Safeguarding vulnerable groups is one of the important parts of a responsible and safer recruitment. For employers that shall comply with Scotland’s legal requirements, understanding the Protecting Vulnerable Groups (PVG) scheme helps ensure that the appropriate checks are carried out for regulated roles.
Recent changes introduced under the Disclosure (Scotland) Act 2020 have improved the Scotland’s disclosure and vetting framework. The historic system of “regulated work” has officially been replaced by a framework of regulated roles, alongside changes to PVG membership and disclosure processes.
For HR, compliance, and safeguarding professionals, keeping pace with these statutory requirements is a crucial part of supporting safe and compliant hiring practices. This guide outlines how recent legislative changes may impact onboarding and background screening programs, and highlights how screening strategies may be considered to support the screening program and recruitment practices.
In this article, we explore:
- What the PVG scheme check is: An overview of membership-based vetting in Scotland.
- PVG vs. basic disclosures: Understanding the differences in screening tiers.
- Who requires a PVG check: Identifying regulated roles across core business sectors.
- Recent legislative changes: Key structural updates under the Disclosure (Scotland) Act 2020.
- Continuous monitoring: How ongoing vetting may support the compliance program of your organisation.
- Employer responsibilities: Your statutory duties regarding vetting, digital sharing, and referrals.
- How to apply: A step-by-step application and verification process.
- Frequently asked questions: Clear answers to common employer compliance queries.
What is a Protecting Vulnerable Groups (PVG) check?
Managed by Disclosure Scotland, the Protecting Vulnerable Groups (PVG) scheme is a membership-based vetting system designed to help protect vulnerable individuals by preventing unsuitable individuals in certain roles. The scheme covers two vulnerable groups: children (individuals under 18) and protected adults (adults receiving specified care, health, or support services).
The PVG scheme supports ongoing safeguarding. As part of the application process, Disclosure Scotland conducts criminal record checks, including searches for both spent and unspent convictions, relevant non-conviction information held by the police, and checks whether the individual is included on the statutory barred lists.
One of the safeguarding objectives of the PVG scheme is to help ensure that anyone is barred from working with vulnerable individuals, do not undertake roles with such vulnerable groups. Once an individual becomes a PVG member, their membership is continuously monitored against relevant new police intelligence and judicial updates.
What is the difference between a basic criminal record check and a PVG Scheme Record?
The Scottish disclosure framework defines different levels of criminal record checks: level 1, level 2, level 2 with barred list check and Protection Vulnerable Groupe scheme. We will now address the two following levels of checks:
Level 1 (Basic Disclosure):
This check is available to anyone for any purpose and contains details of unspent criminal convictions only at the time the certificate is issued.
Level 2 (PVG scheme record):
This check is strictly limited to individuals entering regulated positions. It includes spent and unspent convictions, relevant police intelligence (non-conviction information deemed necessary by the police), a definitive check against the children’s or adults’ barred lists, and crucially, places the applicant under continuous ongoing monitoring.
The following comparison table highlights the functional and operational variances between these two levels:
| Screening attribute | Level 1 (Basic Disclosure) | PVG scheme record |
|---|---|---|
| Eligibility | Available for any role or purpose | Restricted solely to defined regulated roles |
| Conviction profile | Unspent convictions only | Spent and unspent convictions, plus police intelligence |
| Barred list cross-reference | No | Full check against children and/or protected adults lists |
| Monitoring lifespan | Static (accurate only on the date of certificate’s issue) | Continuous ongoing monitoring by Disclosure Scotland |
| Legal mandate | Optional/discretionary based on company policy | Mandatory requirement under Scottish law |
| Renewal framework | Requires full re-application at the employer’s discretion | Governed by a mandatory five-year membership cycle |
Who needs a PVG check?
Whether a PVG check is required depends on the roles meeting the legal criteria for a regulated role. Under the current legislation, a regulated role is defined by the specific activities an individual performs and the level of influence they hold, rather than simply the job title or place of work.
Regulated roles generally fall into two broad categories:
1. Regulated roles with children
This applies to positions involving individuals under 18 where normal duties include teaching, training, supervising, or being in sole charge of children. It can also encompass roles that provide advice, support, or guidance relating to a child’s physical or emotional well-being.
2. Regulated roles with protected adults
A protected adult is an individual aged 18 or over who receives certain health, community care, or welfare services due to different reasons (age, illness, disability, etc.). Roles providing personal care, medical treatment, or specialist support may fall directly into this category.
