DBS Launches Updated Manual ID Guidance for Basic, Standard, and Enhanced DBS Checks

The Disclosure and Barring Service (DBS) has released refreshed manual identity (ID) verification guidance for employers and applicants involved in Basic, Standard, and Enhanced DBS checks. The updated guidance, launched on 22 April 2025, is designed to simplify and standardise how identity is confirmed during DBS applications, benefiting both organisations and individuals.

This update marks a significant move towards clarity, inclusivity, and flexibility in the DBS checking process—especially important for employers, legal representatives, and HR professionals who manage or oversee recruitment and vetting procedures. At Parachute Law, we understand how essential it is to remain compliant with these ever-evolving procedures, so let’s break down what’s new, what’s changed, and what you need to know.

Why Has the DBS Guidance Changed?

The DBS plays a critical role in supporting safer recruitment across the UK by issuing criminal record checks that help employers make informed decisions. One of the key elements in this process is the verification of a person’s identity, which must be done accurately and consistently to ensure the integrity of the checks.

Over time, feedback from employers, registered bodies, and applicants indicated that the previous ID guidance was somewhat fragmented, particularly when it came to dealing with non-UK nationals or specific document combinations. There was also a growing demand for more inclusive and technologically relevant ID documentation, such as digital immigration records and health cards.

In response, the DBS has modernised its manual ID verification guidance to:

• Provide greater consistency for all applicants, regardless of nationality.
   
• Offer a broader range of acceptable documents.
   
• Remove redundant or unnecessary address requirements.
   
• Include clear examples to help organisations apply the guidance correctly.
   

Transition Period: What You Need to Know

While the new manual ID guidance came into effect on 22 April 2025, the previous version will remain valid until 1 November 2025. This transitional period gives employers, Registered Bodies, and Responsible Organisations time to review and adapt their internal systems and workflows to the updated requirements.

If your organisation handles regular DBS applications, especially for sectors such as education, healthcare, or legal services, this is the ideal time to update your ID verification protocols, train relevant staff, and inform your applicants of the changes.

Key Changes to the Manual ID Guidance

Let’s explore the key updates in detail and what they mean in practice:

1. Unified ID Routes for All Applicants

One of the most significant updates is that non-UK nationals are no longer subject to separate ID verification routes. Previously, there were additional steps and conditions depending on an applicant’s immigration status or country of origin.

Now, all applicants can follow the same standard three-route process, which removes unnecessary complexity and promotes equality in the verification process. This streamlining should reduce administrative burden and confusion for HR departments and compliance teams.

2. Address Requirement Removed from ID Documents

Previously, one of the ID documents submitted had to show the applicant’s current address, which often created issues—particularly for people who had recently moved, lacked formal bills or letters, or lived in temporary accommodation.

With the new guidance, there is no longer a requirement for any ID document to include the applicant’s address. This change will make it significantly easier for many individuals to pass the ID verification stage and proceed with their DBS checks without delay.

3. Expanded List of Acceptable Documents – Group 1 and 2b

The range of documents that can be used for ID verification has been widened, with additions made to both Group 1 (primary identity documents) and Group 2b (supporting documents).

New Group 1 documents include:

• e-Visas (electronic immigration status verification)
   
• Biometric Residence Permits (BRP)
   
• Application Registration Cards (ARC)
   

These additions reflect the UK’s move towards digital immigration records and will be especially helpful for applicants with settled status, refugee status, or work visas.

New Group 2b documents include:

• HMRC Self-Assessment or Tax Demand Letters
   
• European Health Insurance Card (EHIC) or Global Health Insurance Card (GHIC)
   

By expanding the list of supporting documents, the DBS is acknowledging the diversity of documentation people may reasonably have. This update also supports those who may not have utility bills or banking statements but are still clearly identifiable and eligible for employment.

4. Clearer Guidance on Viewing and Verifying Documents

The updated guidance includes additional detail on how to view and assess documents during ID verification. This supports Registered Bodies and organisations in conducting compliant, fraud-resistant checks and reduces the likelihood of rejection or delay.

The guidance highlights:

• How to identify official documentation.
   
• Tips for spotting forged or altered documents.
   
• Best practices for physical and digital document viewing.
   

This is particularly useful for remote or hybrid recruitment, where face-to-face document review may not be feasible.

5. Example Scenarios Provided

To aid understanding, the DBS has included illustrative scenarios in the updated guidance. These examples show how different combinations of documents may be used in practice, offering clarity for both new and experienced ID checkers.

For example, scenarios include:

• UK nationals without passports or driving licences.
   
• Overseas applicants with digital-only immigration documents.
   
• Self-employed workers using HMRC documents in place of utility bills.
   

Such illustrations are invaluable when advising clients or processing applications where standard documents may not be available.

Implications for Employers, Legal Advisers, and HR Professionals

If you work in legal services, education, healthcare, social work, or any field requiring criminal background checks, this change is particularly relevant. Here are some implications to consider:

For Employers and HR Teams:

• Update internal DBS check procedures to reflect the new documentation options.
   
• Re-train staff on how to conduct manual ID checks compliantly.
   
• Review onboarding templates and ID checklists given to new employees.
   
• Notify current applicants of the updated guidance to avoid confusion.
   

For Legal Advisers and Compliance Officers:

• Advise clients (especially SMEs and charities) on how these changes may affect their hiring processes.
   
• Ensure that data protection practices are still being followed when handling personal identification data.
   
• Help Registered Bodies prepare for the transition deadline of 1 November 2025.
   

For Applicants:

• Prepare your documents ahead of time and make use of the expanded list if needed.
   
• Understand that your current address no longer needs to appear on submitted ID.
   
• Review the illustrative scenarios if unsure which documents are acceptable.
   

Where to Access the Full Guidance

The updated ID checking guidance documents are now available online through official government resources:

• Basic DBS checks:
  Visit the Basic check guidance and policies page on GOV.UK
   
• Standard and Enhanced DBS checks:
  See the DBS ID checking guidelines page on GOV.UK
   

These resources contain the full list of acceptable documents, explanation of the three-route process, and helpful examples for different types of applicants.

Final Thoughts: A Step Forward in Streamlining and Inclusivity

At Parachute Law, we view these changes as a positive step towards more inclusive, practical, and efficient ID verification standards. By removing barriers for non-UK nationals, relaxing outdated address requirements, and expanding the document list, the DBS is aligning its practices with the realities of modern life.

Whether you're an employer navigating recruitment, a legal adviser supporting compliance, or an applicant preparing for a new role, this update will likely make your experience with DBS checks faster, clearer, and more flexible.

To stay compliant, we recommend familiarising yourself with the updated guidance now, well before the old rules are phased out on 1 November 2025.

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Important Notice

This guide is provided for general information purposes only and is not intended to be relied upon as legal advice. While we’ve taken care to ensure the information is accurate and up to date as of the time of writing, it does not take into account your personal circumstances and should not be used as a substitute for tailored legal advice. Reading this guide does not create a solicitor-client relationship between you and Parachute Law. We accept no liability for any loss or damage arising from reliance on this guide. If you need legal advice about your specific situation, we encourage you to get in touch with us for a confidential consultation. We're here to help you understand your options and take the next step with confidence. Contact us at: thelegalteam@parachutelaw.co.uk