PVG check: what health and care employers with staff in Scotland need in place

If your agency in England books a nurse with an Enhanced DBS certificate onto a hospital ward in Edinburgh, the DBS certificate is not enough. Disclosure Scotland says "if an individual is doing a regulated role in Scotland, they must be in the PVG scheme, even if they're already checked by DBS or Access NI for the same role" [1]. The nurse needs a PVG check first, and since 1 July 2025 an agency that supplies someone for a regulated role before it has received the result commits an offence [2][3].

"PVG check" is the search term; the official result is a PVG scheme disclosure confirming membership of the Protecting Vulnerable Groups scheme [4].

A DBS certificate does not cover a regulated role in Scotland

Membership of the PVG scheme, which Disclosure Scotland manages, is "a legal requirement" for a regulated role and "lasts for five years" [5]. The rule covers "organisations normally based elsewhere in the UK, but whose staff or volunteers work in Scotland some of the time", where that work is "a normal part of the role" [1].

GOV.UK's guidance on Disclosure and Barring Service checks says "There are different rules for getting criminal record checks in Scotland" [6]. It also says a DBS check "has no official expiry date" [6], and applicants can keep a certificate up to date through the DBS Update Service, which "costs £15 per year" [7]. Disclosure Scotland cites one difference: "the PVG scheme has continuous monitoring of members", and someone found unsuitable "can be removed from this work" [1].

Since 1 July 2025, offering a regulated role before the disclosure arrives is an offence

The legal requirement began on 1 April 2025, when "regulated roles" replaced "regulated work" [8][9]. After a three-month grace period [10], it has been a criminal offence since 1 July 2025 "for an organisation to offer a regulated role to someone who is not a member of the PVG scheme" [11].

Section 45D of the Protection of Vulnerable Groups (Scotland) Act 2007 sets the test for the organisation: no offer of a regulated role "unless the organisation has received a Level 2 disclosure" confirming membership [3]. An offer made "subject to the organisation receiving a Level 2 disclosure" is not treated as an offer for this purpose [3].

The disclosure has to arrive before any of the role is done, including work "on a trial and/or under supervision of someone else", and it "cannot be replaced by a risk assessment" [9]. The maximum penalty is 12 months' imprisonment on summary conviction and five years on indictment, and a fine can be imposed instead or as well [12].

Your organisation decides which health and care roles are regulated

Deciding which roles need a PVG check falls to the employer: "Recruiting organisations are responsible for deciding whether a role is a regulated role and requires PVG scheme membership" [11]. The test has two parts, a listed activity and contact with children or protected adults that is "more than incidental", including "exercising power or influence" over them [13]. An activity done once a year can be enough [13].

Disclosure Scotland's health list, which "is not exhaustive", names "Porter (hospital/hospice)" and "Domestic in a hospital or hospice" alongside doctors and nurses, subject to the contact condition [14]. Its care list includes "Support worker" and "Shared lives carer" [15].

Setting changes the answer. In a hospital or hospice, a role that needs unsupervised contact is a regulated role. In another healthcare setting that contact alone does not make it one, and Disclosure Scotland's case study finds a GP receptionist "is not in a regulated role because a GP practice is not a named location" [13].

Line managers and day-to-day supervisors of people doing a listed activity are in a regulated role too, even with no contact of their own with children or protected adults [9].

Agencies supplying staff into Scotland carry their own PVG check duty

Agencies are covered separately. Under section 45F, it is an offence for a personnel supplier to "offer or supply the individual" for a regulated role "unless the personnel supplier has received a Level 2 disclosure" confirming membership [2].

Disclosure Scotland's health sector guidance applies this to locums and other temporary staff from elsewhere in the UK: "the legal requirement is for the agency to ensure that the PVG scheme disclosure is in place before they are supplied for any regulated role" [13]. The guidance adds that this can be done in advance, so an agency in England can complete the PVG check before any Scottish booking exists [13]. Disclosure Scotland's application steps begin with registering the organisation, and an organisation that does not register can use an umbrella body to countersign applications on its behalf [18][29].

Direct hiring moves the duty. A Scottish health service employing a locum directly from elsewhere in the UK "must carry out the PVG scheme disclosure prior to the individual commencing their role" [13]. The guidance treats an emergency arrangement that does not continue beyond the emergency as outside the scheme, and gives no number of days [13].

Each registered organisation needs its own copy of the disclosure, even for someone already in the scheme through another organisation [16]. The duty to refer harmful behaviour to Disclosure Scotland covers "an employment agency" too [17]. For staff you also place in England, see the equivalent evidence question in England and our guide to onboarding agency and locum staff.

What a PVG check costs and how long each step takes

A PVG check starts with your organisation: "The person you're working with cannot apply until you start it" [18]. The applicant has 14 days to complete the form, and 14 days to share the disclosure with you after viewing it; Disclosure Scotland "aims to process applications within 14 days" [18]. Between 1 July and 30 September 2026 it completed 99.9% of applications of all types within 14 days, averaging 4.7 days [19]. Sharing is slower: in what its October 2026 update calls quarter two, 92.8% of eligible disclosures were shared within 14 days [20], so about 7 in 100 were not.

