Overseas police check for health and care recruits: what to ask for and what to record

A nurse who has lived in the UK for three years applies to your staff bank with a clear enhanced certificate from the Disclosure and Barring Service. In 2024 she spent eight months working in another country. She is an invented example, and her DBS certificate may not cover those eight months because, in the service's own words, "DBS is unable to access criminal records held overseas" [1].

Whether you ask her for an overseas police check depends on the threshold you apply: eight months abroad clears the six months NHS Employers suggests and falls short of the 12 months the visa rule uses [2][3]. This guide is written for employers in England, because the NHS criminal record checks standard it draws on covers England only [2].

A DBS check cannot see most overseas criminal records

A small number of overseas records are held on the Police National Computer and would appear on a DBS check [1]. For the rest, DBS guidance tells employers: "You should try to obtain a certificate of good conduct, and any other references, from potential overseas employees" [1]. It adds: "The standard of foreign police checks varies" [1].

DBS has no part in the application to the overseas authority, and it points employers to the embassy or High Commission of the country concerned [1].

An overseas police check sits alongside the DBS check. The NHS standard states: "In addition to any overseas police check, the Home Office recommends that employers should obtain a DBS check" [2]. Its reason is that a recruit from abroad may have lived in the UK before, "whether they declare it or not" [2].

The visa rule and the NHS suggestion set different look-backs for an overseas police check

The Home Office says there are "some statutory requirements for employers to carry out such checks in the health and education sectors" [3]. It does not name the statute, and no other source cited here does.

The first look-back is a visa rule for recruits applying for entry clearance in listed health, care and education occupations [3]. On the Health and Care Worker visa, the certificate is needed when applying from outside the UK, with four occupation codes excepted [4]. On the Skilled Worker route, the sponsor tells the recruit whether a certificate is needed when the certificate of sponsorship is issued [3], and NHS Employers recommends raising it "as early in the recruitment process as possible" [2].

The visa rule also limits the certificate's age. For the latest country of residence, the caseworker guidance from UK Visas and Immigration, known as UKVI, accepts a certificate issued no earlier than 6 months before the date of application [5].

The second look-back is a suggestion in the NHS standard for applicants already living in the UK. Employers should consider whether an overseas police check is needed where an applicant declares a significant period overseas in the last five years, and NHS Employers adds: "We suggest that a significant period should be considered as any period of six months or more (whether continuously or in total) within the last five years" [2].

Neither source reconciles the two, and neither says which applies to a sponsored recruit once in post.

Care workers recruited inside the UK since July 2025

Entry clearance for care workers and senior care workers closed on 22 July 2025, and switching from other visa routes inside the UK continues until 22 July 2028 [6]. Recruiting care staff after the overseas route closed covers the closure itself.

The visa certificate rule applies to entry clearance, and the Home Office adds that people already in the UK seeking to extend their stay "are not presently included" [3]. Taken with the closure, that means a care worker recruited from inside the UK since 22 July 2025 has had no overseas certificate checked by UKVI on their current application, so any overseas police check for that recruitment is your own. No source states this in those terms; it is an inference from the two facts above. The Home Office employer guidance still lists care workers (6135) and senior care workers (6136) among the occupations the visa rule covers [3], although entry clearance in those codes has closed [6].

A certificate of good conduct counts when a police authority issues it

The NHS standard says overseas police checks must follow the issuing country's justice system, and that some police authorities issue only a certificate of good conduct or standing. On those it is direct: "Any such certificates issued by a police authority are valid and can be accepted" [2].

A certificate of good standing from an overseas regulator is a different document. NHS Employers says it "is not equivalent to a police check", though it may still inform the overall assessment of suitability [2]. If a recruit offers one, it can sit on file as supporting evidence while the overseas police check remains outstanding.

Any overseas police certificate should be "verified in the exact same way as all other official documentary evidence" [2]. For the visa, the Home Office accepts a photocopy or scan, and NHS Employers says employers should tell the applicant they will need to present the original "for employment checking purposes" [2][5]. For the recruit, that means keeping the original safe after a visa application where a scan was enough, and bringing it to your document check.

