From 1 September 2026, Table Tennis England Removes the "Supervision Exemption" from DBS Checks

Six o'clock in the evening, Tuesday 29 September. An online webinar lasting exactly sixty minutes. The presenter is Kyhl Daly, Designated Safeguarding Officer at Table Tennis England. The topic sounds dry: the changes to DBS requirements, what they mean for clubs, and the wider picture of DBS in table tennis. Behind that dry title sits one of the largest legal shifts that grassroots sport in England has had to absorb in years.

To picture it concretely, walk into a village hall in southern England on any Saturday morning. Eighteen children aged seven to twelve, six folding table tennis tables, one adult organising the queue, and one coach standing in the corner watching. The person in the corner is the head coach, with a DBS check that has been in place for years. The person organising the queue is a new volunteer who joined last month and has never been through any screening at all. Under the old rules, that volunteer's role counted as "supervised", so a DBS certificate was not mandatory. From 1 September 2026, that gap closes.

That is the whole story, compressed into two dates. But the real story lies in what happens between those two dates, and in what table tennis clubs must do before the new season begins.

What DBS is, and why a table tennis body cares

The Disclosure and Barring Service, known as DBS, is the UK government agency responsible for criminal record checks and barred list checks. A DBS certificate is not a licence, not a qualification, not a certificate of merit. It is a record indicating whether a person has relevant criminal convictions, and whether that person appears on a list barring them from working with children or vulnerable adults.

There are four main levels. A basic check searches national criminal records only. A standard check adds the DBS barred lists but does not search the lists held by education and health regulators. An enhanced check adds local police records from the areas where the applicant has lived. An enhanced check with barred list check is the highest level and applies only to roles defined in law as Regulated Activity.

For a sport with thousands of grassroots clubs, that final level is the one that matters. And that is precisely where the legal definition becomes uncomfortably important.

Table Tennis England is the national governing body for table tennis in England. Its safeguarding team runs a dedicated DBS process, acting as an umbrella body that verifies identity and submits applications to DBS on behalf of member clubs. In table tennis, most activity involving children takes place at club level: junior coaching sessions, youth tournaments, holiday camps, weekend social sessions. The sport's volunteer structure has a particular characteristic: most club officials are older adults, unpaid, and frequently hold several roles at once.

One person can be treasurer, hall keyholder, and the person who drives two children home after training. Three roles, one person, and under the old legal definition only one of those three roles might have triggered a mandatory check.

Regulated Activity: the legal definition few people read to the end

Regulated Activity is the central concept of the whole system. For children, a person is engaged in Regulated Activity when they frequently teach, train, instruct, care for or supervise children, or work in a setting with children overnight, or manage those who do the above.

The word "frequently" is defined very precisely: once a week or more often, or four or more days in a thirty-day period, or overnight. A volunteer who helps at two sessions across an entire season falls outside. Someone present every Thursday evening through the winter falls inside.

There are evenings when I sit with numbers longer than with people, and I have never felt lonely in them. Definitions like this are the reason. They look like administrative text, but they determine who is allowed in a room with children and who is not.

The system covers two groups. The first is children under eighteen. The second is vulnerable adults, defined as people aged eighteen or over who need care or support because of health or disability. In table tennis the second group appears less often but does not disappear: rehabilitation sessions, programmes for players with disabilities, and social sessions involving adults who need support.

The supervision exemption: loophole or reasonable solution?

This is the part that needs to be explained slowly, because it is the root of the entire change.

For many years, English law contained a provision known as the supervision exemption. It stated that if a person worked with children but was always supervised directly, continuously and regularly by someone holding a DBS certificate, that person was not considered to be engaged in Regulated Activity. Not being in Regulated Activity, they did not need a DBS certificate.

The argument for the provision was simple: if someone already screened is always standing right there, the risk is controlled. Adding a second certificate is an administrative step that creates no additional real safety.

The argument against was equally simple: "supervision" in operational reality does not look like "supervision" on paper. In a hall with eighteen children, six tables, bouncing balls, laughter, and someone calling a parent to collect a child late, the head coach is present but cannot be beside everyone at once. One adult alone with one child for two minutes in the shoe area is an entirely normal situation, and also the situation in which every paper control is neutralised.

