Updates to DBS ID Checking

Updates to DBS ID checking

In April 2025 and October 2025, DBS published new guidance on ID verification checks for the purposes of DBS applications. The guidance took effect on 1^st November 2025.

The guidance published in April provided the following options for ID verification:

Option 1 - a physical check of the relevant original documents with the candidate physically present; or

Option 2 - requiring the employer to be in physical possession of the relevant original documents (they need to have been sent to you by post or secure courier service for example) with the candidate on a live video link such as Facetime. You must make a record of the document details and note that the physical documents were checked but that the applicant was seen over video link.

Option 3 - The ID check can be completed via video link – for example Google Meet or FaceTime – without you being in physical possession of the ID documents. The documents can either be held up to the camera during the video link or sent as a scanned image/photograph via email. The details of the documents must be recorded and stored at the time of the video link ID check, the relevant original documents must subsequently be presented to you prior to an assignment starting and in exceptional circumstances this can be done on the first day of the assignment. 

Option 1 is the default for ID checking. If you use Option 2 you must record the reason why you did not use Option 1. If you use Option 3, you must record the reason why you did not use either options 1 or 2. The reasons for electing one option over the other available options must be relevant to the individual circumstances of the ID verification. You cannot have a blanket rule providing that your business will not conduct manual checks.

Additional DBS Digital Identity Verification Guidance issued on 6^th October 2025 provides that where digital ID checks are conducted, this satisfies the requirements of the above guidance published in April 2025.

“A digital identity provided by a digital verification service certified against the trust framework and the DBS supplementary code is equivalent to an identity verified using:

• ID checking guidelines for Standard/Enhanced DBS check applications from 22 April 2025 - GOV.UK
• Basic check ID checking guidelines from 22 April 2025 - GOV.UK”

Once an output from a Digital Verification service has been provided, DBS states that it should be retained for a minimum of two years and employers should “maintain an audit trail showing details of each application submitted, including the data from the DVS, which must be kept for a minimum of 2 years and made available to the DBS if requested.”

This essentially means that the ID checking guidelines are satisfied if employers conduct Digital ID verification checks on candidates and retain evidence of the application for the digital verification and the output for a minimum of two years.

It important to note that the updated guidance relates to ID checking for the purpose of a DBS application only and is separate from ID checking requirements under Government Supplier frameworks and the Conduct Regulations.

For advice on specific enquiries, please get in touch with the REC legal team.