Enhanced DBS check for work experience? KCSIE 2026 explained
Do work experience supervisors need an enhanced DBS check?
No. Under KCSIE 2026, work experience supervisors don’t need an enhanced DBS check. The law now puts more of them into regulated activity, which means a barred person must not do it, but the DBS confirmed on 25th August that this creates no new requirement to carry out DBS checks. For 16 and 17 year olds, a school can’t ask for an enhanced check with barred list information at all.
It’s not too late to get work experience right this year, but the decisions that settle it are being made now.
What changed for work experience in September?
Two things happened at once. The careers guidance changed, and schools in England should now be building towards two weeks’ worth of work experience for every student by the end of Year 11. For Years 10 and 11, the guidance says placements should be meaningful, in person and immersive. That’s a good ambition, and a week in a real workplace is still the thing students remember.
The law changed too. From 1st September, the Crime and Policing Act 2026 removed what’s known as the “supervision exemption” from regulated activity, and KCSIE was rewritten to reflect it. Under paragraph 407, anyone who teaches, trains, instructs, cares for or supervises a student on placement frequently, on more than three days in 30, or overnight is in regulated activity, whether or not someone else is in the room.
The second change has started to undo the first.
Why are schools cutting work experience placements to three days?
Since September I’ve seen Careers Leaders talking about cutting five day placements to three, and placement organisers across the country are reporting the same pattern. I’ve also seen schools told that an enhanced DBS check is legally required for any supervisor over the threshold.
Schools have passed that on to employers who’ve hosted students for years, and I’m told some of those employers have stopped. These are people who wanted to help, being turned away by a reading of the guidance that isn’t in the guidance.
What KCSIE actually says about enhanced checks
Paragraph 407 of KCSIE 2026 says: “You must not allow someone on the barred list to take part in regulated activity.” That’s the school’s duty under KCSIE. It doesn’t say the supervisor has to be checked.
The DBS put this in writing on 25th August, saying the change creates no new requirement for organisations to carry out DBS checks, and that DBS doesn’t mandate them either. What has changed is that more roles are now eligible for an enhanced check with barred list information, which is where some of the confusion has come from. For supervisors of 16 and 17 year olds on work experience, though, KCSIE is clear a check can’t be requested. The heading to look for in the DBS statement is “This legislative change means that I must now carry out a DBS check”.
Can a school ask for a DBS check on supervisors of 16 and 17 year olds?
No. Paragraph 409 says schools and colleges are not able to ask a work experience provider to get an enhanced DBS check with children’s barred list information for staff supervising 16 and 17 year olds. The footnote to it explains that employers can no longer request checks in these circumstances either.
When these elements are present, work experience moves beyond observation and becomes a structured learning opportunity.
What about supervisors of students under 16?
KCSIE doesn’t require a check here either. If your DSL feels a particular placement warrants an enhanced check on the supervisor, the school can ask the employer. It’s then for the employer to decide, because a check on a member of staff has to be requested by their employer. (Paragraph 410 also says DBS checks can’t be requested for children under 16, but that’s about checking the student, not the supervisor.)
How does a school make sure nobody barred is supervising?
Through the employer. Paragraph 406 asks schools to make sure the placement provider has policies and procedures in place to protect children from harm. KCSIE doesn’t set out how to do that, or how to meet paragraph 407. A written agreement with the employer is the most practical way we’ve found to do both, and your DSL can still ask for more on any placement where they feel it’s needed.
In a good agreement, the employer confirms it won’t allow anyone it knows or has reason to believe is barred to work with the student, which follows the wording of the Safeguarding Vulnerable Groups Act. It also confirms that its staff have been told they must say if they’re barred. Alongside that sits what good practice always covered: a named, competent supervisor, staff avoiding being alone with the student in isolated or private settings, any concern reported to the school straight away, and the school free to contact the student or visit while the placement is running.
A box saying “we’ve DBS checked everyone” might look safer, but most employers couldn’t honestly tick it, and for 16 and 17 year olds the check can’t be asked for anyway. A box most employers can’t truthfully tick gives you less assurance, not more.
Most of this isn’t new. What’s changed is that more supervisors now fall under a prohibition that was already there.
Does cutting a placement to three days help?