From 1 September 2026, the Crime and Policing Act 2026 removes the supervision exemption from the legal definition of Regulated Activity. Roles previously treated as supervised are now treated the same as unsupervised ones. The same level of check, the same obligation, the same consequence if it is missing.

One thing needs stating clearly to avoid misunderstanding. The Act does not say every volunteer at a table tennis club must hold a DBS certificate. It says that someone working regularly with children cannot avoid that obligation merely because someone else is standing nearby. This is a change of scope, not of nature.

What actually changes, and for whom

It helps to build a few concrete scenarios, because that is the only way to see the real impact.

Scenario one: a parent signs up to help at the junior session every Wednesday evening. They do not coach, do not set drills, they collect balls and keep score in internal matches. Previously, because a certified head coach was always in the room, they counted as supervised and needed no certificate. After 1 September 2026, because they attend once a week throughout the season, they count as frequent, and being supervised is no longer a ground for exemption. They need a DBS check.

Scenario two: a coach runs the beginners' group under the supervision of the head coach. Each session lasts two hours, attendance is weekly and complete. Previously supervised. After the change, mandatory. This is the group most affected in numbers, because beginners' classes concentrate the largest share of young and trainee coaches.

Scenario three: a club committee member handles logistics, does not work directly with children, but is present at every session to unlock, set up tables and lock up afterwards. They do not teach, train or care for children. Unlocking a hall does not automatically become Regulated Activity. But if that person regularly supervises children in the periods before and after sessions, the boundary blurs, and the committee needs to assess it themselves.

Scenario four: a volunteer driver takes a group of children to a regional tournament. Once a month, which is not frequent under the legal definition. This case most likely falls outside mandatory checks, yet it is exactly the kind of situation clubs need their own internal policy for, because a two-hour car journey with children is time in which nobody else is present.

Scenario five: a junior tournament manager responsible for assigning umpires and handling complaints across weekend events. They do not directly coach or care for children, but they manage those who do. Managing Regulated Activity is itself Regulated Activity. This is the group most often missed in club self-assessments.

Five scenarios, five different levels of risk, and one common thread: the decision sits with the club, not with Table Tennis England's head office. The governing body sets the process and provides the tools. Who needs a certificate, who does not, and who has actually been checked, is decided by whoever sits at the desk on Wednesday evening.

The webinar on 29 September: content and audience

This is why the online webinar on 29 September exists. Across sixty minutes, Kyhl Daly will set out the changes in regulations, how they affect individuals and the volunteers clubs work with, Table Tennis England's DBS processes, and the importance of the DBS check in safeguarding children in the sport.

The intended audience is stated clearly: Club Welfare Officers, members of club or league committees, and volunteers who work regularly with children. Those three groups map onto three different functions. The first carries responsibility for safeguarding policy. The second makes decisions and allocates resources. The third is directly affected by the change.

Based on my experience of tracking similar training sessions across different sports, one pattern repeats: the people who most need to attend are the least likely to be there. Club Welfare Officers are usually the busiest people at a club and have already sat through too many compliance talks. New volunteers, the people who genuinely need to know whether they fall inside the scope, often do not know the webinar exists.

A one-hour webinar, scheduled on a Tuesday evening, with no confirmation yet on whether it will be recorded, is a limited tool. It delivers accurate information to the right people, but it cannot restructure the operating model of a club with twenty members and one person keeping the books.

Cost, time, and the volunteer pipeline

This is the part usually skipped in DBS discussions, yet it decides whether the change actually works.

On fees, for eligible volunteer roles the DBS fee is normally waived. That rule long predates this change and remains in place. What remains is administrative cost: the time of the person verifying identity, the waiting period for results, and the effort of tracking applications. For a large organisation this is a minor line item. For a club with a hundred members and one records keeper, it is a major one.

On time, a DBS application takes anywhere from a few weeks to a few months, depending on whether local police need to make further enquiries. In table tennis, the critical moment is September, when the new season starts and junior classes reopen. A club that discovers in September that three volunteers need new certificates will not have them before November. That two-month gap is a gap no administrative measure can fill.

On volunteer flow, this is a variable public data cannot measure, so I can only speak from observation. Every additional administrative barrier reduces the number of people who voluntarily step through. This holds in every field, from blood donation to book clubs. In grassroots sport, where most volunteers are parents already holding down full-time jobs, a twenty-minute form can be the deciding threshold between taking part and not.

