with the previous version (from 1 July 2021) and outlines how organisations can prepare for these changes.

Alternatively, you can just read the new guidance at : https://www.gov.uk/government/publications/dbs-identity-checking-guidelines/id-checking-guidelines-for-standardenhanced-dbs-check-applications-from-22-april-2025

What’s Changing? A Comparison of the 2021 and 2025 Guidelines

The DBS has updated its identity checking guidelines to enhance security and prevent fraud.
Here’s a summary of the key differences between the 2021 and 2025 guidelines:

Feature	2021 Guidelines (Effective 1 July 2021)	2025 Guidelines (Effective 22 April 2025)	Impact/Significance
Acceptable Documents	Specified lists of acceptable documents categorized into Group 1, Group 2a, and Group 2b.	Further analysis needed as the document is not yet released Specific details as to the changes to documents must be obtained before the publication date.	Clarification around what documents can be used to prove ID.
Online Checking		Increased emphasis on digital identity verification, potentially including use of online checking tools and verification services.	May require organisations to invest in new technologies or partner with identity verification providers. Could offer a more secure and efficient way to check IDs.
Validity of Documents	Specific expiration rules for some documents	Increased clarity and strict rules on expired documentation, with more emphasis on checking validity through official sources.	Ensures documents are current and less susceptible to fraud. May require more diligence in checking expiration dates and using online verification tools.
Document Verification	Guidance on visually inspecting documents for authenticity.	More stringent requirements for verifying document authenticity, potentially requiring organisations to use online verification services or contact issuing authorities.	Strengthens the integrity of the ID checking process and reduces the risk of accepting fraudulent documents. May require more specialized training for ID checkers.
Photographs		Enhanced Guidance on ensuring photographs on identity documents are a true likeness of the applicant.	Reduces the risk of impersonation. ID checkers will need to be more vigilant in comparing photographs to the applicant’s appearance.
Name Consistency	Emphasis on ensuring consistent use of names across all documents.	Emphasis on ensuring name consistency across all documents and providing clear procedures for addressing name discrepancies.	Reduces the risk of identity theft and ensures accurate record-keeping. Organisations will need to establish clear procedures for handling name discrepancies.
Addressing Discrepancies	Guidance on addressing discrepancies in information provided by the applicant.	More prescriptive procedures for addressing discrepancies, potentially including contacting the DBS for guidance.	Ensures a more consistent and thorough approach to resolving discrepancies. May require more training and support for ID checkers.
Retention of Copies	Guidance on retaining copies of identity documents.	Tighter restrictions on retaining copies of identity documents to comply with data protection regulations (GDPR).	Protects applicant privacy and reduces the risk of data breaches. Organisations will need to review their document retention policies.
Vulnerable Applicants	Limited guidance on supporting vulnerable applicants.	More specific guidance on supporting vulnerable applicants who may have difficulty providing standard identity documents.	Ensures that vulnerable applicants are not unfairly disadvantaged. Organisations will need to be more flexible and accommodating when checking the identities of vulnerable applicants.

Addressing Name Discrepancies on Passports

Name discrepancies can be a significant issue when verifying identity for DBS checks. It is vital that names used across all documentation match precisely. If discrepancies exist, you should seek to resolve them and, if necessary, seek clarification from the DBS. Here are a few common examples of name discrepancies that might occur on passports:

• Omission of Middle Names: The passport lists a full middle name, while other documents only use the initial, or omit the middle name entirely.
  • Example: Passport shows “Elizabeth Anne Smith”, but a utility bill is in the name of “Elizabeth Smith”.
• Use of Nicknames or Shortened Names: The passport lists a formal name, while other documents use a common nickname.
  • Example: Passport shows “Robert” but the bank statement shows “Bob”.
• Changes in Name Due to Marriage/Divorce: The passport may not yet reflect a change of name due to marriage or divorce.
  • Example: Passport is in maiden name “Jane Doe”, but the applicant now uses “Jane Smith” and provides a marriage certificate.
• Typographical Errors: There is a typographical error on the passport.

Dealing with Name Discrepancies:

• Seek Clarification: Ask the applicant to explain the discrepancy and provide supporting documentation to prove the link between the different names (e.g., a marriage certificate, a deed poll).
• Document the Explanation: Carefully document the explanation provided by the applicant and any supporting documentation.
• Assess the Risk: Assess the risk associated with the discrepancy. If the discrepancy is minor and there is strong supporting evidence to prove the link between the names, it may be acceptable. However, if the discrepancy is significant or there is a lack of supporting evidence, you may need to refuse the application or seek guidance from the DBS.
• Inform the DBS: Contact the DBS for guidance.
• Consult with the DBS: If you are unsure how to proceed, consult with the DBS.
• Be Consistent: Apply a consistent approach to dealing with name discrepancies.

