Care Worker Compliance Checklist: What CQC Expects on File
Care worker compliance checklist for UK agencies: every CQC Schedule 3 document needed before the first shift, how long each lasts, plus a printable table.
Last reviewed: 12 October 2026. This guide is general information, not legal advice.
A care worker compliance checklist must cover everything in CQC Schedule 3, plus right to work and your agency's own reference duties. That means photo ID, an enhanced DBS with the adults' barred list and conduct evidence from past care jobs. It also means a full employment history, qualifications and a health declaration. All of it should be confirmed before the first shift, not during it.
In short:
- In England, Regulation 19 and Schedule 3 set the core list for anyone working in a CQC-registered service, agency staff included.
- Agencies supplying care workers must also get two references from non-relatives, under the Conduct of Employment Agencies Regulations.
- A DBS certificate has no official expiry date, but right to work permission, training and some registrations do.
- The most common gaps are unexplained employment gaps, unverified reasons for leaving and health questions asked too early.
- Scotland, Wales and Northern Ireland use different regulators, disclosure schemes and worker registers.
Who does a care worker compliance checklist apply to?
It applies to everyone working in a CQC-registered care service in England, including bank and agency staff.
The CQC's guidance on Regulation 19 covers agency and bank staff, not just employees. It also says the Schedule 3 information must be confirmed before the person starts work.
That puts the legal duty on the care provider, your client. In practice, your client relies on your agency's file. If an inspector asks for a worker's checks, your client will ask you, and they will want them the same day.
Your agency has its own duty too. Regulation 22 of the Conduct Regulations 2003 applies when you supply someone to care for or attend a vulnerable person. You must obtain two references and copies of relevant qualifications, and offer copies to the client.
What does CQC Schedule 3 require on a care worker's file?
Schedule 3 lists eight pieces of information the provider must hold for each worker, and each one needs a document behind it.
| Schedule 3 item | What it means for your file | Documents that count |
|---|---|---|
| 1. Proof of identity with a recent photograph | You have seen and copied valid photo ID | Passport, photocard driving licence or other photo ID, plus a recent photo |
| 2 and 3. Criminal record certificate | A copy of the DBS certificate at the level the role requires | Enhanced DBS certificate with the adults' barred list for most care roles |
| 4. Conduct in previous employment | Evidence of how they behaved in past health, social care or vulnerable adults work | Written references from those employers |
| 5. Reason the previous role ended | Where they worked with children or vulnerable adults, why that job ended, verified so far as reasonably practicable | A reference or confirmation from the employer stating the reason |
| 6. Qualifications | Evidence of any qualification relevant to the duties, so far as reasonably practicable | Certificates, for example a care qualification or Care Certificate |
| 7. Full employment history | Every job, with a written explanation of any gaps | CV or application form, plus signed gap explanations |
| 8. Health | Information on physical or mental health conditions relevant to the role, after reasonable adjustments | A health declaration or occupational health assessment |
Schedule 3 defines "satisfactory" as satisfactory in the opinion of the Commission. So the test is what an inspector will accept, not what the worker thinks is enough.
What about professional registration?
Regulation 19(4) says workers must be registered with the relevant professional body where the law requires it. Most care workers in England have no professional register. If a registered nurse picks up care shifts, check their PIN first. Our guide to NMC PIN checks covers how.
What else should a care agency file hold beyond Schedule 3?
Beyond Schedule 3, your file needs right to work, two references, induction and training evidence, and role extras such as driving documents.
Right to work
Every worker needs a right to work check before they start. The Home Office guide, updated on 1 October 2026, treats the agency supplying temporary workers as their employer for this check. For a manual check over a live video call, you must already have the original document in your possession. A scan or screenshot is not enough.
We cover acceptable documents and share codes in our UK right to work checks guide. The Home Office rules are in the employer's guide to right to work checks.
Two references
The Conduct Regulations ask for two references from people who are not relatives. Each referee must have agreed to their reference being shared with the client. Schedule 3 also asks for evidence of conduct in past care roles, so at least one should come from a care employer.