There is no public dataset in the UK tracking how many people leave volunteer roles after each regulatory change. That is a blind spot. And in child safeguarding, a blind spot always costs more than it does in statistics.

How Table Tennis England's DBS process works

A club seeking DBS certificates for its volunteers has two routes. The first is to approach an external umbrella body. The second is to go through its sport's governing body. Table Tennis England provides the second route.

The basic process has four steps. First, the club identifies who needs checking and at what level. Second, the applicant completes their details and presents identity documents to a verifier. Third, the application is submitted to DBS through Table Tennis England's channel. Fourth, the result is returned to the applicant and to the governing body under a confidentiality mechanism.

The most important of those four steps is the second. The entire system depends on there being a real person, physically present, checking real documents. If the verifier does not know what they are verifying, or verifies from a photo sent by message, the rest of the process loses its value.

There is another mechanism rarely mentioned: the update service. Someone who already holds a DBS certificate can subscribe so employers can check its status online without starting again. For a sport with high volunteer turnover, this saves considerable time. But it only works if the person managing club records knows it exists.

The counterintuitive angle: one more certificate does not mean one safer child

This is the part I want to write most slowly, because it is the easiest to misread.

Correlation is not causation. Widening the scope of DBS checks produces a clear correlation: the number of certificate holders rises, and the number of reported incidents may shift. But no model demonstrates that increasing certificate numbers is the direct cause of children being safer in a specific hall on a specific Wednesday evening.

A DBS certificate is a filter on the past. It answers the question: has this person previously been recorded for anything. It does not answer the question: what will this person do in the next two hours. Most harm to children in sport does not come from someone with a criminal record on file. It comes from someone never recorded, in situations where nobody was watching, in relationships built over months.

Does that make this change meaningless? No. A filter on the past still filters something, and something is enough to be worth doing. But if a club believes that after 1 September 2026 it is safe because everyone holds a certificate, it has traded one gap for another.

There is a second paradox. Removing the supervision exemption concedes that supervision did not work as designed. But the chosen remedy is to replace supervision with criminal record checks, rather than to improve supervision. If supervision did not work, why remove it rather than fix it? The answer is administrative rather than professional: amending a legal definition is easier than amending the operating habits of thousands of clubs.

A third paradox is structural. When every regular volunteer must be checked, the welfare officer's time is pulled into processing applications. That is time not spent observing behaviour, not spent building a reporting culture, not spent talking to a child who seems not quite right. Safeguarding runs on adult time. Every hour poured into paperwork is an hour taken out of people.

Data does not lie; only readers who are not honest enough do. An honest reading here is to accept that this is an improvement in compliance, not an improvement in safety. Those two things are different, and the difference appears in no spreadsheet anywhere.

What clubs should do before the season starts

No complex plan is required. Four tasks, done in order.

First, build the list. Every adult present in the junior area once a week or more, regardless of their formal title. That list is usually longer than the committee expects, which is why the list comes before everything else.

Second, reconcile certificate status. Who has one, whose has lapsed, who has subscribed to the update service, who has never applied. In many clubs this information lives in one person's memory, and memory is the worst kind of database because it vanishes when that person moves on.

Third, plan backwards from a date. If a volunteer needs a certificate by the day junior classes open, and an application takes eight weeks, the deadline to start is eight weeks before that day. It is simple subtraction that many clubs never perform.

Fourth, send at least one person to the webinar on 29 September. Not the whole committee. One person, and that person must have the authority to change the process.

Signals for the next cycle

Three signals I will be tracking after 1 September 2026.

First, how many table tennis clubs complete their review before the season starts. If that number is low, the legal change has outrun the operational capacity of the grassroots system.

Second, how many people leave volunteer roles over the following twelve months. This is a variable nobody publishes, but it is the real cost of administrative reform, and it only becomes visible after two seasons.

Third, whether other sports follow the same path. Table Tennis England often moves ahead of team sports on governance changes, because its club structure is smaller and easier to pilot. If this model works here, it will be copied.

A traveller needs no compass once he has read enough data about the winds. Here, the wind changed direction on 1 September 2026, and the webinar on the evening of Tuesday 29 September is the first time the governing body tells clubs plainly where the new wind blows. One hour for a change lasting years is a reasonable exchange. What remains is how many of the people who need to hear it will actually sit down and listen.