A barred list check through DBS Adult First: what it tells you before the certificate arrives

A home care agency has a new care worker due on Monday's rota and nobody else free to cover her calls. Her application for an Enhanced check with the Disclosure and Barring Service went in on Wednesday. On Friday the DBS Adult First reply arrives: "no match exists for this person on the current Adults' Barred List" [1]. That reply is the result of a barred list check, and it lets the registered manager consider starting her before the certificate comes back. This guide covers England, where the Care Quality Commission and Skills for Care guidance quoted here applies. It does not cover Wales.

A barred list check through DBS Adult First answers one question

DBS's employer guidance says: "Depending on the result, a person can be permitted to start work, under supervision, with vulnerable adults before a DBS certificate has been obtained." [1]

The reply takes one of two forms: "Registered Body must wait for the DBS certificate", or "no match exists for this person on the current Adults' Barred List" [1]. For a wait reply, DBS says the details provided "may have indicated a match", and that "further investigation is required to confirm this and you should await the certificate" [1].

A no match reply settles whether the person was on the Adults' Barred List when DBS looked. The Enhanced certificate also carries Police National Computer information and a check of information held by police forces [1], and the Adult First reply contains none of that.

Skills for Care's guidance, dated January 2024, adds that "Many people who may pose a risk of harm to adults at risk are not included on the adults' barred list", and that the check "cannot generally access barring information or criminal records held overseas" [2]. Barring decisions can also take DBS a long time, and "unless/until a person is barred, they may still apply for roles engaging in regulated activity" [2].

DBS Adult First is for eligible adult roles, and for exceptional cases

DBS sets three criteria: the position must require a criminal record check by law, it must be eligible for access to the Adults' Barred List, and the organisation must have asked for a barred list check on the DBS application form [1]. Care workers giving personal care to adults can be asked for an Enhanced DBS check with an Adults' Barred List check, whether they work in the person's own home, a care home or another setting [3].

Not every care home role qualifies. DBS says cleaning, administration and maintenance staff with regular contact with residents, but no regulated activity, can be eligible for "an Enhanced DBS check without an Adults' Barred List check" [3]. With no barred list check on the application, DBS Adult First is closed to them.

DBS's terms of use say a check "is not appropriate where a person intends to work with both children and adults", because "There is no equivalent quick check of the children's barred list." They add that "DBS Adult First checks should be used only in exceptional circumstances and when absolutely necessary." [4]

CQC covers Adult First in two documents. Its Regulation 19 FAQ, dated June 2018 and linked from CQC's current Regulation 19 page, says Adult First checks "should not be relied upon routinely", and that "Providers must be able to demonstrate sound reasons for not obtaining a full DBS check before a person takes up post, and also demonstrate they have assessed any potential risk." [5]

CQC's DBS checks guidance, version 7, dated October 2019 on its cover, gives the detail. The file is still on CQC's website, though no current CQC web page could be found that links to it. It says an Adult First start "should only happen if the safety of people using the service would be put at risk if the person wasn't started in their role" [6].

What a DBS Adult First check costs, and how long the certificate takes without it

DBS check fees changed on 5 October 2026 [7]. The DBS employer guidance updated that day lists an Enhanced with Barred List(s) check at £41 and a DBS Adult First check at £6 [1]. The fee announcement itself does not mention Adult First. GOV.UK says the service "costs an extra £6" and gives its answer "usually within 2 days" [8]. Registered bodies and responsible organisations may add an administration fee, which "DBS is not involved in setting or regulating" [7], so quoted prices vary.

DBS's annual report for 2025 to 2026 gives an average of 12.4 calendar days to issue an Enhanced check, with 75% issued within 14 days against an 80% target [9]. CQC's 2019 test is whether people's safety would be put at risk if the person did not start, and that average is the wait to set it against [6]. See where the time goes in an adult social care hire for the rest of the timeline.

The report's accounts record 104 thousand Adult First applications in 2025-26, against 3,301 thousand paid Enhanced applications, a total that includes roles not eligible for Adult First [9]. Adult First also cost DBS more than it brought in: income of £626 thousand against costs of £830 thousand, a 75% recovery, and a notional cost of £7.98 per application against the £6 fee [9].

Supervision on an Adult First start looks different in home care

DBS says a person can start "under supervision" and does not define the term [1]. CQC's 2019 guidance expects an appropriately qualified and experienced member of staff to be appointed to supervise: "Wherever it is possible, this supervisor is on duty at the same time as the new worker, or is available to be consulted". New workers do not escort people away from the premises unless a colleague whose full and satisfactory DBS certificate has been received goes with them [6].

For a domiciliary care agency, the guidance adds contact with people using the service, or their representative, "at weekly intervals" to monitor their satisfaction with the new worker. They should be told about the outstanding information and when it arrives, and the worker's contact with them should end if the registered person considers it unsatisfactory [6]. The same section then says: "There is no requirement for the staff member to be directly supervised provided they have completed their induction." [6] That line is written for domiciliary care agencies.

No source read for this guide defines what supervision has to consist of, or limits how long someone may work on an Adult First result; the end point the sources imply is the certificate arriving.

The record that shows why someone started early and how the risk was managed

None of the guidance quoted here uses the phrase "supervision record" or prescribes a form for an Adult First start. The record a provider needs is the one that shows what CQC says it expects: sound reasons [5], a risk assessment [5], the safeguards in place [6] and the certificate once it arrives [6]. Skills for Care adds that the worker must be told the appointment stays conditional until then [2].

