Changes to CRB disclosure

New rules and legislation come into effect from September 2012 affecting identity checking and eligibility for criminal record disclosures. UKHCA Disclosure Service outline the changes and their implications for care providers.

Identity Checking


New identity checking rules introduced by the Criminal Records Bureau (CRB) limit the range of documents that can be used to prove the identity of disclosure applicants from 1st September 2012, and set up a three stage process for identity verification in England and Wales.

According to the CRB the intention of the new rules are to improve public protection, in particular, by making it more difficult for individuals to conceal criminal records by changing their name.

Some documents that were previously accepted for ID checking purposes, for example a UK NHS Card, are no longer acceptable. In addition, some documents have changed status, for example, an EU National ID Card is now in Group Two A, rather than Group One. The new three stage process must be undertaken for all applicants and relates to the type of ID documents that they can produce.

Applicants able to produce documents from the Group One list will be processed through Route One where the process remains unchanged. Applicants without any Group One documentation must have their ID checked through Route Two which involves producing three documents from Group Two and successfully passing an ID check by an external validation service. This will be organised by your registered body. Route Three should only be used after a Registered Body has fully explored with the applicant why their identity could not be successfully validated via Routes One or Two. The applicant will then need to produce a copy of their birth certificate and four documents from Group Two.

If the Registered Body is unable to validate the applicant's identity using Routes One, Two or Three, they should indicate this on the application form and return it to the CRB. The applicant will then be asked to give their consent to have their fingerprints taken in line with the current procedure. This may require attendance at a Police Station at an appointed time, and may delay the overall application process.

Care providers need to;

  • Familiarise themselves with the new lists of acceptable ID documents and what to ask for from applicants in each case.

  • Talk to their registered body about external validation services and any further information that may be required from the applicant as well as any additional charges that may be incurred.

To find out more about the new ID checking rules, visit UKHCA's Disclosure Service website. CRB disclosure eligibility

Some provisions of the Protection of Freedoms Act affecting the CRB disclosure system are due to come into force from 10th September. The changes include;

  • Repeal of the definition of a 'vulnerable adult' and 'controlled activity' and the introduction of a new definition of a regulated activity. (Anyone who provides physical assistance, prompts and supervises or trains and instructs an adult to eat or drink, go to the toilet, wash or bath, dress, care for their mouth, skin, hair or nails because of the adult's age, illness or disability, will be providing personal care and therefore engaging in regulated activity.)

  • Introduction of a more rigorous relevancy test for locally held police information and repeal of 'additional information'.

  • A new right to review through an independent monitor will be introduced for applicants.

  • Children under the age of 16 will no longer be eligible for a CRB check.

Providers need to;

  • Familiarise themselves with the new definition to ensure that they do not apply for a check on those ineligible to receive them.

  • Consider which positions would no longer be eligible for checks now that the 'controlled activity' category has been repealed.

For more information on the current changes, including the full definition of regulated activity and exemptions you can visit the Department of Health website.

For more information about UKHCA's online disclosure service, call 020 8288 1572 or email

For further information, please contact us on 020 8336 0099 or via email and don't forget to mention UKHCA. Alternatively, please visit our dedicated UKHCA page

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