What is a Charity Trustee and do they need a DBS Check?
If you're involved in running a charity – whether as a board member, volunteer, or part of the management team – you've likely come across questions about DBS Checks and who actually needs one. Charity trustees, in particular, often sit in a grey area when it comes to criminal record screening.
This article is here to clear things up.
We’ll explain exactly what a charity trustee is, when a DBS check might be required, and the different levels of checks available depending on the type of work your charity does. We’ll also explore what “regulated activity” means in practice – and how trustees can still be properly vetted, even if they’re not eligible for the highest level of DBS check.
Whether you're a trustee yourself or supporting one behind the scenes, understanding your safeguarding responsibilities is key to protecting your charity, its service users, and your own peace of mind.
What is a Charity Trustee?
A charity trustee is someone responsible for overseeing the running and direction of a charity. Trustees play a crucial role in making sure a charity is well-governed, financially sound, and staying true to its mission.
In most cases, trustees are unpaid volunteers – but the level of responsibility they carry is significant. According to the Charity Commission, trustees have six main duties, including acting in the charity’s best interests, managing resources responsibly, and ensuring the organisation complies with the law.
Trustees don’t usually get involved in the day-to-day delivery of services. Instead, they set the strategy, approve budgets, and make key decisions about staffing, safeguarding, and risk. That said, in smaller charities, trustees might also wear multiple hats – stepping into operational roles when needed, which can sometimes change their eligibility for DBS checks.
Understanding the scope of a trustee’s duties is essential, because it directly affects whether or not they’re eligible (or legally required) to have a criminal record check.
Do Charity Trustees Need a DBS Check?
The short answer is: it depends.
Charity trustees aren’t automatically eligible for a DBS check just because they hold a trustee role. Whether they need one comes down to what type of work the charity does, and whether the trustee is personally involved in what’s known as regulated activity.
In most cases, trustees who only perform governance duties (such as attending board meetings, overseeing finances, or setting strategic direction) are not eligible for an Enhanced DBS check with barred list information.
However, even when a DBS check isn’t mandatory, many charities still choose to carry out some form of background screening for trustees. This helps to protect the organisation’s reputation, assure funders, and demonstrate a commitment to good governance and safeguarding.
Whether a charity trustee needs an Enhanced DBS check often hinges on one key term: regulated activity. If a trustee also takes on a more hands-on role – for example, helping deliver services to children or vulnerable adults – this would potentially be classed as carrying out regulated activity. That’s when a higher level of check becomes a requirement.
Regulated activity is a legal definition used by the Disclosure and Barring Service (DBS) to describe certain types of work with children or vulnerable adults that trigger eligibility for higher-level DBS checks, including checks against the relevant barred lists.
Regulated Activity with Adults
This includes tasks such as:
Providing personal care (e.g. washing, dressing, feeding)
Assistance with finances or shopping due to age, illness or disability
Helping with medication
Transporting adults to receive health or personal care services
If a trustee personally delivers any of these services – even as a volunteer – they’re likely to be engaging in regulated activity with adults.
This is not a comprehensive list and you can view the full guidance for Enhanced DBS Checks for the Adult Workforce here.
Regulated Activity with Children
For children, regulated activity includes:
Teaching, training or instructing children
Supervising children unsupervised and regularly
Caring for or driving children as part of the charity’s services
Again, if a trustee is actively doing any of these tasks, they may fall into the scope of regulated activity.
It’s important to stress: overseeing services that involve regulated activity isn’t the same as carrying them out. Most trustees, unless they double up as frontline staff or volunteers, won’t meet the threshold for a barred list check – but some will.
When is an Enhanced DBS Check with Adult Workforce and Barred List Required?
If a charity trustee is directly involved in regulated activity with adults, they will need an Enhanced DBS Check with Adult Workforce and a check of the adults’ barred list.
This level of check is only appropriate when the trustee is personally delivering services that fall under the definition of regulated activity – such as:
Assisting adults with eating, washing, dressing or going to the toilet
Managing or handling finances on behalf of adults who can’t do so themselves
Administering medication
Driving adults to or from healthcare or day care settings, on behalf of the charity
These roles are considered high risk because they involve a high level of trust and direct support. If a trustee is only overseeing these activities as part of their governance responsibilities – for example, reviewing safeguarding policies or signing off budgets – they won’t be eligible for barred list checks.
However, although not technically classed as regulated activity, any person who is managing an individual who is carrying our regulated activity with vulnerable adults will be eligble for an Enhanced DBS Check against the Adult Workforce without a barred list check.
When is an Enhanced DBS Check with Child Workforce and Barred List Required?
As mentioned, all trustees at a childrens charity are entitled to an Enhanced DBS Check. However, only trustees who are directly involved in regulated activity with children will need an Enhanced DBS Check with the Child Workforce selected and a check of the children’s barred list.
This applies if a trustee’s role includes:
Teaching, training, or instructing children (e.g. leading youth workshops)
Supervising children on a regular, unsupervised basis
Providing personal care to a child due to age, illness or disability
Driving a vehicle solely for the purpose of transporting children as part of the charity’s work
To meet the legal definition of regulated activity with children, the trustee’s involvement must typically be both frequent (once a week or more, or four times in a 30-day period) and unsupervised.
Trustees who simply oversee services that support children – such as signing off safeguarding policies, reviewing project reports, or fundraising for child-focused initiatives – do not meet the threshold for this type of check.
However, anyone who is a trustee of a charity that is specifically for children is eligible for, and needs, an Enhanced DBS Check against the Child Workforce without a barred list check.
As always, it’s not about job titles – it’s about the actual, hands-on duties being carried out. If those duties bring the trustee into unsupervised, regular contact with children, a full Enhanced DBS with Child Workforce and barred list check is absolutely necessary.
Using Full Spectrum Screening to Safeguard Your Charity
Even when charity trustees aren’t eligible for an Enhanced DBS check, it doesn’t mean thorough safeguarding checks should be skipped altogether. That’s where full spectrum screening comes in.
At Personnel Checks, we believe trustees should be held to the same high standards of trust, accountability, and due diligence as those working on the front line. After all, trustees are responsible for financial oversight, strategic decision-making, and – crucially – safeguarding governance. That means your recruitment process should go beyond just DBS eligibility.
Full spectrum screening is our approach to offering a broader, risk-based check that can be tailored to suit a trustee role. It can include:
Standard DBS Checks (if eligible)
Identity verification
Sanctions and watchlist checks
Adverse media checks
Right to work (where applicable)
Character or reference checks
It’s a proactive way for charities to demonstrate due diligence and maintain public trust – even if trustees don’t meet the legal threshold for barred list checks. It also reassures donors, regulators, and beneficiaries that your board takes safeguarding seriously at every level.
Trustees might not always be on the front lines, but they’re responsible for setting the tone from the top. A comprehensive screening programme makes sure that the tone is one of safety, accountability and integrity.
If you’re unsure about eligibility or want help building a safer recruitment process for trustees, our team is here to guide you. You can give us a call on 01254 355688 or drop us a message via our contact form here.