FR-11 Accepted in Part

Extend Disclosure Regime Overseas

IICSA · The Report of the Independent Inquiry into Child Sexual Abuse · Issued 20 October 2022 · Addressed to: UK Government

Source — verbatim from the inquiry

Inquiry recommendation, K.4

The Inquiry recommends (as originally stated in its Children Outside the United Kingdom Phase 2 Investigation Report, dated January 2020) that the UK government introduces legislation permitting the Disclosure and Barring Service to provide enhanced certificates with barred list checks to citizens and residents of England and Wales applying for: work or volunteering with UK-based organisations, where the recruitment decision is taken outside the UK; or work or volunteering with organisations based outside the UK, in each case where the work or volunteering would be a regulated activity if in England and Wales.

IICSA, The Report of the Independent Inquiry into Child Sexual Abuse · 20 Oct 2022 Source PDF →

Published evidence summary

Publicly available evidence relating to this recommendation:

- In January 2021, the Home Office stated that it would consider whether disclosure arrangements could be strengthened for those working with children overseas (Government Response, Home Office, January 2021).
- In May 2023, the government accepted this recommendation, stating it would review disclosure arrangements subject to the Bailey Review findings (Government Response to IICSA Final Report, HM Government, May 2023).
- No published legislation permitting the DBS to provide enhanced certificates for overseas work with children has been identified to March 2026.

Response — verbatim from government

UK Government

We accept the need to review whether disclosure arrangements can be further strengthened for those working with children overseas, and we will consider the scope of further strengthening the regime, taking into account the findings of the Bailey Review of the Disclosure and Barring Regime published in April 2023.

UK Government · 22 May 2023 Written response →

Evidence trail — what's actually happened since

  • 8 Apr 2025 Enabling overseas decision-makers to access DBS barred list data. Implementation expected by 2026. Source →
  • 21 Jan 2025 · Home Affairs Select Committee Professor Alexis Jay told Home Affairs Committee that £187m was spent on IICSA and "to date none of its final recommendations had been implemented." Called for "full implementation" saying "get it done." View source → No Meaningful Progress

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.