A translated copy is needed where the certificate is not in English [2][5]. DBS asks for a "certified translation" without defining the term, and the guidance cited here does not say who may provide one [1].

When a country will not issue a certificate, record the attempt and the decision

Not every country shares criminal records for employment purposes [2]. The Home Office gives two reasons a certificate may be unobtainable: the country does not have "functioning criminal record regimes", or it refuses to issue certificates to anyone other than its own citizens [3]. UKVI's caseworker guidance adds others, among them armed conflict and humanitarian disaster [5].

Country procedures add their own obstacles to an overseas police check. For China, the Home Office country guide says "the individual must make the application in person" and that "embassies/consulates will not accept applications", and adds that "a third party representative must consult the Public Security Bureau covering their county of residence" [7]. The guide was last updated on 31 January 2025, with country entries dated then or earlier, so check the current entry before advising a recruit [7]. For someone already settled here, the request arrives after the move, and the application runs under the rules of a country they have left [2][7].

The NHS standard sets out what to do next: "Employers should ask applicants to show any attempt made to seek an overseas police check and any reasons given as to why one could not be obtained" [2]. Where an overseas police check is genuinely not possible, the recruitment decision rests on the wider evidence gathered during recruitment, including character and other references [2]. The Home Office expects employers "to obtain as much information as possible in the form of references" before deciding whether to offer [3]. For the referencing itself, see NHS reference checks.

For the visa, the applicant must explain the attempts made, and UKVI decides whether to waive the requirement [3]. A waiver covers one country, and certificates for any other country that meets the 12 month test are still owed where it is feasible to obtain them [5]. None of these sources publishes a list of countries that will not issue: the Home Office works country by country and UKVI by category of reason [5][7].

What the file should show for an overseas police check in England

Schedule 3 to the Health and Social Care Act 2008 (Regulated Activities) Regulations 2014 lists the information that Regulation 19 requires to be available for each person employed. It names the criminal record certificate issued under the Police Act 1997 and does not mention overseas records [8][9]. The Care Quality Commission's Regulation 19 guidance asks providers to "make every effort to gather all available information to confirm that the person is of good character" [8], and has no sentence on overseas checks. For Schedule 3 more widely, see the Regulation 19 evidence you owe CQC for agency staff.

The only CQC text found for this guide that speaks directly to staff recruited from abroad is a DBS guidance document dated October 2019. It asks providers to apply the same process as for other staff and to contact the relevant foreign embassy to check an overseas record [10]. It still refers readers to the UK Border Agency, which no longer exists, so treat it as dated.

Drawing on what the NHS standard and the Home Office say to obtain and record, an overseas police check file in England would hold:

• the applicant's declaration of time overseas [2], listing the countries and dates
• for each country within your threshold, a certificate issued by a police authority, with the original seen and verified like any other official document [2]
• a translated copy where the certificate is not in English [2]
• where no certificate could be had, the applicant's evidence of each attempt, the reasons given and the references the decision rested on [2][3]
• the DBS check obtained alongside it [2]

Add the threshold you applied and the name of whoever made the recruitment decision. Neither source asks for these in terms.

Several points are not settled by any source cited here. None gives a look-back for adult social care providers outside the NHS or says how old a certificate may be when an employer relies on it for employment. Nothing read for this guide sets a retention period for the certificate or says whether a recruit may start work while one is awaited.

Matching each overseas document to the requirement it satisfies

Credentially is a healthcare onboarding and compliance platform. It classifies each uploaded file and matches it to the requirement it satisfies, capturing the relevant dates as it goes, so your team can see what is still missing and what needs review without working through every document by hand. That matters where you treat the overseas police check as a pre-employment requirement in its own right, because the certificate and its translation arrive as separate documents alongside the DBS check.

Agents can follow up candidates and draft messages as the process progresses, which helps when a recruit is waiting on a certificate from abroad. You decide what each agent can do on its own and what must come back to a person for approval, and every action is recorded. Where no certificate can be obtained, the NHS standard leaves the recruitment decision to the employer on the wider evidence [2], and the platform brings that decision back to a person on your team.

