Changes to DBS ID checking guidance: a compliance timeline for employers

DBS checks are a cornerstone of safe recruitment in England and Wales. For employers in regulated industries, they’re a legal requirement.

In April 2025, the Home Office released updated ID checking guidelines for basic DBS checks. Employers have until 1st November 2025 to implement the new guidelines fully.

In this article, you’ll learn how the rules are changing, what this means for employers and how HR teams can prepare.

Disclaimer: Everything in this article is correct as of August 2025. Always check official government guidance before finalising your processes.

What is a DBS check?

A DBS check is a criminal record check carried out by the Disclosure and Barring Service to help employers in England and Wales make safer hiring decisions.

DBS checks reveal whether a candidate has a criminal history that could make them unsuitable for particular roles (e.g., those that involve working with children or other vulnerable groups). The information is confirmed in a DBS certificate.

There are different levels of DBS checks, from basic checks to enhanced checks, depending on the role. Identity verification is an important part of the DBS checking process and new ID checking rules for employers were introduced in 2025.

Note: A DBS check does not provide evidence of a person’s right to work in the UK. Employers must use a different process to conduct a right to work check.

What’s new in the 2025 DBS ID guidance?

The ID checking guidance for basic DBS checks and standard/enhanced checks changed on 22nd April 2025 but organisations have until 1st November 2025 to update their processes. From then on, compliance with the new rules will be mandatory.

The updated guidelines include:

• Simplified ID routes for standard and enhanced DBS checks, making it easier to validate the applicant’s identity.

• Removal of some current address requirements, reducing the number of proofs of address needed in many cases.

• Expanded acceptance of digital ID verification, including the use of an e-visa for non-UK nationals.

• Updated retention periods, setting out clearer rules for how long HR teams and schools should keep identity documents before secure disposal.

Who needs to follow the new guidance?

The updated guidance applies to:

• HR managers and recruiters in any organisation that carries out DBS checks

• Safeguarding leads in schools, charities and healthcare settings

• Registered bodies working directly with the DBS or through umbrella organisations

• Employers in regulated industries such as education, healthcare and financial services

Note: Individuals who carry out identity checks in organisations can’t verify the identity of a relative or partner, anyone who lives in the same house as them, or a personal friend.

Acceptable ID documents for DBS checks from November 2025

From November, applicants must prove their identity using one of three approved routes. The correct route depends on the documents available and whether the applicant lives in the UK, the Channel Islands, or the Isle of Man.

Group 1: Primary identity documents

Primary documents are the strongest form of ID. Accepted documents include:

• A valid passport issued by the UK, Channel Islands, Isle of Man or Ireland

• An e-Visa

• A biometric residence permit (BRP) issued by the Home Office

• A current UK driving licence photocard (full or provisional)

• An Application Registration Card or ‘ARC’ (for applicants with a pending claim for asylum)

• An EEA passport card (for standard and enhanced checks only)

Group 2a: Trusted government and financial documents

If the applicant cannot provide a primary document, they may use a selection of trusted government or financial records. Examples include:

• Current driving licence photocard (full or provisional)

• Current driving licence (full or provisional) - paper version (if issued before March 2000)

• A birth certificate issued after the time of birth

• A marriage or civil partnership certificate

• Immigration document, visa or work permit

• An HM Forces ID card or HM Armed Forces Veteran card

Group 2b: Financial and social history documents

If applicants cannot provide the above, they may rely on financial and utility documents. Group 2a documents must be recent, usually dated within the past three months. Examples include:

• Mortgage statement

• Bank or building society statement

• Credit card statement

• Financial statement (e.g. pension statement)

• P45 or P60 statement

• Council tax statement or utility bill

• HMRC Self Assessment letters or tax demand letter

• EEA National ID card

• Cards carrying the PASS accreditation logo

• European Health Insurance Card (EHIC) or Global Health Insurance Card (GHIC)

For applicants living in the Channel Islands or on the Isle of Man, equivalent documents from their jurisdiction are also accepted, provided they meet the same criteria.

The ID checking process for basic and standard/enhanced checks

The new rules outline clear routes through which an employer can check a candidate’s ID, depending on the combination of documents they have.

Basic checks: the 2-route process

For basic DBS checks, there are two routes available for ID checking. You must use route 1 where possible.

Route 1

Employers must use Route 1 where possible, and can only use Route 2 if the candidate is unable to provide the documentation required for Route 1.

The applicant must be able to show the:

• One document from Group 1

• One further document from either Group 1, Group 2a or Group 2b

This combination of ID documentation must confirm the applicant’s name and date of birth. If this isn’t possible with two documents, applicants can provide a third document.

Route 2

If the applicant doesn’t have any of the documents in Group 1, they must be able to show:

• One document from Group 2a

• Two further documents from either Group 2a or Group 2b

This combination of ID documentation must confirm the applicant’s name and date of birth.

If an applicant is unable to provide this documentation they can’t submit an application for a DBS basic check.

Standard/enhanced checks: the 3-route process

For standard and enhanced DBS checks, there are three routes available for checking a candidate’s ID.

