Feedback on enhancements to criminal background checks

1    Executive summary

1.1    Overview

1.1.1    This paper confirms our policy position on criminal background checks for Principal Persons (PPs) and Key Persons (KPs). We consulted on this in Consultation Paper No 1 2025 (the CP), published on 29 January 2025.

1.1.2    Given the extent of the feedback received, we are issuing this paper a few months later than originally envisaged. The additional engagement required us to refine our original proposals and adopt a revised approach to reflect stakeholder input, while maintaining our commitment to a proportionate and effective regime.

1.1.3    Key changes include the removal of the three-year rolling refresh requirement and placing the responsibility on Supervised Persons,    to collect and maintain records of checks performed. The full details of the revised approach are covered throughout the remainder of this paper and the appendices.

Read our full feedback on enhancements to criminal background checks.