Core sectors and affected positions
The mandate for PVG screening spans multiple public and private sectors, including:
- Education: Teachers, early years practitioners, lecturers, and private tutors.
- Healthcare and social care: Doctors, registered nurses, care home assistants, and personal care assistants.
- Charities and voluntary organisations: Youth workers, community volunteers, and trustees of organisations whose primary purpose is serving vulnerable groups.
- Sport: Children’s football coaches, swimming instructors, and club welfare officers.
- Managers and supervisors: Individuals whose regular duties include the day-to-day management or direct supervision of people in regulated roles may also require PVG scheme membership.
Additionally, the scope of what qualifies as “incidental” contact has been significantly narrowed. If contact with vulnerable groups is planned, expected, and part of an organisations normal activities, even if it occurs infrequently, it may be considered as a regulated role.
Recent changes to the Disclosure (Scotland) Act
The implementation of the Disclosure (Scotland) Act 2020 introduced significant changes to Scotland’s disclosure and vetting framework including update to role classifications and PVG membership requirements. It may impact and transform employers’ compliance obligations.
The shift to regulated roles and mandatory status
On 1 April 2025, the definition of “regulated work” was formally replaced by “regulated roles”. Concurrently, joining the PVG scheme became a legal requirement for individuals carrying out the relevant positions. Following a three-month transitional grace period, the full statutory enforcement came into effect on 1 July 2025.
Under the revised framework:
- For employers: It is a criminal offence to recruit or appoint an individual into a regulated role without the appropriate membership and disclosure checks.
- For individuals: It is a criminal offence to perform a regulated role without PVG scheme membership where PVG membership is required.
- Age limits: Children under 16 are generally excluded from joining the PVG scheme. Individuals undertaking regulated activities are required to hold membership from the age of 16.
The five-year membership model
Furthermore, 1 April 2026 marked the end of the legacy “lifetime membership” model. All new individuals joining the PVG scheme from this date forward are automatically enrolled in a five-year membership linked to their specific regulated role.
Existing lifetime members will be transitioned to the new rolling five-year structure through a phased rollout managed by Disclosure Scotland. This helps the central vetting system remains up to date, reflecting individuals who are currently engaged in regulated roles practice across Scotland.
Continuous monitoring: Why the PVG scheme is different
When an individual becomes a certified member of the PVG scheme, Disclosure Scotland does not simply close the record after the initial check. Instead, the organisation maintains an ongoing link with Police Scotland and the wider UK criminal justice systems. If the relevant new information arises that may affect an individual’s suitability to work with vulnerable groups, Disclosure Scotland may carry out a formal review known as a consideration for listing.
[New Criminal Record/Intelligence]
│
▼
[Disclosure Scotland Review]
│
▼
[Automatic Employer Notification]
As an employer linked to that individual’s PVG membership, your organisation may be notified of the relevant status changes. This ongoing monitoring helps organisations to manage their screening requirements, support their safeguarding programs, and mitigate their risks.
Employer responsibilities under the PVG scheme
Operating within regulated environments requires organisations to meet specific safeguarding and recruitment obligations. Employers play a key role in helping safeguard vulnerable groups as per the Scottish framework.
How employers can apply for a PVG check
Navigating the application process efficiently requires an organised approach to help minimise delays and maintain data accuracy. Here are a couple of practices that your organisation may consider.
Step 1: Identify the regulated role
Review the job description, daily activities and responsibilities, and contact thresholds against Disclosure Scotland’s guidance and checklists to confirm whether the position meets the definition of a regulated role.
Step 2: Gather applicant information
Collect the required information from the candidate, including full legal names, historical name changes, address history, date of birth, and contact details.
Step 3: Complete identity verification
Before submitting an application to regulatory authorities, employers should consider conducting an identity check in accordance with the applicable requirements. For more context on these methodologies, see our comprehensive guide on Digital Identity and Right to Work in the UK: A Guide for Employers.
Step 4: Submit the application
Log into your designated online portal or software or application system to complete and submit the file digitally to Disclosure Scotland for processing.
Step 5: Disclosure Scotland review
Disclosure Scotland scans national criminal databases, local police intelligence files, and relevant statutory barred lists to assess the applicant’s suitability before producing the official disclosure record.
