Continuous DBS Checks: Can UK Employers Monitor Staff After Hire?

Jurisdiction: This article covers the DBS Update Service for standard and enhanced DBS checks in England and Wales.

This article is for informational purposes only and does not constitute legal advice. Employment law and screening regulations vary by jurisdiction. Consult a qualified legal professional before making compliance decisions.

The DBS Update Service lets employers confirm instantly whether an existing DBS certificate is still current, without a new application. For HR and compliance teams managing large workforces in healthcare, education, and care, it offers a simple way to keep criminal record information up to date between full checks.

DBS published updated employer guidance in August 2026 following a Home Office review of the service, and reduced the subscription fee to £15 a year from 5 October 2026. The updated guidance clarifies what a status check shows, when employers can run one, and how often. What is the DBS Update Service?

The DBS Update Service is an online subscription that keeps a standard or enhanced DBS certificate up to date. With the individual's consent, employers can run a free, instant status check on that certificate. Subscriptions cost £15 a year and are free for volunteers.

Three features define how it works:

Personal subscriptions: the certificate holder creates and manages the subscription, even when an employer pays for it

Regular DBS searches: once a certificate is linked, DBS searches weekly for new conviction and barred list information, and every 9 months for relevant non-conviction police information

Portability: a subscriber can take a certificate from role to role, where the new role needs the same level and workforce

The Update Service covers standard and enhanced certificates only. Basic certificates are managed through a separate DBS online account.

How does the Update Service differ from a fresh DBS application?

A status check confirms whether anything has changed since an existing certificate was issued, while a fresh application produces a new certificate with full details. The status check is instant and free. A new application takes longer and carries the DBS fee.

Here is how the two compare directly.

In summary, the status check tells you whether to act, and a fresh application tells you what has changed.

Who should register for the DBS Update Service?

Anyone who holds a standard or enhanced DBS certificate and expects to need it again benefits from registering. Employers in sectors that recheck staff regularly may encourage new hires to subscribe as part of onboarding.

Individuals register in one of two ways:

During an application, using the application reference number, with DBS receiving the form within 28 days

After the certificate arrives, using the certificate number, within 30 days of the date of issue

The subscription works particularly well for:

Staff in regulated activity with children or adults, who may be rechecked throughout employment

Agency and supply workers, who move between organisations requiring the same check

Volunteers, who can subscribe free of charge

How do employers check an existing DBS certificate's status?

Employers check a certificate's status on the Update Service website by entering the certificate number, the holder's surname, and date of birth, after confirming a legal declaration. No account or fee is needed for an individual status check.

What you need before running a status check

DBS guidance sets five conditions, and all five must be met:

You have seen the original certificate in person and confirmed it is genuine. Copies and video calls are not sufficient.

You have verified the holder's identity under the DBS ID checking guidelines.

You have the individual's consent.

You are legally entitled to the same level of check for the role.

The certificate covers only the workforce, child, adult, or other, that you are entitled to know about.

Once those conditions are met, later status checks for the same person and role do not need the certificate or identity check repeated each time. Status checks stop when the person leaves, moves to a role without the same entitlement, or withdraws consent.

What the status check results mean

A status check returns one of four results:

Did not reveal any information and remains current: the certificate was blank when issued and no new information has been confirmed

Remains current: the certificate contained information and nothing new has been confirmed since

No longer current: DBS has confirmed new information that would appear on a new check, so apply for a new certificate

Details do not match: the person has not subscribed, has removed the certificate, or the details were entered incorrectly

When a result shows a change, DBS recommends discussing it with the individual. For enhanced checks with a barred list, an early confirmation check can confirm within 7 working days whether the change relates to barring.

Checking many certificates at once

Organisations with large workforces can use the DBS multiple status checking facility. The web service connects an organisation's own system to the Update Service and returns results for many certificates at once.

Why does ongoing checking matter for regulated industries?

Ongoing checking matters because a DBS certificate reflects information on the date it was issued, and a certificate has no official expiry date. Periodic status checks give regulated employers continued confidence that their workforce remains suitable for the roles they hold.

Can UK employers carry out continuous DBS checks on existing employees?

Not in a continuous sense, and DBS is clear on this point. A status check reflects information at the moment it is carried out and is not continuous monitoring. DBS does not notify employers when a status changes, so the employer decides when to check.

What employers can do is run status checks at any time, with consent and legal entitlement. DBS sets no fixed frequency and asks organisations to set a risk-based schedule using:

The nature of the role

The level of potential risk

Regulatory requirements

Safeguarding policies

DBS guidance gives the example of an academy that runs status checks every 6 months and rechecks staff identity every 2 years.

What continuous screening looks like in the UK

Ongoing screening in the UK combines several periodic checks rather than one always-on feed:

Scheduled DBS Update Service status checks for eligible roles

Fresh DBS applications where there is no subscription or a status change

Right to Work follow-up checks for staff with time-limited permission

Professional registration checks for regulated professions

Clear policies on how employees raise relevant changes in their circumstances

DBS also reminds employers that the Update Service works best alongside identity checks, employment history checks, and references, rather than on its own. A healthcare pre-employment screening checklist shows how those checks fit together.

How does AI-powered verification support Update Service checks?

AI-powered verification supports the Update Service by handling the verification steps around it: identity checks, consent records, employment history, and a complete audit trail. DBS operates the Update Service itself, and a person reviews every result and makes every decision.

TRACE, TraqCheck's AI background verification agent, fits alongside your Update Service process in four ways:

Identity verification, including liveness checks, as part of your wider safer recruitment checks

Consent captured through a branded, mobile-friendly link, with a timestamped record

Employment and education verification, the wider safer recruitment checks DBS recommends alongside status checks

International criminal record checks across 190+ countries for staff with overseas history, which DBS checks do not cover

A human verification specialist reviews every TRACE result before the report reaches your team, and every check sits in a full audit trail. Pairing scheduled status checks with consistent compliance and regulatory screening gives compliance and risk teams one clear record for every employee.

Keeping DBS assurance current

The DBS Update Service gives employers a free, instant way to keep criminal record information current. The service works best when the conditions are met and checks follow a schedule matched to the risk of each role. The August 2026 guidance makes those expectations clearer than ever. To see how TRACE supports the identity, consent, and verification steps around your DBS process, book a demo.

Frequently asked questions

What is the DBS Update Service?

The DBS Update Service is an online subscription that keeps a standard or enhanced DBS certificate up to date. With the holder's consent, employers can run a free, instant status check to see whether the certificate remains current.

How much does the DBS Update Service cost?

The subscription costs £15 a year from 5 October 2026 and is free for volunteers. Employers do not pay to run status checks.

Can employers check the Update Service without permission?

No. Employers need the individual's consent, must be legally entitled to the same level and workforce of check, and must have seen the original certificate and verified the holder's identity.

Does the DBS Update Service notify employers of changes?

No. DBS does not notify employers when a status changes. Employers run status checks on a schedule they set, based on the risk of each role.

Can basic DBS certificates be added to the Update Service?

No. The Update Service covers standard and enhanced certificates only. Basic certificate holders use a separate DBS online account.

How long do you have to join the DBS Update Service?

Individuals joining with a certificate number must register within 30 days of the certificate's date of issue. People joining during an application use the application reference number, and DBS must receive the form within 28 days.