Your role. Their safety. Regulated roles and the PVG scheme

From the 1 April 2025, a new law comes into force. Those individuals who are to carry out a regulated role with children, protected adults or both, must ensure they are a member of the Protecting Vulnerable Groups (PVG) scheme for that type of work, to ensure that they follow legal requirements. It is also a legal requirement for organisations to ensure that they receive confirmation of an individual’s membership of the PVG scheme ahead of them carrying out a regulated role.

Three-month grace period to join the PVG scheme

There will be a grace period of three months after the PVG scheme becomes a legal requirement from 1 April 2025. This will ensure individuals and organisations don't commit an offence if there are individuals who are not PVG scheme members but are currently working in regulated roles.

From 1 July 2025 onwards, it will become a criminal offence for:

individuals to carry out a regulated role if they are not a member of the PVG scheme

organisations to offer a regulated role to an individual who is not a member of the PVG scheme

Regulated roles

In addition to these changes to the PVG scheme, it is important that individuals and organisations are aware of the change from ‘regulated work’ to ‘regulated roles’ from 1 April 2025. In Scotland, a' regulated role' is a type of paid or unpaid position. When a role is regulated, it means that a person does certain activities when in contact with children and protected adults.

This might be:

roles which have caring duties
teaching or managing children or protected adults
providing personal assistance and dealing directly with children or protected adults

Contact might be supervised or unsupervised, depending on the activity. Some roles allow people to exert power and influence over children to the point that contact happens even when a 'responsible person' is present.

The PVG scheme safeguards vulnerable people by ensuring that those individuals doing regulated roles are suitable to do so. Examples of regulated roles are teachers, children’s football coaches, children’s tutors and support workers.

New regulated roles

From 1 April 2025, new regulated roles will be introduced. This means that individuals who carry out these roles need to be a member of the PVG scheme to comply with legal requirements.

Sports agents and talent agents will become regulated roles. Sports and talent agents which deal with children (under 18s) and represent children in future recruitment, training or employment with sports clubs or other organisations are regulated role activities. These roles possess significant power and influence over children, even if the contact occurs in the presence of a parent or responsible person.
Non-clinical health or hospice staff or volunteers who have unsupervised contact with patients will become regulated roles.

Children and regulated roles

The term 'child' or 'children' refers to persons who are below the age of 18 years. Schedule 2 of the Protection of Vulnerable Groups (Scotland) Act 2007 details the activities and circumstances where membership of the PVG scheme will be a legal requirement for working with children.

Protected adults and regulated roles

A Protected Adult is a person over the age of 18 who may:

by reason of physical or mental disability, illness, infirmity or ageing,

have an impaired ability to protect themself from physical or psychological harm, or requires assistance with the activities of daily living

be homeless, as is defined by section 24 of the Housing (Scotland) 1987 and is receiving counselling, therapy, advice, guidance or advocacy support in relation to health or wellbeing.
have experienced, is experiencing or is at risk of experiencing domestic abuse and is receiving counselling, therapy, advice, guidance or advocacy support in relation to health or wellbeing
receive a prescribed health service or a community care service

Schedule 3 of the Protection of Vulnerable Groups (Scotland) Act 2007 details the activities and circumstances where membership of the PVG scheme will be a legal requirement for working with protected adults.

Information