The fees page, last updated 6 November 2026, lists £59 to join and £18 for an existing member continuing with the same vulnerable group [4]. The Scottish Government will pay for applications received between 1 August 2026 and 31 July 2027 from eligible workers taking up a new job or a new position "in social care commissioned services in the private, voluntary and independent sectors", marked "FSC" in the Position Applied For field [21]. Nurses and shared lives carers were added on 18 August 2026 [21].

Five-year membership started on 1 April 2026, and the renewal process was unpublished in November 2026

Lifetime membership ended on 1 April 2026, replaced by "a five-year membership period", and earlier members move across when they next apply [22]. Disclosure Scotland will notify members "at least three months before their membership is due to end", and "Organisations with an interest will also be informed" [23]. The organisation that applied is also told "if the Scheme member is later considered for listing or becomes barred" [9]. Organisations are asked to keep "interested party details up to date regularly" [20] and to report when a member stops doing a regulated role for them [24].

No Disclosure Scotland page read for this guide in November 2026 sets an interval for repeating a PVG check on existing staff. Its March 2026 questions page says organisations "should not apply earlier or more often than usual", without defining usual [23]. None of those pages describes an on-demand look-up of a member's current status. The renewal process is promised: "More information on the renewal process will be published on this webpage once the renewal dates are nearer" [22].

The staff file keeps the record of the PVG check and deletes the disclosure

Disclosure Scotland's Code of Practice says "You must not keep a photocopy or other image of the disclosure information. This should be deleted" [25]. In the full Code's example, disclosure information "could be securely destroyed on the date on which the recruitment or other relevant decision has been taken" [26].

A registered organisation keeps a written policy and a record that tracks "disclosure applications and results" [16]. Disclosure Scotland's sample spreadsheet sets out fields for each PVG check, including position, disclosure level, date received, disclosure number, PVG membership number, date destroyed or deleted and recruitment decision [27]. The Code also suggests keeping "details of identity checks undertaken" [26].

The Care Inspectorate and Scottish Social Services Council guide "Safer recruitment through better recruitment" says "The Care Inspectorate expects employers to retain full records for people who are appointed" [28]. The edition on the Care Inspectorate site is dated 3 October 2023 and uses the earlier terms, such as "regulated work". No source reconciles that expectation with the Code's ban. This guide reads the two together as a full record of the check, with the disclosure deleted; neither body has published that reading.

Building requirements around the role, site and client

Credentially, a healthcare onboarding and compliance platform, builds each compliance package around the role, site and client, so each person is asked only for what applies to them. Your team sees which requirements are complete and which need review, and agents can follow up candidates, with every action recorded. Under the Code, no copy or image of the disclosure itself may be kept in the file. In pre-employment checks, you decide what agents can do on their own and what must come back to a person for approval.

Before your next Scottish booking, ask Disclosure Scotland for the list of PVG members connected with your organisation [24] and compare it with the roles you treat as needing a PVG check, managers included. Then see compliance packages built around the role, site and client on a demo, and bring your PVG check questions.

Frequently asked questions

Does a nurse with an Enhanced DBS check need a PVG check to work in Scotland?

Yes, if the work is a regulated role in Scotland. Disclosure Scotland says the person "must be in the PVG scheme, even if they're already checked by DBS or Access NI for the same role". This includes staff of organisations based elsewhere in the UK whose work in Scotland is a normal part of the role.

Who does the PVG check for agency or locum staff working in Scotland?

For agency locums and other temporary staff, Disclosure Scotland's health sector guidance puts the duty on the agency: the PVG scheme disclosure must be in place before the person is supplied, and can be arranged in advance. Supplying without it is an offence under the Protection of Vulnerable Groups (Scotland) Act 2007. A Scottish health service hiring a locum directly does the check itself.

Can an employer keep a copy of a PVG disclosure on the staff file?

No. Disclosure Scotland's Code of Practice says "You must not keep a photocopy or other image of the disclosure information". Keep a tracking record instead. Disclosure Scotland's sample includes the disclosure number, PVG membership number, date received, date destroyed or deleted and the recruitment decision. The Code also suggests keeping details of the identity check.

Does PVG scheme membership expire?

Yes. Since 1 April 2026, membership lasts five years, and people who joined earlier move to five-year membership when they next apply. Disclosure Scotland will notify members at least three months before membership ends, and organisations with an interest will be informed. Details of the renewal process had not been published when this guide was written in November 2026.

