Protecting Vulnerable Groups (PVG) Scheme Changes
Published: 12/03/25
Starting April 1st, 2025, it will be a legal requirement for individuals to be members of the PVG Scheme to perform regulated roles involving children, protected adults, or both.
The Protecting Vulnerable Groups (PVG) (Scotland) Act 2007 came into being as a response to the Bichard Inquiry report that called for a registration scheme for all those who work with children and protected adults.
The PVG Scheme covers all kinds of regulated work and pharmacists take part in that regulated work in their role as responsible pharmacists.
The Scheme allows contractors to check that their pharmacists are not on any barred list by having them disclosed and their company name becomes listed as an ‘interested party’ on the pharmacist’s Disclosure Scotland file. If the applicant's status changes, the company as an "interested party" would be informed.
Following the amendment to the Disclosure (Scotland) Act 2020, which focuses on protecting the public, while balancing the need for people to move on from offending and also simplifying the process for disclosing criminal history information. It will make changes to disclosure checks, changes to the PVG scheme membership, give new powers to Disclosure Scotland and new powers for councils and integration boards.
From 1st April 2025, it will be a legal requirement for individuals to be a member of the PVG Scheme when carrying out a regulated role with children, protected adults, or both.
‘Regulated work’ will be replaced by ‘regulated role’. Roles which are currently included under regulated work, will also be regulated roles and work which is currently regulated, will remain regulated. However, the introduction of the ‘regulated role’ will bring new roles into the PVG scheme that are currently not regulated work. CPS has enquired with Disclosure Scotland the requirements for pharmacy technicians to be PVG’d and referred them to GPhC. As soon as this is defined we will communicate this out.
-
'Level 1' and 'Level 2' checks will replace the current basic, standard, enhanced and PVG disclosure levels
you'll be able to ask for an independent review of some disclosure content
you'll be able to explain the context for certain spent or childhood convictions before they're disclosed
The PVG scheme remains which is mandatory for people in regulated roles with children and protected adults or both.ion text goes here
-
Two new offences will come into force:
Anyone carrying out a regulated role to do so whilst not a member of the PVG scheme
Organisations to offer any type of regulated role to an individual unless they have received a Level 2 with PVG disclosure
This adds to the existing offences under the PVG Act. For example, it will continue to be an offence for an individual to seek, agree to do or carry out a regulated role if the individual is barred from working with children, protected adults or both. Similarly, organisations must also not offer a regulated role to someone who is barred from that type of regulated role
-
The current fees remain the same:
Basic Disclosure / Level 1 - £25
PVG Scheme Record / Level 2 (PVG) (Join) - £59
PVG Scheme Record / Level 2 (PVG) (Existing) - £18
-
Continuous monitoring of PVG Scheme members
Suitability updates on PVG scheme members to interested parties
Your duty to refer
Barred status applies across the UK
Organisation should notify Disclosure Scotland when a PVG scheme member stop doing regulated work with you
PVG Members should update Disclosure Scotland when there are any changes to their personal details
Future changes
As of 1st April 2026, the lifetime membership of the PVG scheme will be replaced by a time-limited scheme membership, with renewal required every five years. The transition period of existing scheme members to time-limited membership is being looked at by Disclosure Scotland in order to understand what is required with further information to be provided as soon as possible.
This application form has been adapted by CPS for you to complete and contains all the information that you need to send us. CPS will then process the application and submit to Disclosure Scotland. You should then receive an email from Disclosure Scotland with a link to complete your application. Once the changes come into effect on the 1st April this from will be updated to reflect.
If you have any enquiries, please get in contact with the team at pvg.enquiries@cps.scot.
Check out our Policy & PR Pharmacist, Sarah Scott, speaking to BBC Radio Scotland this morning about how people can manage their hay fever symptoms and access expert support through NHS Pharmacy First Scotland.