Disclosure Scotland’s PVG Backlog Hit 301 Days Before Quietly Easing

Almost 78,000 background checks for people working with children and vulnerable adults in Scotland missed their 14-day target between April and December last year, according to figures Scottish Labour published Sunday. Nearly 12,000 of those took more than 42 days to clear. One applicant waited 301 days.

The party blames the Scottish National Party (SNP) government for starving Disclosure Scotland of resources during a legal overhaul that flooded the agency with new applications. Disclosure Scotland’s own newer figures, published in the months since, show average waits sliding back toward a week by early this year. That recovery gets little mention in Sunday’s row over last year’s numbers.

What Labour’s Numbers Actually Add Up To

Labour’s figures cover the Protection of Vulnerable Groups (PVG) scheme, the background check required for anyone working with children or protected adults in Scotland. Add the four bands the party released together and Disclosure Scotland completed 334,732 PVG applications between April 1 and December 31, 2025.

Run the math and roughly 77% of applications cleared inside the 14-day target, short of Disclosure Scotland’s own service standard of clearing 90% of applications within that window. About 23% ran long. A separate clock for suspensions, the time paused while Disclosure Scotland waits on an applicant or a countersignatory, stretched as long as 146 days in one case.

Katherine Sangster, Scottish Labour’s education spokeswoman, said the checks carry real weight. “These checks are vital in keeping children and protected adults safe from harm,” she said. “However, these figures show that thousands of checks are now taking much longer than the 14-day target for completion.”

A Law Change Nobody Fully Resourced

The surge behind those numbers has a specific starting point. The Disclosure (Scotland) Act 2020 took effect on April 1, 2025, the same day Labour’s data window begins, making PVG membership a legal requirement for regulated roles that had been exempt for up to 14 years.

Disclosure Scotland received 51,474 more PVG applications between April and June 2025 than in the same three months of 2024, a 73.4% jump, as roles from charity trustees to sports coaches joined the scheme for the first time. The agency’s own service agreement calls for 90% of applications to clear within 14 days.

Staffing did not obviously scale with demand. 176 of Disclosure Scotland’s 387 staff were assigned to processing applications as of November 2025. The agency has said it temporarily brought in agency workers between April and August 2025 to chip away at the backlog, alongside its core Scottish Government team.

Sangster argues that was not enough. “A well-functioning disclosure system is a matter of public safety, but unfortunately, the SNP government has failed to provide Disclosure Scotland with the resources it needs to carry out robust and speedy checks,” she said. “Ministers must urgently act to ensure the organisation has the support it needs to cut the backlog.”

The criticism lands two months after Scottish Labour’s worst-ever results in Scotland and Wales, a defeat that has left the party hunting for ground where it can still hold the SNP government to account on public services.

Twelve Weeks on Universal Credit

The backlog peaked in the summer. By July 14, 2025, 33,776 applications sat in progress at once. That week’s average processing time reached 17.1 days, and the longest wait for a case without extra checks was 24 days.

For applicants, even a few weeks can mean lost income. A Kirkcaldy jobseeker described his experience to local station Radio Cowdenbeath in September, after a summer spent waiting on a PVG check tied to a confirmed job offer.

It’s incredible that after all this time I still dont have my PVG back.

The man, who gave only the name Mark and asked not to be identified for fear it would affect his employment, said he had called Disclosure Scotland more than five times and waited on hold for close to two hours each time. He spent months on Universal Credit rather than in the job he had already been offered.

Disclosure Scotland Says the Backlog Cleared

Disclosure Scotland’s own account of the following months describes a steady recovery rather than a system still in crisis.

