DBS certificates for overseas work
IICSA · Children Outside the United Kingdom Phase 2 Investigation Report · Issued 9 January 2020 · Addressed to: Home Office
Government responseHome Office: Not accepted (Jan 2021)
DeliveryHome Office says not accepted (Jan 2021)
Recommendation, verbatim from the inquiry
●Inquiry recommendation, E
The Home Office should introduce legislation permitting the Disclosure and Barring Service to provide enhanced certificates to UK nationals and residents of England and Wales applying for: 1. work or volunteering with UK-based organisations, where the recruitment decision is taken outside the UK; or 2. work or volunteering with organisations based outside the UK, in each case where the work or volunteering would be a regulated activity if in the UK.
IICSA, Children Outside the United Kingdom Phase 2 Investigation Report · 9 Jan 2020 Source PDF →
Published evidence summary
AI-generated evidence summary
The Inquiry recommended legislation permitting Disclosure and Barring Service (DBS) enhanced certificates for overseas work. In January 2021, HM Government stated that it was "not persuaded" that replacing the International Child Protection Certificate (ICPC) with enhanced certificates would make accessing criminal records more effective for overseas employers (Home Office response, Jan 2021; Home Office, Jan 2021). In April 2023, Simon Bailey CBE QPM reported in the Independent Review of the Disclosure and Barring Regime that he found no reason to depart from the government's response, but expected it to review the matter (Simon Bailey CBE, QPM, Apr 2023).
AI-generated summary of the record on this page, checked by a second model and automatic checks, 5 Oct 2026.
Government response
●Home Office · Not accepted · 21 Jan 2021
11. The Government shares the Inquiry’s concerns that effective protections should be in place for children abroad. Criminal record checks are an important part of these protections and the Government wants to ensure that overseas employers are able to access the information that they need when recruiting UK residents to work with children. 12. Under current arrangements, individuals applying to work in a school or organisation outside the UK where they will be in regular contact with children can apply for an International Child Protection Certificate (ICPC). This is produced by ACRO Criminal Records Office (a national policing unit which provides criminal records information services to policing bodies and individuals) in conjunction with the National Crime Agency (NCA). The ICPC details the individual’s criminal record history in the UK and any relevant information or intelligence on police databases which the NCA deems appropriate for disclosure. 13. The Government has considered carefully the Inquiry’s recommendation which for overseas employers would replace the ICPC with the Enhanced Certificate currently issued by the Disclosure and Barring Service in England and Wales in respect of regulated activity. While the Government agrees with the Inquiry that overseas employers should be able to access criminal records information as effectively and straightforwardly as possible, it is not persuaded that this would be the effect of this recommendation.
Delivery
●Home Office says not accepted · 21 Jan 2021
The Government has considered carefully the Inquiry’s recommendation which for overseas employers would replace the ICPC with the Enhanced Certificate currently issued by the Disclosure and Barring Service in England and Wales in respect of regulated activity. While the Government agrees with the Inquiry that overseas employers should be able to access criminal records information as effectively and straightforwardly as possible, it is not persuaded that this would be the effect of this recommendation.
What other bodies have found
●Independent Review of the Disclosure and Barring Regime · 18 Apr 2023
32. I have not found any reasons to recommend departure from the Government’s detailed response to the original recommendation 3 in relation to recruitment decisions taken outside the UK, which was repeated in the final report. However, having regard to the fact that IICSA repeated it, I would expect the Government to review the matter.
From: Independent Review of the Disclosure and Barring Regime (accessible), Simon Bailey CBE, QPM, Independent reviewer
●Independent Inquiry into Child Sexual Abuse · 20 Oct 2022
52. In its Children Outside the UK Phase 2 Investigation Report, the Inquiry recommended that the geographical reach of the DBS be extended. In its response, the Home Office indicated that it considered that the information provided on an ICPC was broadly similar to that on an enhanced certificate. The absence of barred list information on the ICPC creates a significant risk to the safety of children in the UK and abroad. The Inquiry therefore reiterates its recommendation that the disclosure and barring regime should be extended to those working with children overseas.
From: The Report of the Independent Inquiry into Child Sexual Abuse, Part K and annexes (accessible)
Earlier findings (3)
●Independent Inquiry into Child Sexual Abuse · 20 Oct 2022
51. DBS checks on citizens or residents of England and Wales cannot be accessed by employers based overseas. The non-statutory International Child Protection Certificate (ICPC), which some overseas organisations choose to utilise, does not include access to the DBS children’s barred list. These territorial limitations on the DBS disclosure regime facilitate predatory offenders from England and Wales obtaining employment working with children overseas.
From: The Report of the Independent Inquiry into Child Sexual Abuse, Part K and annexes (accessible)
●Independent Inquiry into Child Sexual Abuse · 28 Apr 2022
On 17 June 2021, the UK government stated that its position had not changed in relation to this recommendation. On 17 December 2021, the Home Office stated that the Foreign, Commonwealth and Development Office has set up a working group with the Home Office, Disclosure and Barring Service (DBS), ACRO and the Charity Commission to look at the issue of criminal record checks for the international aid sector.
●Independent Inquiry into Child Sexual Abuse · 28 Apr 2022
In addition, the Home Office announced a review of the DBS regime whose terms of reference will include issues raised by the Inquiry.
How this page is built
The recommendation and the government responses are verbatim from primary documents. Delivery statements and other bodies' findings are shown in their own words, each with its source. The summary is written by this site and labelled as such. The Index does not paraphrase sources or characterise intent; it records what has been published.