Regulated activity is work a barred person must not do. It's a criminal offence for a barred person to do it, and for an organisation to knowingly allow them to. Getting the right level of DBS check for a role, including a check of the Children's Barred List where required, is central to that system working.

Screen productions often engage people who work closely with children only for the length of a shoot, and who are supervised by someone more senior (for example an assistant chaperone working under a lead chaperone, a workshop assistant supporting a lead tutor, or a trainee supervised by a qualified safeguarding lead). Many of these roles currently rely on the supervision exemption to justify a standard Enhanced DBS check without a Children's Barred List check. Because screen work is typically concentrated into short, intensive blocks, roles like these can easily cross the frequency threshold that now brings them into regulated activity, even though the person is closely supervised throughout.

Currently, someone who teaches, trains, instructs, cares for, or supervises children often enough, or overnight, is not supplying a regulated activity if someone else who is in regulated activity supervises them sufficiently. From 1 September 2026, that supervision exemption no longer applies. If the work is done often enough, or overnight, the person is in regulated activity regardless of how well supervised they are.

“Often enough” means more than 3 days in any 30-day period. “Overnight” means once, between 2am and 6am.

A few examples show how this plays out in a production context:

Before 1 September 2026, productions and screen businesses that engage people to work with children should:

• Identify roles where someone teaches, trains, instructs, cares for, or supervises children and is currently treated as exempt from regulated activity because another person supervises them. This includes chaperones, tutors, workshop leaders, welfare officers, and runners or assistants assigned to child cast or young participants.
• Check whether each role meets the frequency or overnight test across a typical production block, not just a single day. A short but intensive shoot schedule can cross the “more than 3 days in 30” threshold quickly.
• Check whether the person's existing DBS certificate includes a Children's Barred List check. If it doesn't, and the role will be in regulated activity from 1 September 2026, a new Enhanced DBS check with Children's Barred List information should be requested.
• Update recruitment, casting, and safeguarding processes, including your safeguarding policy and any chaperone or child welfare procedures, so they reflect the change from 1 September 2026.
• Re-check DBS eligibility whenever a person's role changes, or the way it's carried out changes, since that can move a role in or out of regulated activity.