1. 1 April 2025: The Disclosure (Scotland) Act 2020 takes effect, making PVG membership compulsory for a much wider set of roles.
2. April to June 2025: Applications rise 73.4% year on year, straining processing capacity.
3. 14 July 2025: 33,776 applications sit in progress; that week’s average processing time hits 17.1 days.
4. Week of 25 August 2025: The agency says 86% of disclosures are back within the 14-day target, averaging 8.3 days.
5. Late 2025: Disclosure Scotland tells a freedom of information requester it has returned within its service agreement, with the longest non-suspended wait at 23.8 days.
6. February 2026: 50,780 applications are completed at an average of 6.47 days.
7. 1 April 2026: Lifetime PVG membership ends, replaced by a five-year renewal cycle.

Disclosure Scotland’s published performance data now updates monthly, and the agency has told freedom of information requesters that it returned within its service agreement once the initial surge eased. Applicants apply and manage their PVG membership through ScotAccount, the government’s digital identity service, which recently rolled out non-biometric identity verification options for people who cannot complete facial matching.

Care Homes and Classrooms Feel It First

Sangster’s complaint about staffing shortages was not incidental. PVG delays land hardest in sectors already short of workers. “This not only makes it more difficult for those working in roles such as teachers, nursery practitioners, or in our health service, to begin work, it also presents challenges for those organisations already struggling with staffing shortages,” she said.

• 3.5% was NHS Scotland’s registered nurse vacancy rate at the end of December 2025, up from 2.9% a year earlier, equal to 1,721.4 whole time equivalent posts unfilled.
• 42% of adult care homes reported nursing vacancies in the latest count, down from 55% the year before but still leaving employers short handed.
• 75% of care organisations surveyed by Scottish Care, the sector’s representative body, said they struggled to fill nursing vacancies, and 79% named registered nurse posts the hardest to fill.

The Royal College of Nursing’s 2026 workforce report describes a sector where recruitment has grown harder even as some vacancy measures improved slightly. A candidate who has already cleared an interview and accepted an offer still cannot start a regulated role until the PVG disclosure lands, whatever the vacancy rate says about how badly the post needs filling.

What Happens When the Next Surge Hits?

Disclosure Scotland is already moving existing PVG members onto five year renewable membership rather than lifetime membership, a transition that will process members in batches by original join date rather than all at once, according to the agency’s own guidance.

That phased approach is meant to avoid repeating 2025’s shock, when 51,474 extra applications landed in a single quarter and pushed average waits above 17 days. Whether 176 processing staff, backed by short term agency hires, can absorb a renewal wave stretched over five years without another backlog is the question Sangster’s figures do not answer, because they only look backward.

Disclosure Scotland’s most recent published figures, covering February 2026, show 50,780 applications completed in a single month at an average of 6.47 days, a long way from the 301 day outlier Labour highlighted on Sunday.

Frequently Asked Questions

What Is a PVG Check and Who Needs One?

The Protecting Vulnerable Groups scheme is a legal requirement for anyone doing a regulated role with children or protected adults in Scotland, run by Disclosure Scotland, an executive agency of the Scottish Government. Since April 2025, the requirement covers a far wider range of jobs and volunteer roles than before, including some positions with no direct contact with vulnerable people.

Can a PVG Check Be Fast-Tracked in an Emergency?

No. Disclosure Scotland has confirmed through a freedom of information response that it does not offer a priority or fast track service. Applications are processed in the order they are received and reviewed case by case, regardless of how urgently an employer needs a new starter.

Can I Start Training Before My PVG Check Arrives?

Partly. Guidance from the Scottish Social Services Council says new staff or volunteers can complete office based induction or training while waiting, but they cannot take on any regulated activity or contact with service users until Disclosure Scotland issues the disclosure.

Do I Need to Reapply Under the New Five-Year PVG Scheme?

No action is required from most existing members. Disclosure Scotland is moving current PVG members onto five year membership automatically in batches by original join date, and members are told not to apply early or change how often they normally would.

Where Can I Check the Current PVG Waiting Time?

Disclosure Scotland publishes updated processing time data on its own performance page roughly monthly, based on a live extract from its case management system, giving a more current picture than any single freedom of information release or press statement.