Disclosure Scotland newsletter - December 2025

Disclosure Scotland wrapped - Your year in safeguarding 2025

Another year comes to a close, and what a year it has been. Here's to everything we have achieved this year. Our first Disclosure Scotland wrapped highlights our performance, and tells the story of the impact we have had in shaping a safer Scotland. You can read the text version and download the PDF on our website.

Disclosure Act update – December

From 1 April 2026, individuals who join the Protecting Vulnerable Groups (PVG) scheme will automatically be part of the five-year PVG scheme membership.

Every five years, renewal will be required. Organisations should continue to submit PVG scheme applications as normal, including payment of any fees when you apply for disclosures, not as a fee for PVG scheme membership. You should not change how often or when you apply for the PVG scheme.

We are working with stakeholders to understand the requirements for this transition. We will tell you more about this as soon as possible. 

I am a PVG scheme member, what can I do now?

Many PVG scheme members will not need to do anything ahead of the move to the five-year scheme.

If you are a PVG scheme member who has not recently applied for PVG (for example, you haven’t applied since PVG moved online in 2021), it’s important that you tell us your current email address. We need this so that we can get in touch with you easily in the future to tell you when you are moving to the five-year scheme and how to create your online account.

Please email dsupdate@disclosurescotland.gov.scot with the subject header ‘Email address update’, your:

• name
• date of birth
• PVG scheme number
• current email address

What can organisations can do?

We are also supporting organisations to ensure that the data on PVG scheme members is accurate and up to date as part of preparing for the transition. We may be in touch with your lead signatory about this soon.

You should notify us when a PVG scheme member stops carrying out a regulated role for you. This will reduce unnecessary admin, ensures you only receive updates you are entitled to, and will prevent you from receiving notifications relating to five-year PVG scheme renewal or transition.

Assessing eligibility for disclosure

Determining the correct level of disclosure is the responsibility of the organisation countersigning the application.

To assist organisations making the decision, we provide comprehensive guidance on our website, including a ‘regulated roles tool’, to support decision-making. You can also access:

• regulated roles training – upcoming dates are listed on our events page
• a pre-recorded webinar available on our YouTube channel

If we identify any cases where the level of disclosure appears incorrect, we will work directly with the organisation to resolve the issue promptly.

Guidance

Our resources page has a range of guidance to help you understand your legal obligations and how to use our services.

We have added new guidance for local authorities to help you assess when members of council committees require PVG scheme membership.

Key updates within our written regulated roles guidance include an explanation of the meaning of ‘necessary part of the role’ to help you with your assessment of whether a role is a regulated one.

Our guidance for health services, parent run groups and sports organisations has also been updated.

We regularly review our guidance to ensure that it meets our customer needs. Please ensure that you always refer to the latest version on our website.

If you have any feedback on our guidance resources, please contact our Customer Engagement Team (customerengagement@disclosurescotland.gov.scot).

Accredited body invoices and payments

Please pay your monthly and annual invoices in line with our payment terms and conditions. These are sent to you along with our invoice. Please make sure that you pay the full amount you have been billed for.

When making payments, can you please send a remittance advice that is associated with that payment.

Can all countersignatories and employers ensure applicants complete their application within their ScotAccount and not select ‘Begin new application’. This causes unnecessary delays for the applicant and additional work for Disclosure Scotland.

A year of transformation - Safeguarding Scotland together

As we look back on 2025, it’s clear that the year’s achievements were built on years of steady reform - delivering one of the most significant shifts in safeguarding Scotland has ever seen. Read the full article on our website.