Scotland PVG to 5-year membership from April 2026

PVG checks are the routine pass you show when you work with pupils, young people or adults at risk. If you’re in teacher training, on a college placement, or coordinating volunteers, this sits within your safeguarding basics. The Scottish Government has now confirmed changes that place PVG membership on a five‑year cycle. The detail is set out in Scottish Statutory Instrument 2025/352 on legislation.gov.uk, and it introduces two key switchover dates in early 2026.

Two dates matter. From 12 January 2026, section 81 of the Disclosure (Scotland) Act 2020 takes effect, removing several older court‑referral routes in the PVG Act 2007. From 1 April 2026, sections 71 and 72 of the 2020 Act switch on the new five‑year PVG membership and the surrounding renewal rules. If you plan placements or staff rotas, these are dates to mark now.

From April, PVG membership will run for a set five‑year period for each relevant type of regulated role. When that period ends, you renew to stay in the PVG Scheme for that role type. This replaces the previous open‑ended feel and helps ensure checks remain current. In the law, this sits in new sections 45A and 45B of the PVG Act 2007, inserted by the 2020 Act.

If a member does not renew by the end of the discretionary period and Ministers have reasonable grounds to believe they are still doing a regulated role, a consideration process can begin that may lead to listing. You will be shown the date your membership started or was renewed, any expiry notices, and any information Ministers intend to rely on. You’ll have 28 days to send representations or extra information before a decision is made. These fairness steps are spelled out in the updated Consideration for Listing Regulations, including a new procedure for missed renewals.

If you are already in the PVG Scheme on 1 April 2026 for a given type of regulated role, you count as an existing member. Your new five‑year clock does not backdate; it starts on the day the Scottish Ministers write to confirm it. Keep that letter or email safe, because it sets your renewal date for that role type and will help your school, college or placement office plan ahead.

What happens to cases already in the system? If a court sent prescribed information about someone before 12 January 2026 and a final decision wasn’t made by that date, Ministers will continue under a saved version of section 11 of the 2007 Act, updated to the newer ‘regulated role’ wording. If someone was being considered for the children’s list under the old section 11(2) but does not do a regulated role with children, Ministers must write to say they are no longer considering listing. That letter is not a formal “not to list” decision and doesn’t carry that status.

You will notice the language shift from ‘regulated work’ to ‘regulated role’. For most of us, that means checking whether our post or placement counts as a regulated role with children, adults, or both. The definitions live in the PVG Act and schedules. The aim is clarity rather than an unexpected expansion of who needs PVG.

For organisations, spring 2026 is a compliance checkpoint. Map who currently holds PVG membership, record when each five‑year term begins once letters arrive, and refresh safeguarding handbooks to use the ‘regulated role’ terms. Build simple reminders for renewals so trainees, supply staff and volunteers are not caught out near expiry.

For individuals, add your PVG start‑date to your calendar the day you get the notice and set reminders well in advance of renewal. Ask your mentor or line manager who is tracking renewals and how fees are handled. If you change role type, check whether a separate five‑year period applies, as membership is tied to the role type you hold in the Scheme.

These changes were made on 13 November 2025 and laid before the Scottish Parliament on 17 November 2025, as recorded on legislation.gov.uk. The package also tidies up older cross‑references and revokes provisions that no longer fit the new system. The goal is simple: keep PVG records fresh, make renewal behaviour clear, and ensure that where someone keeps working in a regulated role without renewing, there is a fair process with notice and a chance to respond. For learning settings, that clarity supports safer planning and smoother placements.