PVG Requirements for Locum Pharmacists
Published: 26th February 2026
Locum pharmacists in Scotland must meet new legal requirements under the Protecting Vulnerable Groups (PVG) Scheme. This update clarifies what is now mandatory, what pharmacy businesses must do, and how locum pharmacists can ensure they remain compliant.
What Changed
On the 1st of April 2025, it became a legal requirement for individuals 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 PVG (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 PVG member’s status changes, the organisation is notified.
What This Means For Locum Pharmacists
Locum pharmacists have always been encouraged to be members of the PVG Scheme, but this is now a legal requirement as a locum pharmacist to have a PVG.
If you are a locum, it is a legal requirement for you to have a PVG in order to take on work as a pharmacist, with each pharmacy business engaging their services listed as an interested party.
Short Notice & Emergency Work
Disclosure Scotland does recognise that locums can be required at short notice. As such, it is not always possible to add the business to the individual's PVG as an interested party in the time between booking and carrying out the shift. These emergency cases fall outwith the scope of PVG, but Disclosure Scotland have been clear that this is expected to be an exception to the new norm of each professional being on the scheme and having each business they work for listed as an interested party.
How to Apply for a PVG
You can apply for a PVG using the CPS application form.
Further Support
If you have any enquiries, please get in contact with the team at pvg.enquiries@cps.scot.
Frequently Asked Questions (FAQs)
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Yes. From 1 April 2025, PVG membership is a legal requirement for locum pharmacists undertaking regulated roles in Scotland.
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Yes. Each pharmacy business engaging a locum pharmacist’s services must be listed as an interested party.
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Disclosure Scotland recognises emergency situations. If there is insufficient time to add an interested party, this may fall outside PVG requirements, but this should be the exception rather than the norm.
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This includes Pharmacists, Foundation Trainee Pharmacists, Pharmacy Technicians, and locum pharmacists undertaking regulated roles.
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You can apply using the Community Pharmacy Scotland PVG application form, available via the CPS website
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For enquiries, contact pvg.enquiries@cps.scot.
Today, I represented Community Pharmacy Scotland on BBC Scotland television and BBC Radio Scotland, discussing the availability of private flu vaccinations in community pharmacy and how people can prepare for winter