What Schedule 3 asks for
Regulation 19 says the people you employ must be of good character, have the qualifications, competence, skills and experience for the work, and be able to do it with reasonable adjustments. Schedule 3 lists the information you need to show that.
| Schedule 3 item | What it means in practice |
|---|---|
| Proof of identity, including a recent photograph | Check an original identity document and keep a copy with a photo that looks like the person now. |
| A DBS check | The level the role is eligible for. For most hands-on care roles that is an enhanced check with the adults' barred list. |
| Evidence of conduct in previous employment | Required where the person has worked in health or social care, or with children or vulnerable adults. In practice, references from those employers. |
| Why that employment ended | Verified, as far as reasonably practicable, for previous work with children or vulnerable adults. |
| Relevant qualifications | Documentary evidence of any qualification the duties depend on. |
| Full employment history | With a satisfactory written explanation of any gaps. |
| Health information | Information about physical or mental health conditions relevant to the role, after reasonable adjustments. |
Where the role needs professional registration, check it too. That means the NMC for nurses, Social Work England for social workers and the HCPC for other registered professions.
Gaps in employment history
A gap is not a problem. An unexplained one is. People take time out to care for family, study, travel or recover from illness. CQC's guidance says applicants should give a full history and say where they cannot recall something, and that providers should explore gaps at interview.
Ask about every gap. Write down the explanation and who took it. Inspectors look for the written record.
Care references: who to ask and what to ask
Schedule 3 is specific. It wants evidence of conduct in previous health or social care work, or work with children or vulnerable adults. A reference from a recent retail job does not cover that, however positive it is.
- Ask for a reference from the most recent care employer, even if it was not the most recent job.
- Check the referee is who they say they are. Use the organisation's main number or a work email address, not a personal mobile supplied by the candidate.
- Ask directly whether the person would be re-employed, and whether there were any safeguarding concerns.
DBS checks and starting before the certificate arrives
For most care roles you need an enhanced DBS check with the adults' barred list. From 5 October 2026 an enhanced check costs £41, down from £49.50, and the DBS Update Service costs £15 a year, down from £16.
If the person has subscribed to the Update Service, you can check their certificate online with their consent. It tells you whether anything has changed since it was issued.
Starting someone before the certificate arrives should be rare. It needs a DBS Adult First check against the barred list and proper supervision until the full certificate is back. CQC's guidance says Adult First should not be relied on routinely.
If you are sharing this with a new starter, our candidate guide to DBS checks when changing care jobs explains the Update Service from their side.
Right to work checks
Right to work is a Home Office requirement, separate from Regulation 19, and it applies to every employer. The check must be done before employment starts. Depending on the person, it is a manual check of original documents, an online check using a share code, or a digital identity check through a certified provider.
The maximum civil penalty for employing someone without the right to work is £60,000 per worker. The Home Office updates its employer's guide from time to time, and the version in force on the day you check is the one that applies.
Keeping recruitment records current for CQC
Checks are not a one-off. Professional registrations lapse. Circumstances change. Build a simple schedule for rechecking registrations and, where staff are on the Update Service, running status checks with their consent.
CQC looks at recruitment files at inspection. A file that shows what was checked, when and by whom is worth more than one with every document but no dates.
When a recruiter is involved
The Conduct Regulations require an employment agency to confirm a candidate's identity before introducing them, and to pass on the information it holds about their suitability. The legal responsibility for meeting Regulation 19 stays with you as the provider.
We check identity, right to work, employment history and references before an introduction, plus any role-specific checks such as registration or DBS status. We tell you what we have checked and what is left for you to complete.
Questions
Do agency staff need the same checks as permanent staff?
Yes. CQC treats agency staff as persons employed for Regulation 19, so the same Schedule 3 information applies.
How many references do we need?
The regulations do not set a number. They ask for satisfactory evidence of conduct in previous health or social care work, or work with children or vulnerable adults. Two references, including the most recent care employer, is common practice.
Can CQC prosecute us for a Regulation 19 breach?
Not for a breach of Regulation 19 on its own. CQC can take other regulatory action, and a breach can form part of a prosecution under other regulations.
Are the rules the same in Scotland, Wales and Northern Ireland?
No. This guide covers England. Scotland uses the PVG scheme through Disclosure Scotland and is regulated by the Care Inspectorate. Wales is regulated by Care Inspectorate Wales. Northern Ireland uses AccessNI.
Sources
- CQC: Regulation 19, fit and proper persons employed
- CQC: Employment requirements under Regulation 19 and Schedule 3 (PDF)
- GOV.UK: DBS reduces fees for checks and Update Service from 5 October 2026
- GOV.UK: DBS Update Service
- Skills for Care: DBS Adult First check (PDF)
- GOV.UK: Employer's guide to right to work checks
- GOV.UK: Overview of the Conduct Regulations 2003
This guide covers England unless it says otherwise. It is general information, not legal advice. We review it when the rules change and update the date above.