New Disclosure Scotland Act 2020 Brings Key Changes to PVG Scheme

The implementation of the Disclosure Scotland Act 2020 on 1st April 2025 will introduce changes to the Protecting Vulnerable Groups (PVG) scheme, impacting sports clubs, voluntary organisations, and training centres across Scotland.

RYA Scotland and RYA are supporting clubs by working through those changes to produce pragmatic guidance. This has been sent to affiliated clubs and associations as well as training centres today and will be updated as we learn more.

What’s Staying the Same?

Many aspects of the PVG scheme remain unchanged. Individuals in regulated roles will still need PVG membership, and affiliated organisations can continue to apply for free volunteer checks through Volunteer Scotland Disclosure Services (VSDS). The term ‘regular’ remains undefined, but any role specifically targeting children or protected adults is more likely to require a PVG check. 

Key Changes

• Mandatory Membership Before Starting a Role – Individuals must be PVG members before undertaking regulated roles; trial periods will no longer be allowed.

• Grace Period – A transition period until 30th June 2025 allows organisations to process applications for newly regulated roles. From 1st July, individuals without an approved PVG check must cease their role until membership is confirmed.

• Five-Year Renewals – Starting April 2026, PVG scheme membership will move from lifetime validity to a five-year renewal cycle.

• Expanded Definitions – The act now defines ‘protected adults’ as individuals receiving health or care services due to disability, age, or vulnerability.

• Committee & Board Members – Those in positions of responsibility, such as trustees, commodores, and junior captains, may now require PVG membership if their role involves power or influence over protected groups.

• External Trainers & Events – Organisations should look to verify that external instructors and event organisers comply with PVG requirements, even if they are self-employed. More guidance on this to follow.

Guidance for Clubs and Organisations

Organisations are urged to assess roles carefully to determine whether they meet the criteria for PVG checks. Decisions should be documented, and safeguarding policies updated to reflect any changes.

RYA Scotland will be hosting drop-in sessions in April, May, and June to answer queries – please get in touch for more details.

If you have any PVG queries, then please contact safeguarding@ryascotland.org.uk

RYA and RYA Scotland wish to remind organisations that while PVG checks play a crucial role in safeguarding, they should complement—not replace—robust recruitment and child/adult protection measures within organisations.

CEO Finlo Cottier comments “The changes to the PVG process brought in by the Scottish Government, are about improving the experiences of protected groups by ensuring that those who work with them are recruited safely and securely. Fundamentally RYA Scotland supports sailing and boating to be both fun and safe. The community of clubs and associations in Scotland already provide brilliant opportunities on the water week in, week out. It is our role to help them interpret and implement the new requirements in a pragmatic and supportive way.”

Further guidance can also be found using the following links:

Volunteer Disclosure Scotland Services (registering for PVGs and further advice)

Holding a position of responsibility 

Disclosure Scotland Guidance Tool 

PVG Scheme Regulated Roles Guidance 

Disclosure Scotland video on Regulated roles

Disclosure Scotland Act 2020– in particular Schedule 3