Disclosure (Scotland) Act 2020  - accredited body fees and proposals for discounting: PVG scheme consultation

Accredited bodies

Accredited bodies will replace registered persons. They will be organisations countersigning Level 1 and Level 2 disclosures. They also replace the administrative ‘responsible body’ arrangement for receiving basic disclosures on behalf of applicants, where consent has been given.

Registered persons are currently charged £75 annually for the registration of a lead signatory and up to four countersignatories. There is an additional £15 annual fee for the fifth and each subsequent countersignatory. There is also a one-off £15 fee to change the lead signatory to a person other than an existing countersignatory.

As accredited bodies will now register to countersign for Level 1 disclosures, Level 2 disclosures or both, we have to ensure accredited body registration fees are fair. This is because some organisations may initially register as accredited bodies to countersign only one type of disclosure and then later decide to register to countersign the other type. The fee structure for accredited bodies will therefore need to take account of whether double registration fees are appropriate.

Proposal

Disclosure Scotland propose that the fee structure for accredited bodies will remain the same as the current fee structure for registered persons. An increase in line with inflation was supported in a previous formal consultation in 2018 but was not implemented at that time.

We propose that the fee for registration as an accredited body (and up to four countersignatories) will be £120 annually. The increase in line with inflation would have been to £123. This will cover the increased costs associated with maintaining the registration and auditing of accredited bodies due to inflation.

The fee for additional countersignatories will remain £15 annually per addition.

In addition, Disclosure Scotland propose that accredited bodies who initially register for one disclosure type but later decide to register for the second will be charged a one-off £15 administration fee to have their account upgraded. This fee will not recur annually.

Question 8 - Do you agree with the proposal to increase the accredited body registration fee to £120, with additional countersignatories continuing to be £15 per addition?

[Yes / no / don’t know]

Question 9 – Do you agree with the proposal to introduce an account upgrade fee?

[Yes / No / Don’t know]

Question 10 – What information do you think we need to consider in relation to the accredited body registration fee?

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