DBS Changes Coming This Autumn: What Employers Need to Know

DBS Changes Coming This Autumn: What Employers Need to Know

The Disclosure and Barring Service (DBS) is making changes to the ID checking process for DBS applications. These changes will take effect from 1 November 2025 and apply to all DBS checks processed in England, Wales, the Channel Islands, and the Isle of Man.

Whether you’re processing checks regularly or occasionally, it’s important to understand the key updates and what they mean in practice.

Currently, employers can choose between different ID verification routes (Route 1, 2 or 3), depending on the documents applicants can provide. Applicants must also supply at least one document showing their current address. The DBS uses two categories of acceptable ID: Group 1 and Group 2 documents.

Group 1 – Primary Identity Documents

These are considered the most reliable forms of ID and must include at least one document from this group when using Route 1. Examples include: passport (any nationality), UK driving licence (photocard, full or provisional), biometric residence permit (UK), birth certificate (issued within 12 months of birth in the UK, Isle of Man, Channel Islands), and adoption certificate (UK).

Group 2 – Secondary Identity Documents

These are split into Group 2a and Group 2b:

Group 2a includes documents confirming identity and address, such as a current UK driving licence (paper version – if not already used in Group 1), birth certificate (issued more than 12 months after birth), marriage or civil partnership certificate, P45 or P60, bank or building society statement, mortgage statement, or council tax statement.

Group 2b includes documents confirming address only, such as utility bills, credit card statements, financial statements (e.g. pensions or endowments), or benefit statements (e.g. Child Benefit, DWP). Documents in Group 2 must generally be less than three months old (for statements) or 12 months old (for things like P60s or Council Tax bills).

From 1 November 2025, several changes will come into effect:

1. Mandatory Use of the 3-Route ID Verification Process All employers must use the three-route ID verification process for every applicant, including those from overseas. This removes the option to rely solely on Route 1, ensuring a standardized and more secure approach to identity checking.

2. No Requirement for an Address Document Applicants will no longer need to provide a document that shows their current address. This change simplifies the process, especially for those who have recently moved or have difficulty accessing proof-of-address documents.

3. Expanded List of Acceptable Documents The lists of acceptable Group 1 and Group 2 documents have been expanded. Notably, the following documents have been added:

• Group 1: eVisa, Biometric Residence Permit (BRP), Application Registration Card (ARC)
• Group 2b: HMRC self-assessment or tax demand letters, European Health Insurance Card (EHIC), Global Health Insurance Card (GHIC)

4. Enhanced Guidance on Document Verification The DBS is also introducing clearer guidance for how employers and ID verifiers should check and handle ID documents. This aims to improve consistency and reduce errors in the verification process. In addition, new scenarios and examples are being included in the DBS guidance to help employers better understand how to manage ID checks in more complex or unusual situations, such as for overseas applicants or those without fixed addresses.

5. Additional Scenarios and Examples New scenarios and examples have been included in the DBS guidance to help employers better understand how to manage ID checks in more complex or unusual situations, such as for overseas applicants or those without fixed addresses.

Preparing for the Changes

Employers should take action now to review and update their DBS procedures ahead of November. It’s also important to train staff involved in ID checking, update internal documentation and forms, and begin communicating with applicants and employees who may be affected by the new requirements.

If you need assistance updating your DBS processes or interpreting the new guidance, we're here to support you.