Care Certificate and induction
The CQC's position on the Care Certificate is that it is the benchmark for staff induction. Providers should show that care staff have, or are working towards, its skills. Skills for Care lists 16 standards, updated in March 2025 to add learning disability and autism awareness.
Training
CQC guidance on Regulation 18 includes first aid training for people working in adult social care. It also requires all staff to be trained to interact appropriately with people with a learning disability and autistic people.
The Oliver McGowan code of practice became final on 6 September 2025. It sets the standard for that statutory training in CQC-registered services.
Most clients also ask for moving and handling, safeguarding adults, infection prevention and medication training. Agree the list with each client, as it comes from their contract and policies.
Domiciliary care worker documents
Domiciliary care workers often drive between calls. Clients usually ask for a full driving licence and car insurance that covers business use. These are contract requirements, not Schedule 3, but a missing insurance certificate still stops a start.
Which DBS check does a care worker need?
Most care workers giving personal care need an enhanced DBS check with the adults' barred list, because personal care is regulated activity.
GOV.UK's DBS guidance for employers limits barred list checks to regulated activity and a few listed roles. Ask for the adult workforce and the adults' barred list on the application.
The same guidance describes the DBS Adult First service. An Adult First result can let someone start under supervision before the full certificate arrives. It is only the first part of the check, so the enhanced certificate must still follow.
Levels, the Update Service and portability are covered in our guide to DBS checks for agency workers.
How long do care worker compliance documents last?
Some documents never expire, some carry a printed expiry date and some last only as long as your policy or your client says.
| Document | Does it expire? | When to check it again |
|---|---|---|
| Photo ID | Yes, printed expiry date | When it expires, if it is your main ID record |
| Enhanced DBS | No official expiry date | Per your policy or the client's; use the Update Service where the worker subscribes |
| Right to work (time-limited) | Yes, when the permission ends | A follow-up check before the permission ends |
| References | No | At the start of each new engagement, if your policy says so |
| Employment history | No | Update when they return after a break |
| Health declaration | No | When the worker reports a change |
| Training certificates | Set by the provider or client | Usually on the date printed on the certificate |
| Care Certificate | No expiry date | Clients may still ask for refresher training |
| Driving licence and insurance | Yes | Before each renewal date |
What commonly goes wrong in care worker files?
Most audit findings come from documents that exist but do not prove what Schedule 3 asks for.
- Gaps explained only verbally. Schedule 3 asks for a written explanation. Get a signed note for every gap.
- References from friends or relatives. The Conduct Regulations exclude relatives. A character reference does not cover conduct in a past care role.
- Reason for leaving not verified. If the last care employer only confirms dates, ask again for the reason or record your attempts.
- Wrong DBS workforce or no barred list. A child workforce check or a standard check will not cover adult personal care.
- Health questions asked before the offer. Section 60 of the Equality Act 2010 limits health questions before a job offer, with narrow exceptions.
- Expired documents. Training certificates and time-limited right to work lapse quietly. Track expiry dates, not just "received".
- Starting before the file is complete. The CQC expects Schedule 3 to be confirmed before work starts. "Documents to follow" is not a defence.
Printable care worker compliance checklist
Print this table or copy it into your ATS as a document list for each new care worker.
| Done | Document | Rule it meets |
|---|---|---|
| [ ] | Photo ID, copied and verified, with a recent photo | Schedule 3, item 1 |
| [ ] | Right to work check, recorded and dated | Home Office employer's guide |
| [ ] | Enhanced DBS with adults' barred list, or Adult First result while it is pending | Schedule 3, items 2 and 3 |
| [ ] | DBS Update Service status check, with the worker's consent | Your DBS policy |
| [ ] | Reference covering conduct in the last care role | Schedule 3, item 4 |
| [ ] | Reason the last care or vulnerable adults role ended | Schedule 3, item 5 |
| [ ] | Second reference, neither referee a relative, both agreed to sharing | Conduct Regulations, reg 22 |
| [ ] | Full employment history | Schedule 3, item 7 |
| [ ] | Signed explanation for every gap | Schedule 3, item 7 |
| [ ] | Relevant qualification certificates | Schedule 3, item 6; reg 22 |
| [ ] | Care Certificate or induction record | CQC Regulation 18 and 19 guidance |
| [ ] | Learning disability and autism training | Oliver McGowan code of practice |
| [ ] | First aid and other client-required training, with expiry dates | CQC Regulation 18 guidance; client contract |
| [ ] | Health declaration, taken after the offer | Schedule 3, item 8; Equality Act s60 |
| [ ] | Professional registration, if the role needs one | Regulation 19(4) |
| [ ] | Driving licence and business-use insurance, if driving | Client contract |
| [ ] | Copies of references and qualifications offered to the client | Conduct Regulations, reg 22 |
How do Scotland, Wales and Northern Ireland differ?