References

1. Disclosure Scotland, "Roles outside Scotland or remote work", mygov.scot, last updated 19 June 2026. https://www.mygov.scot/pvg-outside-scotland
2. legislation.gov.uk, "Protection of Vulnerable Groups (Scotland) Act 2007, section 45F", latest available revised version, read 11 November 2026. https://www.legislation.gov.uk/asp/2007/14/section/45F
3. legislation.gov.uk, "Protection of Vulnerable Groups (Scotland) Act 2007, section 45D", with textual amendment F1 on commencement, latest available revised version, read 11 November 2026. https://www.legislation.gov.uk/asp/2007/14/section/45D
4. Disclosure Scotland, "Types of PVG application", mygov.scot, last updated 6 November 2026. https://www.mygov.scot/pvg-scheme/application-types
5. Disclosure Scotland, "Protecting Vulnerable Groups (PVG) scheme", mygov.scot, last updated 6 November 2026. https://www.mygov.scot/pvg-scheme
6. GOV.UK, "Check someone's criminal record", no page date shown, read 11 November 2026. https://www.gov.uk/dbs-check-applicant-criminal-record
7. GOV.UK, "DBS Update Service", no page date shown, read 11 November 2026. https://www.gov.uk/dbs-update-service
8. Disclosure Scotland, "PVG scheme is now a legal requirement", news, 1 April 2025. https://www.disclosure.gov.scot/news/2025/04/pvg-scheme-legal-requirement
9. Disclosure Scotland, "PVG scheme: Regulated roles guidance" (Word document), mygov.scot, page last updated 1 September 2026. https://www.mygov.scot/pvg-scheme-regulated-roles-guidance
10. Disclosure Scotland, "PVG scheme will be a legal requirement", news, 5 December 2024. https://www.disclosure.gov.scot/news/2024/12/pvg-scheme-legal-requirement
11. Disclosure Scotland, "Understanding your legal responsibilities under the PVG scheme", news, 1 September 2026. https://www.disclosure.gov.scot/news/2026/09/understanding-your-legal-responsibilities-under-the-pvg-scheme
12. legislation.gov.uk, "Protection of Vulnerable Groups (Scotland) Act 2007, section 45G", latest available revised version, read 11 November 2026. https://www.legislation.gov.uk/asp/2007/14/section/45G
13. Disclosure Scotland, "Guidance for the health sector" (Health Services guide, Word document), mygov.scot, page last updated 1 September 2026. https://www.mygov.scot/disclosure-guidance-health
14. Disclosure Scotland, "PVG scheme, list of regulated roles: Regulated roles in health", mygov.scot, last updated 13 August 2026. https://www.mygov.scot/list-of-regulated-roles/health
15. Disclosure Scotland, "Regulated roles in care", mygov.scot, last updated 13 August 2026. https://www.mygov.scot/list-of-regulated-roles/care
16. Disclosure Scotland, "Register your organisation with Disclosure Scotland: Responsibilities", mygov.scot, last updated 18 June 2026. https://www.mygov.scot/register-organisation-disclosure/duties
17. Disclosure Scotland, "Making a referral to Disclosure Scotland: What is a referral" and "When to make a referral", mygov.scot, both last updated 18 June 2026. https://www.mygov.scot/pvg-referrals and https://www.mygov.scot/pvg-referrals/when-to-refer
18. Disclosure Scotland, "Apply to the PVG scheme: Start a PVG application for a worker or volunteer", mygov.scot, last updated 1 October 2026. https://www.mygov.scot/apply-to-pvg-scheme/organisations
19. Disclosure Scotland, "Disclosure Scotland performance: 99.9% of applications completed within 14 days", news, 2 November 2026. https://www.disclosure.gov.scot/news/2026/11/disclosure-scotland-performance-99-9-of-applications-completed-within-14-days
20. Disclosure Scotland, "Disclosure Scotland Quarterly Update", news, 28 October 2026. https://www.disclosure.gov.scot/news/2026/10/quarterly-update
21. Scottish Government, "Social care PVG scheme applications: fee waiver", gov.scot, first published 28 July 2026, last updated 18 August 2026. https://www.gov.scot/publications/social-care-pvg-checks-fee-waiver/
22. Disclosure Scotland, "How long PVG membership lasts", mygov.scot, last updated 6 November 2026. https://www.mygov.scot/pvg-scheme/five-year-pvg
23. Disclosure Scotland, "Your PVG scheme membership is changing: Common questions answered", news, 16 March 2026. https://www.disclosure.gov.scot/news/2026/03/pvg-changes-questions
24. Disclosure Scotland, "Manage your PVG membership: Leaving the PVG scheme", mygov.scot, last updated 18 June 2026. https://www.mygov.scot/manage-pvg/leave
25. Disclosure Scotland, "Disclosure Scotland's Code of Practice: Using disclosure information", mygov.scot, last updated 18 June 2026. https://www.mygov.scot/disclosure-scotland-code-of-practice/information
26. Disclosure Scotland, "Disclosure Scotland Code of Practice" (Word document), mygov.scot, page last updated 19 June 2026. https://www.mygov.scot/disclosure-code-of-practice
27. Disclosure Scotland, "Sample spreadsheet to track disclosure applications" (Excel file), mygov.scot, last updated 9 September 2026. https://www.mygov.scot/track-disclosure-applications-sample
28. Care Inspectorate and Scottish Social Services Council, "Safer recruitment through better recruitment" (PDF), 3 October 2023. https://www.careinspectorate.scot/resources-data/publications-and-statistics/library/safer-recruitment-through-better-recruitment
29. Disclosure Scotland, "Register your organisation with Disclosure Scotland: Register with Disclosure Scotland", mygov.scot, last updated 18 June 2026. https://www.mygov.scot/register-organisation-disclosure