Disclosure Act update - October 2025

Most of the Disclosure Act was implemented on 1 April 2025. There is more information on the changes that came into effect on 1 April on our website. 

Looking ahead, from 1 April 2026, anyone who joins the Protecting Vulnerable Groups (PVG) scheme will be enrolled in a five-year membership for the type of regulated role they have joined for, replacing the current lifetime membership model.

We are also making a change from April 2026 to move existing PVG scheme members over smoothly and fairly to the five-year membership.

Important information

• Five-year membership: From 1 April 2026 PVG scheme membership will last for five years from the date scheme members join. Every five years, renewal will be required.
• Separate renewal process: Renewing your PVG scheme membership will not be the same as applying for a disclosure, these processes will be handled separately.
• Online Account:  Renewals will be primarily made through your online account, with an offline process in place for anyone who is unable to use our digital service.
• No change to current application process: Continue to submit PVG scheme applications as normal, including payment of any fees associated with your applications. You should not change how often or when you apply for the PVG scheme when the five-year membership starts or in preparation for this change.
• Organisation notifications: We will notify interested parties (for example, the employer) when an individual's PVG scheme membership is due for renewal. We will notify interested parties of upcoming renewal at least three months in advance of the renewal date.

Moving over to the five-year PVG scheme membership

On 1 April 2026, the PVG scheme will move to a five-year membership. Not all existing PVG scheme members will move to the five-year membership on 1 April 2026. We expect this to happen in phases. We are working with stakeholders to understand the requirements for this transition.

We will tell you more about transitional arrangements as soon as possible.

What can you do now?

To prepare for the five-year membership organisations should:

• notify Disclosure Scotland, when a PVG scheme member stops carrying out a regulated role with them. This helps reduce unnecessary admin and ensures you do not receive updates you are no longer entitled to. Please email dsupdate@disclosurescotland.gov.scot with the individual’s name, date of birth and PVG scheme number

• encourage your staff and volunteers to tell Disclosure Scotland when they no longer require their PVG scheme membership.

• keep records up to date - if you are unsure which PVG scheme members you are linked with, we can provide your organisation with a record of PVG scheme members that your organisation is linked to. Please request this by contacting our dedicated team at dsupdate@disclosurescotland.gov.scot and provide your countersignatory and accredited body codes in your request. 

Please note:

•  Your email must include all relevant information to allow us to action your request. If you do not include this information, we will need to contact you preventing us from actioning your request promptly.
• We are currently unable to produce lists for organisations who are not accredited bodies with Disclosure Scotland.

What you need to do if you are currently a PVG scheme member?

If you are a PVG scheme member who is currently or intends to carry out a regulated role, you do not need to do anything before 1 April 2026.  You still need to tell Disclosure Scotland if your personal details have changed. This will ensure that we hold accurate address and contact information for you. For information on how to update your PVG details, timescales and legal requirements please visit our website. 

Feedback

We intend to provide you with regular updates in the lead up to the commencement of the five-year PVG scheme membership. Please let us know what you would like to see in future updates by contacting our Communications Team directly via email (dswebteam@disclosurescotland.gov.scot).