Step 6: Certificate review and onboarding
Once the digital disclosure has been processed, the applicant must share their official result with your organisation via the online portal. Review the disclosure information and confirm PVG membership before proceeding with the recruitment process, where appropriate.
Why use First Advantage for PVG checks?
Managing a high volume of background checks while adapting to changing legislation can place additional demands on HR teams. Partnering with a dedicated background screening provider may allow organisations to optimise their onboarding workflows while maintaining quality standards.
First Advantage provides trusted, enterprise-grade UK workforce screening services designed to support your regulatory requirements and screening program:
- Streamlined digital applications: Our integrated platform helps simplify Disclosure Scotland submissions by reducing manual administration steps.
- Integrated verification systems: We offer seamless digital identity verification solutions to help employers check candidate identities.
- Unified screening workflows: Manage your PVG checks alongside broader global requirements, including employment, reference, credit checks, and international criminal record checks through a single platform.
- Support for safeguarding obligations: Our solutions are designed to support disclosure and safeguarding requirements, helping your organisation manage their safeguarding screening requirements and make informed hiring decisions.
The Protecting Vulnerable Groups (PVG) scheme is Scotland’s mandatory safeguarding framework for regulated roles involving children and protected adults. It combines comprehensive disclosure checks with continuous monitoring to help employers support safer recruitment and meet their statutory obligations.
Key takeaways
- Mandatory Framework: PVG scheme membership is a legal requirement for individuals carrying out defined regulated roles in Scotland.
- Role-based assessment: Whether a PVG check is required depends on the activities and responsibilities of the role, rather than the job title alone.
- Ongoing monitoring: The PVG scheme provides continuous monitoring and proactive employer notifications, offering a higher level of long-term assurance than standard, single-snapshot checks.
- 5-year membership model: Lifetime membership has been replaced by a five-year membership cycle requiring regular renewals.
- Efficient processing: Using advanced digital screening solutions can help streamline hiring workflows while supporting disclosure requirements, helping employers meet compliance requirements and mitigate risks.
How First Advantage can support your PVG screening requirements
Discover how our tailored workforce solutions can support your organisation’s background screening needs and help you confidently navigate the modern compliance landscape.
Frequently asked questions
What is a PVG check?
A PVG check is a background screening process managed by Disclosure Scotland. It helps assess an individual’s suitability to work with children or protected adults by reviewing criminal records, and checking whether they are barred from carrying out regulated roles.
Who needs a PVG check in Scotland?
Any employee, volunteer, or contractor whose standard duties involve teaching, training, caring for, or directly supervising children (under 18) or protected adults requires a check. Managers and supervisors who oversee these individuals may also require PVG membership.
Is PVG membership now mandatory?
Yes. Following the implementation of the Disclosure (Scotland) Act 2020, holding active PVG membership is mandatory for all regulated roles listed by Disclosure Scotland.
What is a regulated role under the Disclosure (Scotland) Act?
A regulated role is any position (paid or voluntary) that involves specific care, oversight, or direct contact with vulnerable groups. Typically, this includes traditional health and education roles, as well as newer classifications like sports agents and non-clinical hospice staff.
How is a PVG check different from a Basic Disclosure?
A Basic Disclosure (Level 1) contains only unspent convictions and is accurate only on its date of issue. A Level 2 (PVG Scheme Record) includes spent convictions, non-conviction police intelligence, barred list checks, and continuous monitoring.
How long does PVG membership last?
Under the regulations introduced in April 2026, PVG scheme membership lasts for five years from the date of issuance or renewal, replacing the legacy lifetime model.
What happens if a PVG scheme member becomes unsuitable for regulated work?
If new convictions or relevant police intelligence arise, Disclosure Scotland may place the individual under a “consideration for listing” review. Linked employers may be notified, allowing organisations to take appropriate safeguarding action.
How can First Advantage help employers manage PVG checks?
First Advantage provides advanced workforce screening solutions that automate the application process, incorporate digital identity checks and track upcoming renewals, helping organisations meet their disclosure and safeguarding requirements.
Sources:
Protecting Vulnerable Groups (PVG) Scheme – mygov.scot | The Protecting Vulnerable Groups (PVG) Scheme – Citizens Advice Scotland | Disclosure (Scotland) Act FAQs – Disclosure Scotland | PVG Scheme Legal Requirements – Disclosure Scotland | Regulated Roles and the PVG Scheme – Disclosure Scotland