A practical first step is to list every current file where the person declared time abroad, and check that each holds either an overseas police check or a record of the attempt and the decision. When you have the list, see the document matching on a demo.

Frequently asked questions

How far back should an overseas police check go?

Two thresholds are in use. For entry clearance in listed health, care and education occupations, the visa rule requires a certificate from each country outside the UK lived in for 12 months or more in the previous 10 years, from age 18 [3]. For applicants already living in the UK, NHS Employers suggests six months or more overseas within the last five years [2].

Is a certificate of good conduct the same as an overseas police check?

It counts as one when a police authority issues it. NHS Employers says some overseas police authorities issue only a certificate of good conduct or standing, and that such certificates "are valid and can be accepted" [2]. A certificate of good standing from an overseas regulator is a different document and "is not equivalent to a police check" [2], though it can inform the overall assessment.

What should an employer do if a country will not issue a police certificate?

The NHS criminal record checks standard asks employers to have the applicant show any attempt made and any reasons given for why a check could not be obtained [2]. Where a check is genuinely not possible, the decision rests on the wider evidence, including character and other references [2]. The Home Office also expects employers to gather as much information as possible through references before deciding whether to offer [3].

Does CQC require an overseas police check under Regulation 19?

Schedule 3 to the regulations, which sets out the information Regulation 19 requires, names the criminal record certificate issued under the Police Act 1997 and does not mention overseas records [8][9]. The Care Quality Commission's Regulation 19 guidance asks providers to make every effort to gather all available information on good character, with no sentence on overseas checks [8]. The only CQC wording found on staff recruited from abroad dates from 2019 [10].

References

1. Disclosure and Barring Service and Home Office, "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. NHS Employers, "Criminal record checks standard", published 23 July 2026. https://www.nhsemployers.org/publications/criminal-record-checks-standard
3. Home Office, "Guidance on the application process for criminal records checks overseas", GOV.UK, updated 31 January 2025. https://www.gov.uk/government/publications/criminal-records-checks-for-overseas-applicants/guidance-on-the-application-process-for-criminal-records-checks-overseas
4. GOV.UK, "Health and Care Worker visa: Documents you'll need to apply", no date shown, read 11 November 2026. https://www.gov.uk/health-care-worker-visa/documents-you-must-provide
5. UK Visas and Immigration, "Criminal record certificate requirement: caseworker guidance", version 4.0, published for Home Office staff on 11 November 2025. https://www.gov.uk/government/publications/criminal-record-certificate-requirement/criminal-record-certificate-requirement-accessible
6. Home Office, "Explanatory memorandum to the statement of changes to the Immigration Rules: HC 997, 1 July 2025", GOV.UK, last updated 9 December 2025. https://www.gov.uk/government/publications/statement-of-changes-to-the-immigration-rules-hc-997-1-july-2025/explanatory-memorandum-to-the-statement-of-changes-to-the-immigration-rules-hc-997-1-july-2025-accessible
7. Home Office, "Countries A to F: applying for a criminal records check for someone from overseas", GOV.UK, last updated 31 January 2025. https://www.gov.uk/government/publications/criminal-records-checks-for-overseas-applicants/countries-a-to-f-applying-for-a-criminal-records-check-for-someone-from-overseas
8. Care Quality Commission, "Regulation 19: Fit and proper persons employed", page last updated 16 May 2025. https://www.cqc.org.uk/guidance-providers/regulations/regulation-19-fit-proper-persons-employed
9. legislation.gov.uk, Health and Social Care Act 2008 (Regulated Activities) Regulations 2014, Schedule 3, "Information Required in Respect of Persons Employed or Appointed for the Purposes of a Regulated Activity", read 11 November 2026. https://www.legislation.gov.uk/uksi/2014/2936/schedule/3
10. Care Quality Commission, "Disclosure and Barring Service (DBS) checks", version 7, October 2019. https://www.cqc.org.uk/sites/default/files/20191113_Disclosure_and_Barring_Service_DBS_checks_guidance_v7.pdf