Introduction
In April 2025 the DBS announced new manual ID verification guidance.
This document is intended to outline the significant changes to ID verification. Please note, this document is not exhaustive, and we strongly recommend you also read the DBS issued guidance:
- Standard or Enhanced Checks: ID checking guidelines for Standard or Enhanced DBS check applications from 22 April 2025
- Basic Checks: Basic check ID checking guidelines from 22 April 2025
What are the ID Verification changes?
- The DBS have provided more guidance around how to view documents, making it easier for ID checkers to comply with requirements. Example scenarios have been provided in the guidance linked above.
- There are changes to the process for checking identity virtually.
- There is no longer a different route for non-UK nationals to use. All applicants can have their ID verified using the three-route process for Standard or Enhanced checks and two-route process for DBS Basic checks.
- There is no longer a requirement for one of the documents to have the applicant’s current address on it.
- There is now a requirement to store details of documents used to verify identities for 2 years.
- If in person ID verification is impossible, a record must be kept explaining the rationale.
- The DBS have added the e-Visa and Application Registration Card (ARC) to the list of Group 1 documents.
- The Group 1 passport validity has been updated. An expired UK passport can be used up to a maximum of 6 months post expiration.
- The DBS have added documents to the list of Group 2b documents, broadening the range of supporting documents applicants can use. The documents are:
- HM Armed Forces Veteran Card
- HMRC self-assessment or tax demand letters
- European Health Insurance Card (EHIC) or Global Health Insurance Card (GHIC)
Changes to the way ID must be viewed and validated
There are four ways in which ID documents can be viewed and validated. One way is through an approved Digital Identity Service Provider (IDSP). If you choose not to use the approved IDSP route, or the digital verification fails, you must then revert to manual ID verification.
Digital ID Verification
Following the implementation of the new DBS ID Guidance, we are pleased to announce that we will now be offering a Digital ID Verification route in the EmploymentCheck System which will be available to use from 29 September 2025. EmploymentCheck have partnered with Yoti as their Digital Identity Service Provider (IDSP).
This enhancement offers a faster, more convenient experience for applicants while helping your organisation save valuable time and resources. By removing the need for in-person ID checks, you can streamline your onboarding process, reduce scheduling challenges, and maintain full compliance with a secure and user-friendly solution.
When creating a Basic, Standard, or Enhanced application, you’ll now have the option to enable Digital ID Verification. If you select ‘Yes’, the applicant will complete their application form as usual. Once completed, they’ll be prompted to download the Yoti app, enter their details, and upload their ID securely. After completing this step, the applicant will return to the EmploymentCheck system to confirm submission. If the digital ID check is successful, it will be sent straight to our Safer Recruitment team for peer review. If the ID verification is unsuccessful, you’ll be notified and guided to revert to the manual ID verification route.
Manual ID Verification:
You must use option one unless it is impossible to have a face-to-face appointment with the applicant. The DBS have included examples of what constitutes as impossible in the DBS guidance. If you are unable to use option one the reasons need to be recorded and option two can be considered. If option two is impossible the reasons must be recorded and option three can be used.
Option 1: The ID check should be done in person, allowing the ID checker to view physical documents, eVisa or digital PASS card in the presence of the individual.
If you cannot use option 1, please consider using Digital Identity Verification before considering option 2.
Option 2: The ID checker can conduct the ID check via video link. In these circumstances the ID checker must be in possession of the physical ID documents. These can be posted to the ID checker in advance of the virtual call. Any risks identified when using live video must be assessed and mitigated by you. You must not rely on the inspection of the documents via a live video link, or by checking a faxed or scanned copy of the document.
Option 3: The ID Check can be completed via video link without the ID checker being in physical possession of the ID documents. The details of documents must be recorded and stored at the time of the video link ID check. The documents must be presented to the ID checker on the first day of employment. The ID checker must record the date the ID check was completed in person and cross reference with the details recorded from the video link ID check. If there are any discrepancies the DBS check may be invalid.
If option two or three is used, you must keep a record of why the previous option/s were impossible. You will be able to record this in EmploymentCheck. The rationale must be specific to the individual ID verification, it is not acceptable to default to the use of options two or three. The reason will be saved against the application and may be subject to DBS Audits. You should also consider using digital identity verification.
Data retention change details
There is now a requirement to retain records of identity verification documents for a minimum of 2 years. As of 29/09/2025 the data retention period must be extended to 24 months to comply with DBS guidelines.
As part of their compliance checks, the DBS may request evidence of the documents used for ID verification. These can be stored as copies of physical documents or as PDF versions of eVisas. If storing copies is not possible, you must record the following details:
- document type
- country of issue
- any expiry date
- any reference numbers
- notes if there were any discrepancies discussed as part of the ID verification process.
To support this requirement, EmploymentCheck will introduce additional document detail fields to Group 1, 2a and 2b documents in line with the updated guidance.
Changes to EmploymentCheck
EmploymentCheck system changes
- Digital ID option will be added
- A method of recording the ‘option’ used to verify the identity of the applicant including reasons why the selected ‘option’ was used will be added.
- Group 1, 2a and 2b document lists will be updated.
- Additional document detail fields will be added to Group 1, 2a and 2b documents in line with the updated guidance to support the data retention changes.
- The default NI Number selection will be changed to ‘Yes’ for DBS Basics.
- Applicants will be able to enter their Passport and Driving Licence details which would then be presented to the ID Verifier to confirm.
- The non-UK national route will be removed.
When will these changes be effective?
These changes will go live in EmploymentCheck from 29 September 2025.
New user guides
We are currently in the process creating user guides for Digital ID, and are updating our existing EmploymentCheck guides to ensure these reflect the new system changes. These will be available to download from 26/09/2025. A link will be sent to existing customers.
Changes to fees
As per clause 10 of our Customer Agreement, Devon County Council may review and make amendments to our agreement as required, with written notice. We are notifying all existing customers of the following revisions:
We are making changes to our fees in accordance with clause 3.1 of our Customer Agreement. Further information is provided below.
Please be informed that effective Monday 29 September 2025, we will be increasing our handling fees by £2.15 (per application) for Basic, Standard and Enhanced DBS applications.
We understand that price changes can be challenging, but we want to reassure you that this adjustment reflects a significant improvement to our service. In line with the latest DBS ID Verification Guidance, we’ve introduced Digital ID Verification – a secure, convenient option that streamlines the ID Verification process by speeding up the process for applicants and reducing the time and resources your organisation spends on manual checks. This enhancement ensures full compliance while delivering a faster, more efficient experience for everyone involved, providing real value for your investment.
Next Steps
In response to the updated guidance, we recommend that you review any areas that may be affected by these changes, including but not limited to:
- Internal processes relating to ID verification
- Email templates sent to applicants referring to ID verification
- DBS/Safeguarding policies
- Data Retention policies
Now is a good time to consider what changes may be needed so you can plan effectively for the implementation of the new guidance and system changes.
Support
Whilst we are unable to make organisational or policy decisions for you, our team are available to support you in understanding these changes. Please be mindful that following this updated guidance, we are likely to be busier than usual. Your patience is appreciated.
Email: humnres.corporaterecordsdisclosuresecure-mailbox@devon.gov.uk
Phone : 01392 383000 (ask for ‘Safer Recruitment’)