The CQC and Schedule 3 apply in England only; the other three nations have their own regulators, disclosure schemes and care worker registers.
- Scotland. The Care Inspectorate regulates services and Disclosure Scotland runs the PVG scheme instead of the DBS. Disclosure Scotland made PVG membership mandatory for regulated roles from 1 April 2025. From 1 April 2026, membership must be renewed every five years. Most care roles also register with the SSSC.
- Wales. Care Inspectorate Wales regulates services and the DBS still applies. Social Care Wales requires domiciliary care workers and adult care home workers to register within six months of starting.
- Northern Ireland. RQIA regulates services and AccessNI handles criminal record checks. The NISCC gives new care workers six months to register. Returning workers must be registered before they start.
If you supply across borders, keep a separate checklist per nation. Our social care staffing page shows how agencies set this up.
Where does Amy fit?
Collecting these from 30 starters a week? Here's how agencies automate it.
GettingDocs is an AI document agent for recruitment agencies that chases candidates for compliance documents over WhatsApp and email and files them to the ATS. Amy, our AI document agent, asks each candidate for what is still missing. Candidates get no portal and no login, just a conversation on WhatsApp or email.
Amy rejects blurred photos, cut-off pages and wrong documents, and chases again. Accepted documents are filed to the candidate's record in your ATS and to Google Drive. Your chase rule decides which care workers are asked for which documents.
Sharing the file with your client. If your agency uses JobAdder, Crelate or Recruit CRM, GettingDocs can also give your clients a branded Client Portal. Their contacts sign in with a one-time code sent by email, with no password, and see only their own placements and the document types you choose to share, streamed from your ATS.
Frequently asked questions
What documents does a care worker need before their first shift?
A care worker needs photo ID, a right to work check and an enhanced DBS with the adults' barred list. They also need references, a full employment history with gaps explained, relevant qualifications and a health declaration. In England these come from CQC Schedule 3 and should be confirmed before work starts.
Does CQC Schedule 3 apply to agency care workers?
Yes. The CQC says Regulation 19 covers agency and bank staff as well as employees. The care provider holds the duty, so it will expect the supplying agency to provide evidence of every Schedule 3 check.
How many references does a care worker need?
Agencies supplying workers to care for vulnerable people must obtain two references from people who are not relatives. Schedule 3 also expects evidence of conduct in previous care roles. In practice, one reference should come from a past care employer where there is one.
Can a care worker start before their DBS certificate arrives?
They can start under supervision if an Adult First check shows no match on the adults' barred list. The enhanced certificate must still follow. Without Adult First, wait for the certificate.
Do care worker DBS checks expire?
A DBS certificate has no official expiry date. It shows information at the date it was issued, so agencies and clients set their own recheck periods. The DBS Update Service lets you check a subscribed worker's certificate status online with their consent.
Ready to stop chasing care worker documents?
If your coordinators spend the week chasing references and DBS copies, we can show you how Amy handles it. Book a call and we will walk through your care checklist and give you a custom quote. You can also browse our other compliance guides.
Please note: this article is general information, not legal advice, and was correct at the time of writing (October 2026). Rules and guidance change, so please check the latest guidance from the Care Quality Commission, the Disclosure and Barring Service and Skills for Care before relying on it.