The cost of the Update Service will remain the same at £13 per year. 

 Basic DBS checks are applied for by the candidate themselves but an individual is not allowed to apply for their own Standard or Enhanced DBS check.

The individual is not allowed to apply on their own for a Standard or Enhanced DBS check, their employer must countersign the application but can only do so if they’re registered with the DBS. However, an employer can only register with the DBS if they do 100 or more checks per year. If the employer does not anticipate that and cannot explain to the DBS how they are going to meet the 100 or more checks per year then the employer has to use a DBS umbrella organisation to apply for the checks on their behalf.

If an employer does use a DBS umbrella organisation, the likelihood is that under the contract between the DBS umbrella organisation and the employer, the DBS umbrella organisation will charge the employer an amount on top of the cost of the actual check as their fee for processing on the employer’s behalf. It is likely that an employer will charge this total amount back to the individual. The potential problem here is that an employer may be contractually bound by those charging terms for a certain period and the DBS umbrella organisation may not be willing to change those terms to reflect the reduction in the charge for the checks. The employer will most likely want to keep the charges the same to the individual so that the employer isn’t out of pocket but naturally an individual is probably going to expect that the fee they have to pay to their employer is going to reduce in line with the reduction in cost of each check.

If you are an employer, it may be a good idea to contact your DBS umbrella organisation ahead of 1 October 2019 to try and negotiate a reduction in your fees to reflect the reduced charge of DBS checks. It would also be a good idea to speak to them about any applications that are pending prior to 1st October 2019. Is the DBS umbrella organisation going to charge the higher fee if an employer sends over a check prior to the changes but that check application isn’t actually sent to the DBS until after the 1st October 2019? Or is the DBS umbrella organisation going to honour the changes and charge the appropriate fee depending on the date the application is actually sent to the DBS?

As a Recruitment businesses we will need to ensure we have the answers to those questions so that we can comply with our obligation under regulation 13 of the Conduct of Employment Agencies and Employment Businesses Regulations 2003 to inform work-seekers of any services provided by third parties and the cost of those services e.g. in this case DBS checks and the cost to the work-seeker.