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Disclosure Scotland, PVG and AccessNI Checks for Employers

Chris Jack · November 5, 2026
United KingdomCompliancePrivacy
Disclosure Scotland, PVG and AccessNI Checks for Employers

DBS checks cover England and Wales only. If someone will work for you in Scotland, the check comes from Disclosure Scotland. In Northern Ireland, it comes from AccessNI. Both have their own levels, fees and rules, and Scotland has changed a lot since April 2025.

This post covers what each scheme offers today, who can ask for which check, what it costs, how long you can rely on a result, what you can keep, and how to track it in WorkZerk. For England and Wales, see DBS checks for employers.

Scotland: what changed under the Disclosure Act

The Disclosure (Scotland) Act 2020 has come in over several dates. Disclosure Scotland's timeline of changes sets them out:

Date Change
1 April 2025 Basic, standard, enhanced and PVG disclosures replaced by Level 1 and Level 2. PVG membership becomes mandatory for regulated roles. New rules for disclosing childhood convictions, and a right to ask for a review of what is disclosed.
1 July 2025 The offence for an individual doing a regulated role without PVG membership, and the duty on organisations to remove them, come into force (SSI 2025/27)
1 April 2026 Lifetime PVG membership replaced by five-year membership

One part is still not in force: a power for Disclosure Scotland to impose conditions on a PVG member while it considers barring them. It was planned for late 2025, then postponed, and Disclosure Scotland says it will announce the date.

If you have old guidance that talks about basic or enhanced disclosures in Scotland, it is out of date.

The Scottish disclosure levels

There are now three disclosure levels and the PVG scheme (mygov.scot: types of disclosure). Fees are from Disclosure Scotland's fees page, in effect since 1 April 2025.

Check What it shows Who starts it Fee
Level 1 Unspent convictions The person £25
Level 2 Unspent convictions, certain spent convictions, and other information such as notification requirements The organisation £25
Level 2 with barred list check As Level 2, plus whether the person is barred from work with children or protected adults The organisation £25
PVG scheme membership As Level 2 with barred list check, and Disclosure Scotland keeps checking while they are a member The organisation £59 to join, £18 for someone already a member for that type of work

Level 1 is open to anyone, for any role. The person applies with a ScotAccount, and it usually takes up to 14 days (apply for Level 1).

Level 2 is only for specific roles, such as solicitors and prison workers. The organisation starts the application, the person completes it, and it usually takes up to 14 days (apply for Level 2).

Neither comes on paper. Disclosure Scotland emails the person a secure link, they view the disclosure first, and then they share it with you. For Level 2, they have 14 days to share it.

PVG membership for regulated roles

A regulated role usually involves work with children or protected adults, or a position of power or influence over them. Paid and unpaid roles both count. Disclosure Scotland publishes a list of regulated roles and a tool to check if a role needs PVG membership.

For these roles, membership is a legal requirement (mygov.scot: regulated roles). The organisation side is in the Protection of Vulnerable Groups (Scotland) Act 2007:

  • It is an offence to offer someone a regulated role unless you have received a Level 2 disclosure confirming they are a PVG member for that type of role (section 45D). An offer made subject to receiving that disclosure does not count.
  • If someone is already doing a regulated role without membership, you must not let them carry on and must remove them from it, unless they applied before the relevant date and the application is still open (SSI 2024/393, regulation 3).
  • It is an offence to offer a regulated role to someone barred from it (section 35).

So an existing member joining you still needs a new PVG disclosure, started by you. That is the £18 fee.

PVG membership is free for volunteers with qualifying voluntary organisations (fees page), and social care workers do not pay for a PVG application (apply to the PVG scheme). Self-employed people, personal assistants and people working for an individual can apply themselves.

Five-year PVG membership

Since 1 April 2026, PVG membership lasts five years and has to be renewed (how long PVG membership lasts). Anyone who applies after that date moves to five-year membership automatically. Existing lifetime members will be contacted by Disclosure Scotland and moved across. Renewal dates have not been published yet.

Disclosure Scotland says the change does not alter how organisations apply, and there is no extra cost for the five-year change or renewal (February 2026 update). Its notification emails show the date membership ends.

While someone is a member, Disclosure Scotland keeps checking their suitability. You still need to tell Disclosure Scotland when someone stops doing a regulated role for you.

Northern Ireland: AccessNI checks

AccessNI has three levels (nidirect: types of AccessNI checks). Fees and processing targets are from costs and turnaround times.

Check What it shows Who can apply Fee Processing target
Basic Unspent convictions Anyone, directly or through a responsible body £16 95% within 14 days direct, 99% within 7 days through a responsible body
Standard Spent and unspent convictions, informed warnings and other non-court disposals, with some old and minor ones filtered Through a registered body, for roles exempt from the Rehabilitation of Offenders (NI) Order 1978 £16 99% within 7 days
Enhanced As standard, plus relevant police information and, for regulated activity, barred list information Through a registered body, normally for roles with children or vulnerable adults £32 95% within 21 days

Standard and enhanced checks are free for volunteers giving their time to a non-profit organisation. They are charged if the person volunteers directly for a statutory organisation, or for a non-profit funded to pay for its volunteers' checks.

Certificates are digital. Each carries a watermark saying it is not valid if printed, so a printout is not proof (checking job applicants).

How long you can rely on a result

None of the three schemes puts an expiry date on a criminal record disclosure. The rules for reuse differ.

