PVG Requirements for Locum Pharmacists

Published: 20/11/25

We can now confirm that 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.

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As of the 1st of April 2025, it is now 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.

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.

Community Pharmacy Scotland (CPS) had been seeking clarification from Disclosure Scotland following the release of their Guidance for the Health Sector, as there was no specific reference to community pharmacy locums.

We can now confirm that 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.

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.

You can apply for a PVG using the CPS application form here.

Information has previously been provided on the legal requirements of those undertaking regulated roles of which includes Pharmacists, Foundation Trainee Pharmacists and Pharmacy Technicians in having a PVG, detail of which can be found on our website and how the application process works.

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

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