Most of the Disclosure Act (2020) will be implemented on Tuesday 1 April 2025. While there is no decision regarding fee waivers and reductions yet (for more information, please see our Consultation Update article – linked for your convenience), on this date:

There will be different levels and types of Disclosures to choose from.
Regulated Work will become Regulated Roles and The Protecting Vulnerable Groups (PVG) scheme will become mandatory for those carrying out a regulated role with children and/or protected adults.
Applicants will have more control over their information. The disclosure process will include a requirement for applicants to share a copy of their disclosure with you, the organisation who requested the check, or to notify Disclosure Scotland that they will seek a review
An individualised approach to the disclosure of childhood offending and rights of review for convictions disclosed, to enhance fairness and proportionality. Applicants will be able to indicate their intent to review a Level 2 disclosure digitally.

To prepare for these changes, you should establish if your organisation offers regulated roles. Since the Disclosure Act includes replacing the concept of ‘regulated work’ with ’regulated roles’ as the basis for mandatory PVG scheme membership. It is expected that roles that are currently regulated work will also be regulated roles. However, the introduction of ‘regulated roles’ will bring new roles into the PVG scheme that are currently not regulated work, for example, football agents, talent scouts and certain hospice based roles that don’t currently qualify for PVG.

You can also notify Disclosure Scotland when a PVG scheme member stops doing regulated work, this is to comply with their data protection legislation and will prevent organisations receiving information to which you are no longer entitled. Once notified, Disclosure Scotland will then remove your organisation’s interest in the individual. The link to notify Disclosure Scotland has been provided for your convenience.

Volunteer Scotland are hosting regular ‘Act Information Sessions’ that will help groups understand these changes and answer any questions. To book these sessions, please visit the Volunteer Scotland Eventbrite.