35 Not Accepted

Mandatory DBS for work with children overseas

IICSA · Children Outside the United Kingdom Phase 2 Investigation Report · Issued 30 January 2020 · Addressed to: Home Office

Source — verbatim from the inquiry

Inquiry recommendation, E

The Home Office should introduce legislation making it mandatory for: 1. all UK nationals and residents of England and Wales to provide a prospective employer overseas with an enhanced Disclosure and Barring Service certificate before undertaking work with children overseas which if in the UK would be a regulated activity; and 2. UK government departments and agencies to require their overseas partners to ensure that UK nationals and residents of England and Wales obtain an enhanced Disclosure and Barring Service certificate before undertaking work with children overseas which if in the UK would be a regulated activity.

IICSA, Children Outside the United Kingdom Phase 2 Investigation Report · 30 Jan 2020 Source PDF →

Published evidence summary

Publicly available evidence relating to this recommendation:

- In January 2021, the Home Office stated that although this recommendation envisaged placing the legal obligation on prospective employees, it continued to consider legislative options (Government Response, Home Office, January 2021).
- In May 2023, the government stated that it accepted this recommendation subject to feasibility assessment (Government Response to IICSA Final Report, HM Government, May 2023).
- No published legislation making it mandatory for UK nationals to provide an enhanced DBS certificate for overseas work with children has been identified to March 2026.

Response — verbatim from government

UK Government

On 21 January 2021, the Home Office stated that although part 1 of this recommendation envisaged placing the legal obligation of providing overseas employers with an enhanced Disclosure and Barring Service certificate on UK nationals, it would in effect amount to the UK government legislating in respect of employment practices in foreign countries. The Home Office stated that it did not consider this approach to be effective, and stated that it would continue to publicise the existence of the International Child Protection Certificate. Regarding part 2 of this recommendation, the Home Office stated that it recognised the need for government bodies to take reasonable steps to ensure that overseas partners have robust safeguarding policies, and that those partners carry out all appropriate criminal records checks along with broader recruitment checks such as references. It stated that the Foreign, Commonwealth and Development Office is working to strengthen the employment cycle across the aid sector. This aims to prevent individuals with a known history of misconduct from working in the sector, regardless of their nationality. On 17 June 2021, the UK government stated that its position had not changed in relation to this recommendation. On 17 December 2021, the UK government stated that the Foreign, Commonwealth and Development Office had set up a working group with the Home Office, Disclosure and Barring Service, ACRO and the Charity Commission to look at the issue of criminal record checks for the international aid sector.

UK Government · 22 May 2023 Written response →

Evidence trail — what's actually happened since

No published activity has been recorded against this recommendation yet.

Each entry above links to a primary source — gov.uk written statement, consultation response document, or inspection report. The Index does not characterise government intent; it tracks what has been published.

How this page is built

Source and Response are verbatim from primary documents. The Evidence trail records published activity since — written statements, consultation outcomes, inspection findings, parliamentary references. The Index does not paraphrase or characterise intent; it tracks what has been published. Where the evidence is the absence of action (a missed deadline, a slipped timetable), that absence is documented from primary sources rather than inferred.

This recommendation's data is verified periodically against primary sources. The Index is monitored for staleness weekly.