Route 1

Employers must use Route 1 where possible, and can only use Route 2 if the candidate is unable to provide the documentation required for Route 1.

The applicant must be able to show:

• One document from Group 1

• Two further documents from either Group 1, or Group 2a, or 2b

This combination of ID documentation must confirm the applicant’s name and date of birth.

Route 2

If Route 1 isn’t possible, employers can use Route 2.

Applicants must be able to show:

• One document from Group 2a

• Two further documents from either Group 2a or 2b

This combination of ID documentation must confirm the applicant’s name and date of birth.

After checking this documentation, the employer must then also use an appropriate external ID verification service to check the application.

Route 3

Employers should only use Route 3 if it’s impossible to process the application through Routes 1 or 2.

In this scenario, the applicant must be able to show:

• A birth certificate from the UK, the Isle of Man or the Channel Islands issued after the time of birth

• One document from Group 2a

• Three further documents from Group 2a or 2b

Again, this combination of ID documentation must confirm the applicant’s name and date of birth.

What does DBS ID checking involve?

Employers conducting their own ID checks should do so using one of the following methods, prioritising option 1 wherever possible.

Option 1: In-person ID check

The ID check should be conducted face-to-face, allowing the ID checker to view the physical documents, eVisa or digital PASS card in the candidate’s presence.

The government asks employers who can’t use option 1 to consider using digital identity verification before considering option 1.

Option 2: ID check via video link with ID checker in possession of physical documents

The second option is for the ID check to be conducted via video link (e.g. via Google Meet or FaceTime) with the applicant’s physical documents in the ID checker's possession of the physical documents.

Applicants should post the documents to the ID checker in advance of the video call.

Employers who use this option must keep a record of the following information for a minimum of two years:

• The reason why they couldn’t use option 1

• A record of the documents they used to validate the identity

Option 3: ID check via video link with ID checker not in possession of physical documents

The third option is for the ID check to be conducted via video link (e.g. via Google Meet or FaceTime) without the applicant’s physical documents in the ID checker’s possession.

The applicant must show the documents on camera during the video call, which must be recorded. On their first day of employment, they must present the ID checker with the original documentation.

The ID checker must record the date they completed the in-person ID check and cross-reference the details recorded during the video call. If there are any discrepancies, the DBS check may become invalid.

How to verify DBS ID documents correctly

Employers conducting their own ID checks must review ID documentation carefully to ensure authenticity and accuracy.

The government encourages ID checkers to look for signs of tampering and to query any signs of damage, especially on areas of the documentation displaying personal details (e.g. name or photograph).

The National Document Fraud Unit (NDFU) offers guidance on examining identity documents to detect basic forgeries.

DBS ID checking: a compliance checklist for HR teams

If you haven’t yet prepared for the new DBS ID guidance, there’s still time. Here are the steps you need to follow ahead of 1st November.

Immediate action

• Review the Home Office guidance on gov.uk in full as soon as possible

• Brief HR managers and recruiters on the updated DBS identity checking guidelines

• Update your DBS application forms and onboarding materials with the new ID routes

• Start testing an external identity provider if you expect to rely on digital checks

Consolidate and train

• Train HR and recruitment staff on checking identity documents and spotting errors

• Update your internal policies and guidance notes for managers

• Communicate changes to candidates so they know what documents to provide for identification verification

Full compliance

• From 1st November, ensure the updated ID checking guidance is followed consistently

• Archive old processes and securely dispose of out-of-date templates

• Confirm document retention policies align with the new rules

How Rippling helps HR teams stay compliant with DBS ID checking rules

When you’re hiring at pace or juggling compliance with day-to-day tasks, keeping track of DBS checking activities can be a headache. That’s where Rippling comes in.

Rippling lets you manage all your hiring and employee records in one place, making DBS ID checking simple. Rippling's Recruiting software integrates background screening directly into the onboarding flow. This means you can trigger DBS checks at the right time and track progress as part of your wider hiring process.

Rippling isn’t just a DBS check tool or an HR app. It’s a full workforce management platform. It connects HR, Payroll, IT, and Spend, all in one place, and all built on a single source of truth. When someone starts a new role, their data flows automatically across their contract, payroll, access permissions, pension contributions, and more.

DBS ID guidance changes FAQs

How should organisations handle the overlap between the current guidance and the new DBS ID rules before 1st November 2025?

Between 22nd April and 1st November 2025, organisations can continue using the previous ID checking guidelines. However, it’s best practice to move to the updated ID checking process as soon as possible and ensure early compliance.

Can previously accepted ID documents still be used after 1st November?

No. ID documents not listed in either Group 1, Group 2a or Group 2b will not be valid for proving the applicant’s identity from 1st November 2025 onwards.

What are the consequences of failing to follow the new guidance from 1st November?

Submitting checks with incorrect identity documents may result in rejected applications, delays in hiring or regulatory penalties. In safeguarding sectors, it may also lead to compliance investigations, reputational risk and, in some cases, prosecution.

If an applicant can’t provide this documentation, they may be asked to have their fingerprints taken at a police station as an alternative way of checking their criminal record.