No. A three day block may keep the supervisor below the threshold, but no check was required above it either. The student just loses two days of real workplace.
Why getting this wrong matters
The cost is not abstract. There are roughly a million young people aged 16 to 24 not in education, employment or training (981,000 in the latest ONS figures, up 30,000 on the year). Work experience is one of the few things that changes a young person’s view of what’s possible.
Tens of thousands of employers host students every year without an HR department and without ever having applied for a DBS check. If the sector tells them they need one, they’ll stop offering.
When are schools deciding next summer’s work experience?
Now. Most Year 10 placements run in the summer term, so the decisions being made in October and November will decide whether those placements are five days or three, and whether the plumber who’s taken a student every year is still on the list.
What schools and employers should do about the KCSIE change
Headteachers and Trust CEOs
In many schools, your Careers Leader and DSL will make the decisions about next summer’s placements this term, but the outcome lands with you. That includes whether the school meets the two weeks’ worth ambition, and whether employers who’ve supported you for years are still there next year.
A policy of DBS checking every supervisor can’t be applied across your whole cohort. For 16 and 17 year olds the check can’t be asked for, and for younger students it can take weeks to arrange, with most small employers never having applied for one. A written agreement with every employer can be applied consistently, as long as it’s reviewed before the placement goes ahead and your DSL can see it.
For a trust, there’s a strong case for one approach across every school. Otherwise each DSL reaches a different answer, and an employer who hosts students from two of your schools gets asked for two different things.
Two questions are worth asking this half term. Are any of our placements being shortened because of the KCSIE change? And what do we ask employers to confirm before a student starts?
Careers Leaders
Read paragraphs 406 to 410 of KCSIE yourself and read the DBS statement. Then ask your DSL what assurance they actually want from an employer, and build your process round that, not round a check the guidance doesn’t ask for.
Employers asked for a DBS check
If you’ve been told you must get an enhanced DBS check on your staff before hosting a student, that isn’t a legal requirement. Ask the school to show you where it says so, and ask what assurance they’re after. A written commitment that nobody barred will supervise the student may give them what they need.
The two weeks’ worth ambition is the right one, and it would be a waste to lose it to a misreading.
Frequently asked questions
Do work experience supervisors need an enhanced DBS check under KCSIE 2026?
No. A supervisor who teaches, trains, instructs, cares for or supervises a student frequently, on more than three days in 30, or overnight is now in regulated activity, which means a barred person must not do it. The DBS confirmed on 25th August 2026 that the change creates no new requirement to carry out DBS checks.
Can a school ask an employer for a DBS check on supervisors of 16 and 17 year olds?
No. Paragraph 409 of KCSIE 2026 says schools and colleges can’t ask a work experience provider to get an enhanced DBS check with children’s barred list information for staff supervising 16 and 17 year olds.
Do supervisors of students under 16 need a DBS check?
A check isn’t required. If the school’s DSL feels a particular placement warrants one, the school can ask the employer, and it’s for the employer to decide.
What changed for work experience in September 2026?
The Crime and Policing Act 2026 removed the supervision exemption from regulated activity from 1st September, and KCSIE was rewritten to reflect it. Supervisors over the threshold are now in regulated activity whether or not someone else is present.
How can a school make sure nobody barred supervises a student on work experience?
KCSIE doesn’t set out a method. A practical approach is a written agreement in which the employer confirms it won’t allow anyone it knows or has reason to believe is barred to work with the student, alongside commitments on supervision and reporting concerns. The school’s DSL can still ask for more where they feel it’s needed.
Does cutting a work experience placement to three days avoid the DBS issue?
It may keep the supervisor below the threshold, but no check was required above it either. The student loses two days in a real workplace.
Talk it through
If you’re not sure where your school or trust stands, or an employer has asked you a question you can’t answer, email me at manoj@changingeducation.co.uk. I’d rather spend twenty minutes on it than see another placement cut to three days.
About the author
Manoj Khetia is CEO of The Changing Education Group, a specialist organisation that has supported schools, colleges and employer engagement programmes for more than 18 years.
The Changing Education Group helps education providers deliver high quality, meaningful work experience at scale through expert support, technology and employer network development. Last year it directly managed risk and compliance for around 12,000 work experience placements.
