Do new Safeguarding rules put the Work Experience Mission at risk?
Just days after the UK Government announced its National Mission on Work Experience to create 200,000 new placements for young people, concerns are being raised from careers teams in schools and colleges across England, Wales and Northern Ireland that the new regulations for safeguarding could directly impact their ability to deliver.
The Keeping Children Safe in Education 2026 statutory guidance for schools and colleges became statutory on 1 September 2026, and the Crime and Policing Act 2026 changes the definition of regulated activity with the removal of the supervision exemption.
This means that supervision is considered to be a regulated activity if it occurs frequently, is for more than 3 days in a 30-day period or is overnight. Employers must ensure that individuals engaged in such regulated activity are not barred from working with children, usually identified by undertaking an enhanced DBS check with children’s barred list information.
While this affects a number of school and college activities, for careers teams work experience is a key affected area. In the section on ‘Adults who supervise children on work experience’ the statutory guidance states:
407. If the person providing the teaching, training, instruction or care or supervision to the child on a work experience placement or activity will be doing so frequently or for more than three days in a 30-day period, or overnight, this is a regulated activity. You must not allow someone on the barred list to take part in regulated activity.
While everyone agrees that children should be kept safe when undertaking work experience, concerns have been raised that the requirements leave it unclear how schools, colleges and employers should respond. As the impact of safeguarding failures can be so acute, this uncertainty could make school leaders and employers more risk averse until the application of the requirements is clearer, potentially limiting existing activities and any planned expansion. If employers do need to undertake more enhanced DBS checks, the cost and effort could also be a deterrent.
The Disclosure and Barring Service has published a list of FAQs aiming to address ‘common misconceptions’ of the supervision exemption regulation. It includes reference to support from the DBS Regional Outreach team for organisations that are unsure how to apply the removal of the supervision exemption.
The CEC has published a statement on the changes. It mentions that they are in urgent contact with the government to clarify the position and obtain guidance for schools and colleges. They say;
“In the meantime, schools, colleges and employers should continue to follow rigorous safeguarding procedures, undertake suitable risk assessments, and ensure appropriate supervision and safeguarding arrangements are in place for all placements.”
The CDI is also raising the need for urgent clarity with government, and we understand they are aware of the growing concern. We do not have expertise on the legislation, so we suggest following the CEC advice, contacting the Regional DBS team if you need additional support and looking out for further guidance.
The Keeping Children Safe in Education 2026 statutory guidance for schools and colleges became statutory on 1 September 2026, and the Crime and Policing Act 2026 changes the definition of regulated activity with the removal of the supervision exemption.
This means that supervision is considered to be a regulated activity if it occurs frequently, is for more than 3 days in a 30-day period or is overnight. Employers must ensure that individuals engaged in such regulated activity are not barred from working with children, usually identified by undertaking an enhanced DBS check with children’s barred list information.
While this affects a number of school and college activities, for careers teams work experience is a key affected area. In the section on ‘Adults who supervise children on work experience’ the statutory guidance states:
407. If the person providing the teaching, training, instruction or care or supervision to the child on a work experience placement or activity will be doing so frequently or for more than three days in a 30-day period, or overnight, this is a regulated activity. You must not allow someone on the barred list to take part in regulated activity.
While everyone agrees that children should be kept safe when undertaking work experience, concerns have been raised that the requirements leave it unclear how schools, colleges and employers should respond. As the impact of safeguarding failures can be so acute, this uncertainty could make school leaders and employers more risk averse until the application of the requirements is clearer, potentially limiting existing activities and any planned expansion. If employers do need to undertake more enhanced DBS checks, the cost and effort could also be a deterrent.
The Disclosure and Barring Service has published a list of FAQs aiming to address ‘common misconceptions’ of the supervision exemption regulation. It includes reference to support from the DBS Regional Outreach team for organisations that are unsure how to apply the removal of the supervision exemption.
The CEC has published a statement on the changes. It mentions that they are in urgent contact with the government to clarify the position and obtain guidance for schools and colleges. They say;
“In the meantime, schools, colleges and employers should continue to follow rigorous safeguarding procedures, undertake suitable risk assessments, and ensure appropriate supervision and safeguarding arrangements are in place for all placements.”
The CDI is also raising the need for urgent clarity with government, and we understand they are aware of the growing concern. We do not have expertise on the legislation, so we suggest following the CEC advice, contacting the Regional DBS team if you need additional support and looking out for further guidance.
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