Understanding the ID Presentation Options: Option 1, Option 2, and Option 3

The DBS identity checking process typically involves different options for how an applicant presents their identity documents for verification.

IMPORTANT: These descriptions are based on common practice and general understanding.
The 2025 guidelines will likely provide more specific details and may introduce new options, which MUST be incorporated upon release.
Also, the acceptability of these options may depend on the type of organisation and the level of trust required.

• Option 1: In-Person Verification (Preferred) This is generally the preferred option, as it allows the ID checker to directly examine the original documents and compare them to the applicant.
  • Applicant Presents Documents: The applicant physically brings the required documents to the ID checker.
  • Visual Inspection: The ID checker visually inspects the documents for authenticity, checks the validity dates, and compares the photograph (if applicable) to the applicant’s appearance.
  • Direct Interaction: The ID checker can ask the applicant questions to clarify any discrepancies or inconsistencies.
• Option 2: Postal Verification (Less Common, May Be More Restricted in 2025) This option involves the applicant sending copies of their documents by post. It is generally less secure than in-person verification and may be subject to stricter requirements under the new guidelines.
  • Applicant sends copies of document: The documents are sent by a method that requires a signature.
  • The checker returns the documents.
• Option 3: Presentation on First Day of Employment/Remote Verification (Potentially Subject to Stricter Controls) Some organisations may allow applicants to present their original documents on their first day of employment. This option may be discouraged or subject to stricter controls under the 2025 guidelines, especially if there is a significant delay between the DBS application and the start date.
  • Applicant Presents Documents on Start Date: The applicant brings the required documents to their employer on their first day of work.
  • Risk of Delay: There is a risk that the applicant may not be who they claim to be if they are allowed to start work before their identity has been properly verified.
  • Secure Remote Software: Use of a verified company to confirm ID.

Justification Required: Why You MUST Have a Valid Reason for Not Using Option 1

It’s crucial to understand that the DBS strongly prefers Option 1 (In-Person Verification) due to its superior security and reliability.
If your organisation chooses to use Option 2 or 3, you must have a valid and documented reason for not using Option 1.
This justification should be based on genuine circumstances that prevent in-person verification, such as:

• Exceptional Circumstances: The applicant lives in a remote location with no easy access to the organisation.
• Disability or Illness: The applicant has a disability or illness that prevents them from attending an in-person verification.
• Other Justifiable Reasons: Other legitimate reasons that make in-person verification impossible or impractical.

Remember, you may need to explain your reasoning.

Your organisation must keep a record of the reasons for not using Option 1, and be prepared to justify this decision if audited by the DBS. Failing to demonstrate a valid reason for not using Option 1 could result in penalties or sanctions.

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, establishing procedures for addressing name discrepancies, and outlining the acceptable reasons for not using Option 1.
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.
   • Detailed walkthrough of the requirements and risks associated with Option 1, Option 2 and Option 3, and the potential for Option 2 and 3 to be more restricted.
   • Documenting Valid Justifications: Staff must be trained on what constitutes a valid reason for not using Option 1 and how to properly document these justifications.
   • Assessing Name Discrepancies: Staff must be trained to identify and assess name discrepancies on passports and other documents, and on the appropriate steps to take in each case.
4. Invest in Technology (If Necessary): Consider investing in technology solutions that can help streamline the identity checking process and improve accuracy. This may include:
   • Online document verification services.
   • Identity management systems.
   • Secure document storage solutions.
5. Review Your Data Protection Practices: Ensure that your organisation’s data protection practices comply with GDPR and the new DBS guidelines regarding the retention of copies of identity documents.
6. 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 and the preferred option of in-person verification.
7. Seek Clarification from the DBS: If you have any questions or concerns about the new guidelines, contact the DBS for clarification.

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
• Previous DBS Identity Checking Guidelines (Effective 1 July 2021): https://www.gov.uk/government/publications/dbs-identity-checking-guidelines/id-checking-guidelines-for-standardenhanced-dbs-check-applications-from-1-july-2021
• 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, particularly those surrounding name discrepancies, the options for presenting documents (Option 1, Option 2, and Option 3), recognizing the strong preference for Option 1, and taking proactive steps to prepare, organisations can ensure a smooth transition and continue to protect vulnerable individuals.

Things to remember:

• Download and review the new DBS identity checking guidelines.
• Pay close attention to the updated requirements and potential restrictions for Option 1, Option 2, and Option 3.
• Update your organisation’s policies and procedures, including the process for justifying the use of Options 2 or 3 and procedures for handling name discrepancies.
• Train your staff on the new requirements, the importance of documenting valid justifications, and assessing name discrepancies on passports and other documents.
  
  

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. 
The descriptions of Option 1, Option 2, and Option 3 are based on common understanding and are subject to change based on the official 2025 guidelines.
The requirements around justifications for not using Option 1 and the handling of name discrepancies will also be detailed in the official guidance.