This page provides the latest information on the Disclosure (Scotland) Act 2020 and upcoming changes to the Protecting Vulnerable Groups (PVG) scheme.
We keep this page updated as new guidance becomes available. If you need tailored support, please contact the team at disclosures@volunteerscotland.org.uk.
Five-Year PVG Scheme Membership: Coming into Force 1 April 2026
Regulations laid in the Scottish Parliament confirm that the five-year PVG scheme membership will begin on 1 April 2026.
What organisations need to know
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Continue submitting PVG applications as normal.
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Do not change the frequency of applications now or after 1 April 2026.
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PVG members who joined before 1 April 2026 do not need to take any action at this stage.
Disclosure Scotland will:
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contact existing PVG members when they are due to move to the new five-year membership cycle
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manage the transition in phases
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work with VSDS to plan the requirements for this change
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release further details, which we will share with you as soon as they are available
In the meantime, all PVG members should ensure their personal details are up to date. Guidance on updating details is available on the Disclosure Scotland website.
For those joining the PVG scheme from 1 April 2026
Individuals who apply from this date will automatically enter the five-year membership. Renewal will be required every five years.
Examples:
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Andrew joins the PVG scheme on 2 April 2026.
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Renewal due: 2 April 2031
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Renewal reminder sent by: 2 January 2031
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Interested parties will be notified, but no action is required from them.
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Charlotte joins the PVG scheme on 31 January 2027.
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Renewal due: 31 January 2032
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Renewal reminder sent by: 31 October 2031
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Interested parties will be notified, but again, no action is required.
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Both Andrew and Charlotte must renew if they are carrying out a regulated role. If they stop and do not intend to return to regulated roles, they should tell Disclosure Scotland that they will not renew.
If they stop carrying out a regulated role after joining, they must notify Disclosure Scotland at dsupdate@disclosurescotland.gov.scot.
What Organisations Should Do Now
To help ensure that you only receive updates you are entitled to:
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Notify VSDS when a PVG member stops carrying out a regulated role for your organisation.
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You can do this by completing our Removal of Interest form.
This helps reduce unnecessary administration and supports accuracy in safeguarding updates.
Conditions on Scheme Members Under Consideration for Listing
The Disclosure (Scotland) Act 2020 provides Disclosure Scotland with new powers to impose temporary conditions on individuals being investigated for possible barring from regulated roles.
These conditions:
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will only be used when necessary
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will last only until a decision is made
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are designed to strengthen the existing safeguarding system
Because introducing these powers is complex, they will not come into force in 2025. Disclosure Scotland is continuing to work closely with key partners, including professional regulators.
Until these changes are live, the current safeguarding arrangements remain unchanged. Organisations must continue to:
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assess suitability based on the disclosure information they receive
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take steps to manage and mitigate any risks identified
More information will be provided as soon as it is available.
Application Turnaround Times
You can view:
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our current working-on dates on our website
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Disclosure Scotland’s latest performance statistics on their website
Service Level Agreements
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VSDS aims to process 90% of applications within 9 calendar days of receiving them.
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Disclosure Scotland aims to complete 90% within 14 calendar days after the applicant completes their link.
Some applications may take longer due to additional checks, often involving external agencies. These checks:
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are a legal requirement
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may be triggered by factors unrelated to the applicant
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rarely affect the outcome
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cannot be described in detail due to the processes of external organisations
Disclosure Scotland works closely with these agencies to support timely completion of the required checks.
Ongoing Updates
We will continue to share regular updates on the implementation of the Disclosure (Scotland) Act 2020 as further information becomes available from Disclosure Scotland.
If you have questions or need support, contact:
disclosures@volunteerscotland.org.uk
