FR-11 Response Accepted in Part AI-assessed

Extend Disclosure Regime Overseas

Recommendation

The Inquiry recommends (as originally stated in its Children Outside the United Kingdom Phase 2 Investigation Report, dated January 2020) that the UK government introduces legislation permitting the Disclosure and Barring Service to provide enhanced certificates with barred list checks to citizens and residents of England and Wales applying for: work or volunteering with UK-based organisations, where the recruitment decision is taken outside the UK; or work or volunteering with organisations based outside the UK, in each case where the work or volunteering would be a regulated activity if in England and Wales.

Published Evidence Summary
The following publicly available evidence relates to this recommendation:
According to the UK Government's formal response, it accepted the need to strengthen disclosure arrangements for individuals working with children overseas, taking into account the Bailey Review published in April 2023. The Government stated in April 2025 that it aimed to enable those making decisions overseas to have access to DBS barred list data by 2026, in collaboration with ACRO Criminal Record Office and the DBS. However, according to Professor Alexis Jay's statement to the Home Affairs Committee in January 2025, none of the 20 final report recommendations had been implemented as of December 2024.
How was this assessed?
Assessed by gemini-2.5-flash on 19 Mar 2026
Checked data held on this site (government responses, progress updates, independent evidence)
External sources searched: www.gov.uk, www.legislation.gov.uk, hansard.parliament.uk
Jurisdiction
England
Section Reference
K.4
Response
Accepted in Part
Accepted in Part UK Government
22 May 2023

We accept the need to review whether disclosure arrangements can be further strengthened for those working with children overseas, and we will consider the scope of further strengthening the regime, taking into account the findings of the Bailey Review of the Disclosure and Barring Regime published in April 2023.

Read Full Response
Progress Timeline
Official Report
08 Apr 2025

Enabling overseas decision-makers to access DBS barred list data. Implementation expected by 2026.

Published Evidence

Published assessments of implementation progress from inspectorates, select committees, official progress reports, and other sources. Check the source type badge to see whether each assessment is independent or government self-reported.

No Meaningful Progress
21 Jan 2025
Home Affairs Select Committee Select Committee

Professor Alexis Jay told Home Affairs Committee that £187m was spent on IICSA and "to date none of its final recommendations had been implemented." Called for "full implementation" saying "get it done."

View detailed findings

As of December 2024, none of the 20 final report recommendations had been implemented. The previous government's response was described by Prof Jay as "very weak and, at times, apparently disingenuous."

Home Affairs Committee hearing, 21 January 2025 View Source
Source
Inquiry IICSA
Report The Report of the Independent Inquiry into Child Sexual Abuse 20 Oct 2022
Responsible Bodies
UK Government Primary
Recommendation age 3.4 yrs
Last formal update 08 Apr 2025