  • Scotland, Level 1 and Level 2: the disclosure shows what was known on the day. You set your own recheck period.
  • Scotland, PVG: membership now lasts five years, and Disclosure Scotland monitors members throughout. You still need a new PVG disclosure each time you offer someone a regulated role.
  • Northern Ireland: nidirect says certificates "are only accurate on the issue date" and that standard or enhanced certificates "should not be re-used", because each application is countersigned for a specific role. You decide whether to accept an earlier basic certificate. There is no AccessNI equivalent of the DBS Update Service on nidirect.

A DBS certificate from England or Wales does not replace an AccessNI check. nidirect says an employer can still ask for an AccessNI check from someone holding a DBS certificate.

Storing the details, not the certificate

Both schemes say the same thing about copies.

  • Disclosure Scotland: "You must not keep a photocopy or other image of the disclosure information." Keep information no longer than you need, and have a policy on retention, storage and secure destruction (code of practice: using disclosure information).
  • AccessNI: "Employers shouldn't take or keep photocopies of an applicant's certificate", and should not keep a certificate for longer than six months. If you need to keep one longer, you must tell AccessNI (employer obligations, AccessNI code of practice).

What you can keep is a record that you checked: the level, the disclosure number, the issue date, the PVG membership end date, who saw it and your decision. Criminal record information is also criminal offence data under Article 10 of the UK GDPR, so you need a condition from Schedule 1 of the Data Protection Act 2018 as well as a lawful basis.

This is general information, not legal advice. The Scottish rules are still being phased in, so check Disclosure Scotland or AccessNI before you rely on a detail, or ask a solicitor.

What WorkZerk does and doesn't do

  • Each person sends their disclosure details from a private link, with no account or password.
  • Fields and uploads marked Sensitive are stored encrypted, and only admins can see them.
  • You approve each one, and WorkZerk records who approved it and when.
  • WorkZerk emails the person before their PVG membership ends or their recheck date arrives.
  • The Document compliance report shows who is current, due or missing a check.
  • WorkZerk can delete an approved file a set number of days after you approve it, keeping the date and your approval.

What it does not do: WorkZerk does not apply for checks, act as a registered or responsible body, start PVG applications, or connect to Disclosure Scotland or AccessNI. It cannot see a disclosure someone shares from their online account, and it cannot tell you whether a disclosure is genuine. You view the disclosure where the scheme shares it, and WorkZerk keeps the record.

Setting it up in WorkZerk

1. Turn on two-factor authentication

Asking people to upload documents needs two-factor authentication on your account. Set it up first under Account, then Two-factor authentication (opens in WorkZerk in a new tab).

2. Create the fields

The Staff onboarding (United Kingdom) pack asks for a DBS certificate only. It has nothing for Scotland or Northern Ireland, so add your own. Open Fields (opens in WorkZerk in a new tab) and add:

  • PVG scheme membership, an Upload field. Switch on Require an expiry date and Sensitive. The expiry date is the day their membership ends.
  • Criminal record disclosure, an Upload field, for Level 1, Level 2 and AccessNI checks. Switch on Require an expiry date and Sensitive. There is no printed expiry date, so the expiry date here is your recheck date.
  • Disclosure level, a Text field: Level 1, Level 2, PVG, or AccessNI basic, standard or enhanced.
  • Disclosure number, a Text field, marked Sensitive.
  • Disclosure issued on, a Date field.

Switch off Use AI to check expiry date on both Upload fields, since the screenshot you ask for may not show a date. See custom contact fields and keeping sensitive information private.

3. Ask for it on a portal

Open Portals (opens in WorkZerk in a new tab), click New portal and add the Staff onboarding (United Kingdom) pack. See starter request packs. On the portal's Requests panel, click + Insert and add:

  1. An Upload request, "PVG scheme membership", with PVG scheme membership as its Document type and Require expiry on. In the description: "Upload a screenshot of your Disclosure Scotland account showing your name and the date your membership ends. Don't upload the disclosure itself. Share it with us from your account."
  2. An Upload request, "Criminal record disclosure", with Criminal record disclosure as its Document type and Require expiry on, for roles that need a Level 1, Level 2 or AccessNI check. Tell people which date to enter, for example three years after the issue date.
  3. A Fields request for Disclosure level, Disclosure number and Disclosure issued on.

If one portal covers people in different parts of the UK, add a Choice request asking where they will work, and use Show only when on each request so people only see the check that applies. Delete the pack's DBS certificate request on a portal for Scotland or Northern Ireland only.

4. View the disclosure, then approve

For a PVG role, start the application from your Disclosure Scotland account first. When the person shares the disclosure, view it there, or view the AccessNI certificate they share from nidirect. Then open their upload under Needs review on Requests (opens in WorkZerk in a new tab), check the name and dates match, and approve it. If the date is wrong, click Change date first. See reviewing uploads.

5. Delete the screenshot after you approve it

Open Profile (opens in WorkZerk in a new tab) and find Document retention. Under Delete approved files, pick 7 days after I approve them. WorkZerk deletes the file and keeps the expiry date, who sent it and your approval. The level, number and issue date stay in their own fields.

The setting covers every approved file with an expiry date in your account, from your next approval on. See deleting documents after you approve them.

6. Switch on the reminders

Open Automations (opens in WorkZerk in a new tab) and switch on Document expiring reminder and Document expired reminder. Both start switched off. The expiring reminder goes 30 days before the date by default. Change it to 60 days so a new check is back before the old date passes. See automations.

7. Check who is covered

Open Requests (opens in WorkZerk in a new tab) and click Document compliance. Each person shows as current, expiring, needs review, expired or missing for their PVG membership or disclosure. Use Download CSV when an inspector or funder asks for a register. See document compliance.

Getting started

Start a free WorkZerk trial at workzerk.com, then work through the steps above. If you get stuck, the getting started guide walks through a first portal end to end, or email us at [email protected].

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