29 May 2025

Changes to Disclosure Scotland and PVG membership

As of 1 April 2025, significant legislative changes under the Disclosure (Scotland) Act 2020 have come into effect, impacting how disclosure checks are conducted and how PVG (Protecting Vulnerable Groups) membership is managed.

Key changes to disclosure checks

The previous disclosure levels have been replaced with simplified categories:

  • Level 1: Replaces Basic Disclosure; shows unspent convictions.
  • Level 2: Replaces Standard Disclosure; includes unspent and certain spent convictions, cautions, and other relevant police information.
  • Level 2 with Barred List Check: Replaces Enhanced Disclosure; includes all Level 2 information plus details on whether an individual is barred from working with children or protected adults.
  • PVG Scheme Membership: Mandatory for individuals in regulated roles with children and/or protected adults.

These changes aim to simplify the disclosure process and enhance safeguarding measures.

PVG Scheme becomes a legal requirement

From 1 April 2025, it is a legal requirement for individuals to be members of the PVG scheme when carrying out a regulated role with children, protected adults, or both. This replaces the previous concept of 'regulated work'. Roles such as football agents, talent scouts, hypnotherapists, and certain hospital or hospice-based positions are now included under the PVG scheme.

A three-month grace period is in place until 1 July 2025. During this period, individuals and organisations will not commit an offence if an application to join the PVG scheme is made before 1 July 2025, even if Disclosure Scotland has not issued the result. After this date, it will be an offence to carry out a regulated role without PVG membership.

Changes to disclosure process

Applicants now have more control over their information: Applicants must share a copy of their disclosure with the accredited body that countersigned the application or notify Disclosure Scotland if they will seek a review of the content

  • The previous process of applicant and counter signatory results being shared simultaneously has ended.

Managers should be aware that these legislative changes may require action on your part. Your counter signatory and/or senior manager will keep you informed about any specific actions you need to take. Please ensure you stay updated with any communications regarding these changes.

Reminder for PVG scheme members

If you are a member of the PVG scheme, please ensure your personal details (such as address or name changes) are kept up to date with Disclosure Scotland. You can update your details directly via their website which can be found here: https://www.mygov.scot/manage-pvg

Please speak to your HR Business Partner if you have any questions.