Those reasons carry weight because CQC's Regulation 19 guidance says: "Information about candidates set out in Schedule 3 of the regulations must be confirmed before they are employed." [10] Schedule 3 includes the Enhanced certificate and, where applicable, barring information [11]. CQC's 2018 FAQ says inspectors "will expect to see that the provider is keeping a record of the information obtained (including whether barred list information was received)" [5]. Skills for Care says providers "won't be penalised" for Adult First checks that meet the criteria where they can show the risks were "mitigated and managed effectively" [2].

Regulation 19 also covers agency and bank staff [10]. The sources read for this guide do not say whether the agency or the provider requests the Adult First check for a supplied worker, or which of them keeps the record, so settle that before the first shift.

The list below is assembled from the sources in this guide. It is not a CQC form, and what a CQC assessment asks you to produce covers the wider evidence.

• The reasons for not waiting, and the risk assessment [5].
• The Adult First reply and its date [5].
• The named supervisor, and who went with the worker on any trip away from the premises [6].
• For home care, the weekly contacts with people using the service, and when they were told about the outstanding information [6].
• How the worker was told that the appointment stays conditional until the full Enhanced certificate has been received [2].
• A marker on the staff record, such as Skills for Care's suggested code "DBS ADULT FIRST", for "future safeguarding audits" [2].
• When the certificate is seen: its date of issue, the type of check, whether the adults' barred list was checked and the outcome, the unique reference number and the employment decision taken [6].

Seeing which DBS requirements are still waiting on the Enhanced certificate

Credentially, the healthcare onboarding and compliance platform, matches each uploaded document to the requirement it satisfies, including DBS and Right to Work, as part of its pre-employment checks. Requirements are built around the role and site, and your team can see what is complete and what is missing for each person, including a DBS requirement still waiting on the Enhanced certificate. Decisions that need a person come back to your team.

To test this against your next conditional start, book a demo ahead of that barred list check and see what is complete and what is missing for a care worker, DBS included.

Frequently asked questions

Can a care worker start work before their Enhanced DBS certificate arrives?

Yes, in England, under supervision, if the role is eligible for an Adults' Barred List check and a DBS Adult First check finds no match. DBS's terms say Adult First should be used "only in exceptional circumstances and when absolutely necessary". CQC expects sound reasons and a risk assessment, and Skills for Care says the appointment stays conditional until the certificate arrives.

What does a DBS Adult First check tell an employer?

It is a barred list check of the Adults' Barred List only. The reply says either that no match exists or that the registered body must wait for the certificate, and a wait reply does not confirm the person is barred. It carries no police information, and it cannot generally access barring information or criminal records held overseas.

How much does a DBS Adult First check cost and how long does it take?

On the DBS employer guidance updated 5 October 2026, a DBS Adult First check costs £6, on top of £41 for an Enhanced with Barred List(s) check. GOV.UK says the result comes usually within 2 days. Registered bodies may add their own administration fee, which DBS does not set or regulate.

What supervision does CQC expect while the DBS certificate is outstanding?

CQC's DBS checks guidance, dated October 2019 and still published, expects an appropriately qualified and experienced supervisor, on duty at the same time where possible or available to be consulted. In domiciliary care it adds weekly contact with people using the service, and says direct supervision is not required after induction.

References

1. Disclosure and Barring Service, "DBS checks guidance for employers, voluntary organisations and third parties", GOV.UK, last updated 5 October 2026. https://www.gov.uk/guidance/dbs-check-requests-guidance-for-employers
2. Skills for Care, "Disclosure and Barring Service (DBS) Adult First check", costs stated correct as of January 2024. https://www.skillsforcare.org.uk/resources/documents/Recruitment-support/Recruitment-planning/DBS-adult-first-check.pdf
3. Disclosure and Barring Service, "DBS checks for adult social care roles", GOV.UK, last updated 17 September 2026. https://www.gov.uk/government/publications/dbs-guidance-leaflets/dbs-checks-for-adult-social-care-roles
4. Disclosure and Barring Service, "DBS Adult First Terms of Use", no date shown, read 11 November 2026. https://www.isaadultfirst.co.uk/guidance.aspx
5. Care Quality Commission, "Meeting our requirements of employment for Regulation 19: frequently asked questions", version 1.03, June 2018. https://www.cqc.org.uk/system/files/fid2932547-employment-requirements-regulation-19.pdf
6. Care Quality Commission, "Disclosure and Barring Service (DBS) checks (formerly criminal record (CRB) and barring checks)", version 7, cover dated October 2019, file dated 13 November 2019, read 11 November 2026. https://www.cqc.org.uk/sites/default/files/20191113_Disclosure_and_Barring_Service_DBS_checks_guidance_v7.pdf
7. Disclosure and Barring Service, "DBS reduces fees for checks and Update Service from 5 October 2026", GOV.UK news story, 9 September 2026. https://www.gov.uk/government/news/dbs-reduces-fees-for-checks-and-update-service-from-5-october-2026
8. GOV.UK, "Check someone's criminal record: Get a standard or enhanced DBS check for an employee or volunteer", read 11 November 2026. https://www.gov.uk/dbs-check-applicant-criminal-record/get-a-standard-or-enhanced-dbs-check-for-an-employee-or-volunteer
9. Disclosure and Barring Service, "DBS annual report and accounts: 2025 to 2026", 16 July 2026. https://assets.publishing.service.gov.uk/media/6a58bbf931fb6daf3141383f/ARA_2025-2026.pdf
10. Care Quality Commission, "Regulation 19: Fit and proper persons employed", page last updated 16 May 2025. https://www.cqc.org.uk/guidance-regulation/providers/regulations-service-providers-and-managers/health-social-care-act/regulation-19
11. Health and Social Care Act 2008 (Regulated Activities) Regulations 2014, Schedule 3, legislation.gov.uk. https://www.legislation.gov.uk/uksi/2014/2936/schedule/3