Volunteers Are No Longer "Low Risk": What the New Regulated Activity Changes Mean for Safeguarding

2 Jul

When we talk about safer recruitment, conversations often focus on paid employees but safeguarding has never been about job titles. It is about opportunity, access and risk. A recent update from the Department for Education reminds us exactly why that matters.

From 1 September 2026, one of the biggest changes to regulated activity with children in recent years comes into force. The long-standing supervision exemption for volunteers is being removed, fundamentally changing how many organisations recruit, check and manage volunteers working with children.

For safeguarding leaders, this is much more than a DBS update, it is a governance issue.

What is changing?

Until now, many volunteers working with children were not considered to be carrying out regulated activity if they were supervised by someone already in regulated activity.

That changes from 1 September 2026.

If a volunteer is carrying out activities such as teaching, training, instructing, caring for or supervising children frequently, or meets the legal period condition (more than three days in a 30-day period or overnight), they will now be undertaking regulated activity regardless of supervision.

This means they will require:

An Enhanced DBS check with Children's Barred List information.
Appropriate safer recruitment processes.
Ongoing safeguarding oversight.

Importantly, DBS checks for volunteers remain free, removing what could otherwise have been a financial barrier.

Why this matters

Too often organisations unconsciously place volunteers into a lower-risk category.

After all...

"They're only helping out."
"They're supervised."
"They're giving up their own time."
But children do not experience risk based on whether someone receives a salary.
Risk comes from access.
The ability to build relationships.
The opportunity to groom.
The trust placed in an individual.

Some of the most trusted adults in a child's life may be volunteers, sports coaches, activity leaders, charity workers, faith group helpers, youth workers, reading volunteers or those supporting school trips. Safeguarding should never distinguish between paid and unpaid when considering the potential for harm.

This is about culture- not just compliance

While the legislation changes the legal definition of regulated activity, safeguarding organisations should already be asking wider questions.

Do we know exactly who our volunteers are?
Have we assessed every volunteer role against the new criteria?
Are recruitment processes consistent across paid staff and volunteers?
Do volunteers receive safeguarding training?
Do they know how to recognise abuse?
Would they know how to report a concern?
Are they included within safeguarding supervision, communications and learning?

A DBS certificate should never become the end of the conversation, it should be the beginning.

The governance challenge

For Designated Safeguarding Leads, safeguarding managers, trustees and boards, this change creates an opportunity to review systems rather than simply update paperwork.

Consider reviewing:

Volunteer role descriptions.
Recruitment and induction processes.
Single Central Records (where applicable).
DBS eligibility decisions.
Safeguarding policies.
Volunteer safeguarding training.
Risk assessments for supervised activities.
Governance reporting to boards and senior leaders.

Many organisations will need to identify volunteers who were previously outside regulated activity but will now require Children's Barred List checks before September. Planning early will avoid unnecessary disruption.

Safeguarding is everyone's responsibility

Legislation evolves because safeguarding evolves. Our understanding of abuse, exploitation and organisational risk continues to develop.

The removal of the supervision exemption reflects a simple reality: Children deserve the same protection regardless of whether the adult supporting them is employed or volunteering.

As safeguarding professionals, we should welcome any opportunity to strengthen safer recruitment and create safer environments because safeguarding has never been about ticking boxes, it has always been about preventing harm before it happens.

Need support?

At RLB, we support organisations across every sector with safer recruitment, safeguarding audits, governance reviews, accredited training and strategic safeguarding advice.

If your organisation relies on volunteers, now is the time to review your arrangements before September.

Resources

Regulated activity: removal of the supervision exemption (comes into force 1 September 2026)

Rachael Bishop