Pharmacy Technicians Will Require PVG Membership from April 2025

Published: 19/05/25

We can now confirm that Pharmacy Technicians will be included under the updated definition of ‘regulated roles’ and will therefore require PVG Scheme membership from 1st April 2025.

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Starting 1st April 2025, it will be a legal requirement for individuals (including Pharmacy Technicians) to be members of the Protecting Vulnerable Groups (PVG) Scheme in order to undertake regulated roles involving children, protected adults, or both. 

The PVG Scheme, created under the Protecting Vulnerable Groups (Scotland) Act 2007, was introduced in response to the Bichard Inquiry and aims to prevent unsuitable individuals from gaining access to vulnerable groups. It allows organisations to ensure their employees are not on any barred lists, with their name listed as an ‘interested party’ on the applicant’s Disclosure Scotland file. If a member’s status changes, the organisation is notified.

Until now, pharmacists have been required to be members of the PVG Scheme due to their responsibilities under regulated work. Community Pharmacy Scotland (CPS) has been working to clarify the position for Pharmacy Technicians in light of legislative updates under the Disclosure (Scotland) Act 2020.

We can now confirm that Pharmacy Technicians will be included under the updated definition of ‘regulated roles’ and will therefore require PVG Scheme membership from 1st April 2025. 

This clarification follows direct engagement between CPS, Disclosure Scotland, and the General Pharmaceutical Council (GPhC). Contractors will now be expected to ensure that any pharmacy technician performing a regulated role is a member of the PVG Scheme before undertaking such work.

The term ‘regulated work’ will be replaced by ‘regulated role’ under the 2020 Act. This change will maintain the scope of current roles but also bring new roles—such as that of pharmacy technicians—into scope. The PVG Scheme remains mandatory for anyone carrying out regulated roles with children or protected adults.

• Important Changes to Note:

  • New Offences from July 2025:

    • It will be an offence for an individual to carry out a regulated role without being a PVG Scheme member.

      • It will also be an offence for organisations to offer a regulated role unless a Level 2 (PVG) disclosure has been received.

    • Level 1 and Level 2 Disclosure Checks:

      • These will replace the current disclosure levels.

      • Level 2 (PVG) checks will be required for regulated roles.

      • Individuals can request independent reviews of disclosure content and provide context for certain convictions.

    • Fees (remain unchanged):

      • Level 1 (Basic Disclosure): £25

      • Level 2 (PVG – Join): £59

      • Level 2 (PVG – Existing Member): £18

• What Is Not Changing:

  • Continuous monitoring of PVG Scheme members

  • Notifications to ‘interested parties’ of any suitability changes

  • The duty to refer concerns to Disclosure Scotland

  • UK-wide barred status recognition

  • Obligation for organisations to notify Disclosure Scotland when an individual ceases regulated work

Looking Ahead:

From 1st April 2026, the PVG Scheme will transition from lifetime membership to a renewable five-year membership. Disclosure Scotland is currently reviewing the transition process for existing members and further guidance is expected.

CPS has updated the PVG application form to reflect this new requirement and will continue to support members through the process. Contractors can complete the adapted form and submit it to CPS, who will manage the submission to Disclosure Scotland. Applicants will then receive a link directly from Disclosure Scotland to finalise their application.

If you have any enquiries, please get in contact with the team at pvg.enquiries@cps.scot.

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