If you work for yourself as a counsellor or psychotherapist, a register, agency, school or client may ask you for a criminal record check. In England and Wales you do not need a DBS certificate to start practising. Whether you can be asked for one depends on who your clients are and how they come to you. In Scotland, a regulated role carries a legal requirement to join the PVG scheme, covered below.
Until 21 January 2026, a self-employed person could apply only for a Basic check. From that date, you can apply for an Enhanced check yourself if your role is eligible. The steps in this section cover England and Wales. Scotland and Northern Ireland use their own schemes, covered below.
Work out which check your role is eligible for
Not every counsellor works in a regulated activity. The table shows the checks you can be asked for, based on your client group and how clients reach you.
A direct referral means a regulated healthcare professional, such as a GP or psychologist, refers clients to you and you work under their direction. A client who mentions that their GP suggested counselling, and then books with you themselves, is not a direct referral.
If you see children, count the days. Giving advice or guidance to children on more than 3 days in any 30-day period is regulated activity with children, however the appointments are made. If none of the rows fits your practice, you can apply only for a Basic check.
If a person is barred from working with children or adults, it is an offence for them to do regulated activity with that group. An Enhanced check with a barred list check shows whether you are barred.
Apply for an Enhanced check through an umbrella body
You cannot apply to the DBS directly for an Enhanced check. You apply through a DBS umbrella body. The DBS holds a list of umbrella bodies that process checks for self-employed people.
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1. Confirm your role is eligible
Match your client group and referral route to the table above. Read the DBS guidance on eligibility for healthcare roles if you are unsure.
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2. Check whether an organisation should apply for you
If you work under contract for an agency, clinic or school, ask whether it applies on your behalf under its own policy. Apply yourself only if it does not.
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3. Choose an umbrella body
Use the DBS list of umbrella bodies and filter for those that process checks for self-employed people and personal employees.
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4. Tell the umbrella body what you do
Describe your client group and how clients are referred. The umbrella body confirms which check your role is eligible for.
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5. Complete the application and prove your identity
The umbrella body guides you through the form and the identity checks. You pay the DBS fee and the umbrella body's own administration fee.
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6. Keep your certificate
The DBS posts the certificate to you. Show it to the register, agency or client that asked for it. You can also join the DBS Update Service using your application reference number.
Umbrella bodies set their own administration fees, so compare them before you choose.
Apply for a Basic check
Anyone can apply for a Basic check, including a counsellor whose role is not eligible for an Enhanced check. If an umbrella body tells you that your role is not eligible, apply for a Basic check instead.
Checks in Scotland and Northern Ireland
The DBS does not cover Scotland or Northern Ireland. If you practise in either nation, use the scheme that applies there. Wales uses the DBS, so the steps above apply to you.
If something goes wrong
The common problems with a self-employed application, and what to do about each:
- the umbrella body says your role is not eligible, so apply for a Basic check and tell the register or agency that asked
- an agency or clinic has asked for a certificate, so ask whether it applies on your behalf before you pay for your own
- you start seeing children, so check the table again because the check you can ask for changes
What next
A criminal record check is one step in setting up a practice. Follow the whole path in Start a counselling or psychotherapy practice.
Your client group also decides whether a planned duty to report suspected child sex offences will reach you. For that and the other disclosure duties, see Client notes, confidentiality and disclosure for counsellors. Read Counsellor and psychotherapist registration rules to check which titles and registers apply to you.
If you take on staff, you become an employer and your duties change. See DBS checks for employers.
Legal basis
Primary legislation and key regulations
Related Guvnor guides
Start a counselling or psychotherapy practice
Client notes, confidentiality and disclosure for counsellors
Counsellor and psychotherapist registration rules
DBS checks for employers
Official guidance
DBS checks for self-employed people and personal employees (opens in a new tab)
GOV.UK
DBS eligibility guidance: healthcare roles (opens in a new tab)
GOV.UK
Request a basic DBS check (opens in a new tab)
GOV.UK
Apply to join the PVG scheme as a self-employed person (opens in a new tab)
mygov.scot
AccessNI checks for self-employed people (opens in a new tab)
nidirect
Safeguarding Vulnerable Groups Act 2006 (opens in a new tab)
legislation.gov.uk
Disclosure (Scotland) Act 2020, section 73 (opens in a new tab)
legislation.gov.uk