Organisations urged to review PVG scheme compliance for regulated roles

Disclosure Scotland is encouraging organisations to review how they assess regulated roles and ensure that appropriate checks are in place before recruitment takes place.

The campaign follows the introduction of legal requirements under the Disclosure (Scotland) Act 2020, which made PVG scheme membership a legal requirement for people carrying out regulated roles with children, protected adults or both.

Since 1 July 2025, it has been a criminal offence for an individual to carry out a regulated role without PVG scheme membership. It is also a criminal offence for an organisation to offer a regulated role to someone who is not a member of the PVG scheme.

Many organisations are familiar with the requirement for front line workers to be members of the PVG scheme. However, some organisations may not realise that day-to-day supervisors and managers of people carrying out regulated roles may also require PVG scheme membership.

The campaign also highlights the importance of understanding legal referral duties. Organisations may have a legal duty to refer an individual to Disclosure Scotland where harmful behaviour results in removal from a regulated role. This duty can apply to both employees and volunteers and can continue even after an individual has left an organisation.

Supporting safer recruitment

The PVG scheme supports organisations by helping them make informed recruitment decisions through ongoing monitoring of PVG scheme members. However, Disclosure Scotland is reminding organisations that PVG scheme membership should form part of wider safeguarding and safer recruitment arrangements rather than replace them.

Organisations and individuals can access guidance, check whether a role is regulated and find information about referral duties and the Disclosure Scotland Code of Practice at disclosure.gov.scot.