11th August 2025

The Disclosure Act in Action: Progress, Challenges, and Ongoing Support

Back in April, when the Disclosure Act was enacted, we braced ourselves, but nothing quite prepared us for the sheer wave of activity that followed.

Organisations began contacting us to enrol as the legal requirement had come into effect. They had individuals in regulated roles who hadn’t been checked and individuals in positions that had now moved into the PVG scheme, an example of this is positions involving ‘power or influence’.

PVG scheme applications reached our highest-ever incoming volumes, both for new regulated roles and for roles that needed to be checked before the end of the grace period on 30th June. The demand on our training team to support organisations and help them navigate these changes was also at its highest.

It’s been a challenging few months, but also an incredibly energising one. One of the most significant changes in the legislation is the requirement for all individuals in a regulated role to join the PVG scheme. The scale of response has shown just how seriously the sector is taking this.

Now that the dust has (mostly) settled, we wanted to take a moment to reflect on what’s changed, what we’ve learned, and how we’re continuing to support you moving forward.

What are the key changes?

Here’s a quick recap of what the Disclosure Act has introduced:

Membership of the PVG scheme is now a legal requirement for those carrying out a regulated role.

The old ‘regulated work’ definition has been replaced by clearer ‘regulated roles.’

Application types have been simplified, and individuals have more control over their information via their online Scots Account.

Childhood convictions are treated with more fairness, and review rights are built into the process.

Disclosure Scotland can now impose conditions on PVG scheme members under consideration for listing.

A glance at our first 3 months with the Disclosure Act

Here are some interesting statistics comparing the first quarter of this year to the same period last year.

PVG scheme applications rose by 70%.

Enrolment of new organisation increased by 217%.

Training availability from our team grew by 27%, while the number of signatories trained surged by 206%.

These numbers speak volumes, literally and figuratively about the level of activity we’ve seen. But behind the data lies the real human effort of teams and organisations across Scotland.

What have we learned?

Customer Operations

On the lead up to the implementation of the Disclosure Act, we were inundated with PVG Application requests which naturally meant we were no longer able to meet our service level agreement (SLA). We’ll be honest, it’s been tough, but thanks to teamwork, close collaboration with Disclosure Scotland and some process efficiencies, we are slowly getting there.

Our agreed SLA is currently 9 working days, and we’re pleased to report a significant improvement, with applications now being processed within that timeframe. However, performance may vary depending on the volume of incoming requests and will continue to be monitored daily by our Customer Operations Manager, Claire Laurie.

Claire said: “We’ve been watching the numbers like hawks. We know how important timely processing is, and the team has really stepped up, even with the pressure.”

Interestingly, July brought a dip in incoming volumes. Is it the summer holidays? Or is this our new normal? Time will tell. Either way, we took this breathing space to streamline our internal processes, removing duplicate data entry tasks and shaving time off each application.

Enrolment & Assessment

Before the Disclosure Act, our enrolment volumes were relatively steady. That all changed overnight. One of the biggest surprises? School PTAs. They became our highest-enrolling group, something we hadn’t anticipated.

There was a lot of uncertainty in the sector, especially around whether PTA committee roles were regulated. Our training team worked closely with Disclosure Scotland and Connect to offer clarity. We learned a lot through those conversations, and from the groups themselves.

To help speed things up, we also launched an online enrolment application. This allowed organisations to self-assess their eligibility and roles, giving them more control and taking pressure off our admin team.

Training & Compliance

After implementation, it quickly became clear that one of the biggest challenges wasn’t just processing applications or managing enrolments; it was helping organisations understand how the new legislation applied to them.

We were inundated with support requests from organisations trying to determine how the changes affected roles within their teams. While we had been delivering Disclosure Act training throughout 2024 and into early 2025, the early sessions were broad overviews. Naturally, some questions remained unanswered as Disclosure Scotland was still finalising its guidance, particularly around the regulated roles criteria.

As new information became available, our team responded quickly by updating training materials, rewriting examples, and refining our FAQs to reflect the most current understanding.

“Planning the sessions in advance was key so we could manage team resources, know how many sessions were needed, and how many attendees we could support per session. We worked together to review points we were unsure of in the regulated roles criteria and collaborated closely with Disclosure Scotland on FAQs and organisation specific queries.” – Pauline Foley, VSDS Compliance & Training Officer

Feedback from organisations highlighted that the training had a significant impact, particularly in boosting confidence when assessing roles and determining when PVG scheme membership is required.

In July, 44% of signatories rated their knowledge as poor or not good prior to the training session. Following the session, 88% rated their knowledge as good or very good, and a further 6% rated it as excellent.

Participant feedback includes:

“The PowerPoint was very informative, and the materials provided beforehand were very insightful. Duncan was also very helpful at describing everything in detail and answering any questions.”
“The session was very helpful, and Wendy explained everything very clearly. We have benefited from the multiple training sessions offered to better understand the Act and all the legal requirements.”

One of the most common questions we received during these sessions was: “If an individual has a PVG scheme with another organisation for the same work group, can we use this when they volunteer with us?”

This is a great example of how details matter. According to the guidance:

Individuals must be a member of the PVG scheme for the group they will be working or volunteering with (children and/or protected adults).

The recruiting organisation must have received the PVG scheme result for the individual before they can start the regulated role, even if that individual is already a PVG scheme member with another organisation.

That kind of clarity has been invaluable, and it is why we continue to update our training and resource materials as new questions and situations arise.

What did we really experience behind the scenes?

Across enrolment, application processing, and training, the pressure was real. We had prepped, planned, and scheduled extra training and drop-in sessions, but nothing quite matched the volume of need we saw leading up to 1st April (and in the four months that followed).

There were evenings, weekends, and last-minute pivots. But our teams responded with incredible resilience. Whether they were launching new online tools, adapting on the fly, or answering hundreds of calls, they showed up, and kept showing up, to support the sector.

How will we continue to support you?

Our helplines remain open:

Monday–Thursday: 9:00am – 5:00pm
Friday: 9:00am – 12:30pm

We’re still busier than usual, especially with queries chasing enrolments and PVG results, but many answers can be found in our resource section on the website. If you haven’t checked it out yet, we strongly encourage you to do so. A few minutes there could save you a phone call (and help us focus resources where they’re most needed).

If you are looking for more support, you can drop us an email at disclosures@volunteerscotland.org.uk and one of our team will get back to you as soon as possible.

So, what now?

The most important thing for organisations is to make sure you’re compliant. If you’ve got someone in a regulated role, they can’t begin until you’ve seen their PVG scheme result. If you’re not sure if a role qualifies, just ask.

If you’re still feeling unsure, don’t worry, you’re not alone. Email us at disclosures@volunteerscotland.org.uk, and we’ll help you get where you need to be.

A final word…

Change is rarely easy, especially on this scale. But what we’ve seen so far has given us a lot of confidence. Organisations across Scotland are engaging, adapting, and stepping up to meet the new requirements. And we’re proud to be on this journey with you.