Pharmacy locums need an enhanced DBS certificate from January 2027

Community Pharmacy England reported on 11 September 2026 that a package of amendments had been laid before Parliament, and that from January 2027 the regulations will require professional staff and locums, pharmacists and pharmacy technicians alike, to hold an enhanced DBS certificate. Community pharmacy has not had a checking regime of that shape before. For anyone self-employed the point is the lead time: the certificate has to exist before January, and an enhanced check is not bought on the morning it is asked for.

What the September regulations change

The amendments sit in The National Health Service (Pharmaceutical and Local Pharmaceutical Services) (Amendment) (No. 2) Regulations 2026. CPE's summary describes a package supporting prescribing in NHS pharmacy services that takes effect from 1 October 2026, and which also lets a pharmacy close for up to four hours a month for learning and development, subject to conditions, and requires explicit patient consent before an EPS nomination is changed.

The DBS provision carries a later date of its own. On CPE's account it arrives in January 2027, and it reaches locums by name rather than leaving them implied inside a category of staff. CPE did not present it as something done to the sector: it framed the change as putting community pharmacy "in good standing by establishing professionally responsible practice".

The exact wording lives in the statutory text, not the summary. What the summary does not settle is the part that decides your autumn: who applies for the check, who pays, and whether a certificate you already hold, registered with the Update Service, will satisfy the requirement. By mid-September 2026 the trade press had not answered those questions for self-employed locums either.

Why the arranging happens now and not in December

If the requirement bites in January, the certificate has to be applied for, processed and issued before then, and an enhanced check is applied for through an organisation rather than bought off a shelf. That means a conversation with the pharmacies, multiples or agencies you work for, while there is still time for it to be routine.

Two questions are worth putting in writing to each organisation: which of them will apply for the check, and whether they expect you to hold it personally and give them access to it. The one planning to deal with it in the new year is the one to chase first.

The autumn costs, in one place

The Disclosure and Barring Service announced on 9 September 2026 that its fees fall on 5 October 2026. The General Pharmaceutical Council's registration fees moved in the opposite direction in September 2026.

An enhanced check bought on or after 5 October costs £8.50 less than the same check in September.

The Update Service is the piece that matters most to someone working across several employers. A subscription lets an organisation you give consent to check the status of your existing certificate online, instead of putting you through a fresh application every time you start somewhere new. One condition comes with it: the subscription has to be started within a set window running from the certificate's issue date, so a certificate left in a drawer can lose the option. That window is in the DBS guidance, and the day to read it is the day a certificate lands.

The GPhC fee is £310, and the direction is set

The GPhC announced on 26 March 2026 that renewal fees would rise by 6% from September 2026. The Pharmaceutical Journal, reporting the same day, noted that this is the second consecutive 6% rise, following September 2025.

The regulator gave its reasons in volume terms: almost 9,750 concerns received in 2025-26, up 77% since 2023-24; inspection activity up by more than 60% since 2023/24, with almost 2,000 inspections expected this year; and over 600 additional regulatory contacts with pharmacies. It also signalled regular, incremental increases aligned with inflation in future, and a review and consultation on how premises fees are set.

That intention is the part to plan around. Against the long run the fee has been cheap to hold: the GPhC puts the average annual increase since it was established in 2011, including September 2026, at 1.13% a year for pharmacists and 0.19% for pharmacy technicians. Two 6% years in a row and a stated policy of inflation-aligned rises make this a cost to budget for rather than notice.

Renewal runs through myGPhC, the requirements sit on the GPhC's revalidation pages, and the renewal page is blunt about the dependency: "You need to submit your revalidation record to successfully renew your registration". If your CPD entries are scattered across a year of different pharmacies, which is normal for a locum pharmacist, the record is what delays the renewal, not the payment.

The tax line in the announcement is not written for a locum

In the same announcement the GPhC pointed registrants at its own tax-relief guide, which it says shows a pharmacist on the basic income tax rate saving £62 a year and a pharmacy technician £29.20 on the fees for September 2026 onwards. Anyone who has not claimed before, it says, can claim for this year and the previous four financial years.

Look at the arithmetic. £62 is basic rate tax on £310, and £29.20 is basic rate tax on £146. That is what relief on a professional fee looks like for someone taxed through PAYE: the fee is allowed against employment income, and the cash value is the marginal rate applied to it.

If you invoice for your sessions, you are not in that mechanism. The fee is a cost of your own business, recorded in your accounts as an expense against the profit you declare, and what it is worth to you depends on your own figures rather than on a published example. The same goes for the DBS fee and the Update Service subscription. Whether a particular cost is deductible in your circumstances is a question for your accountant, and the GPhC's guide is not written to answer it. None of this is tax advice.

What to do before 1 January

Four things.

Establish where you stand today: the level of certificate you hold, its issue date, whether you are on the Update Service, and when that subscription renews. Then ask each organisation you work for who is applying for your enhanced check and when, and keep the answer somewhere you can find it in December.

If you are buying a check or joining the Update Service, the prices from 5 October 2026 are in the table above. Keep the receipts as they happen rather than reconstructing them in January: the certificate details and registration dates in a compliance passport, the fees in an expense log as you pay them.

The last thing is your next renewal. The fee is £310 and the revalidation record gates it, so keep the record current through the year rather than assembling it in the week it is due.

Sources

• New regulations to support prescribing, closures for learning and other CPCF changes (Community Pharmacy England, 11 September 2026)
• DBS reduces fees for checks and Update Service from 5 October 2026 (GOV.UK, Disclosure and Barring Service, 9 September 2026)
• Increasing demand and complexity drives GPhC fee increase (General Pharmaceutical Council, 26 March 2026)
• GPhC announces 6% rise in registration fees (The Pharmaceutical Journal, 26 March 2026)
• Renew your registration (General Pharmaceutical Council, undated)
• Revalidation requirements (General Pharmaceutical Council, undated)