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ICO Registration, Insurance and DBS: Checklist for Training Providers

Getting ready to bid · 1 October 2026

This checklist is for training and L&D providers getting ready to apply for a public sector framework or DPS. The same items come up in almost every application: ICO registration, insurance, DBS checks, a safeguarding policy and evidence of financial standing. Sort them out before you start, not against a deadline.

ICO registration comes first because other registrations depend on it: the UK provider reference number (UKPRN) and the apprenticeship register both ask for your ICO number.

1. ICO registration and the data protection fee

Do I need to register with the ICO? The ICO says organisations, including sole traders, that use personal information must pay a data protection fee unless they are exempt. Paying puts you on the ICO's register of fee payers, which is what people mean by ICO registration. Learner names, contact details and assessment records are personal information. The ICO's online fee checker tells you if an exemption applies.

ICO registration fee. There are three tiers:

  • Tier 1, micro organisations: turnover up to £632,000 or no more than 10 staff. £52.
  • Tier 2, small and medium organisations: turnover up to £36 million or no more than 250 staff. £78.
  • Tier 3, large organisations: everyone else. £3,763.

Paying by direct debit takes £5 off. The fee covers 12 months and is renewed every year.

2. Employers' liability insurance

Employers' liability insurance is a legal requirement as soon as you become an employer. GOV.UK says it must cover you for at least £5 million, come from an authorised insurer, and that you can be fined £2,500 for every day you are not properly insured. There are exemptions, for example where your only employees are close family.

3. Public liability insurance

Public liability insurance covers damages awarded to a member of the public for injury, or damage to their property, caused by you or your business. For a trainer, that means delegates and the venues you deliver in. It is generally not compulsory, but buyers routinely want proof of it.

On public liability insurance cost: premiums depend on the type of business and its level of activity, usually turnover.

4. Professional indemnity insurance

Professional indemnity insurance covers claims from a client who says you made a mistake or were negligent, including legal costs. For a training provider, think of a client who says your compliance course taught the wrong procedure and it cost them money. Cover is usually claims-made, so it only responds while the policy is live; if you change insurer or stop trading, you may need run-off cover.

How much cover? It varies by buyer and contract, so we do not quote figures. Read each framework's requirements. Under the Procurement Act 2023, a buyer cannot insist that contract insurance is in place before award, only that you show you could get it, for example with a quote. Older frameworks and DPSs set up under the previous rules may still ask for it up front.

5. DBS checks for trainers

There are four levels: basic, standard, enhanced, and enhanced with barred list checks. Anyone can get a basic check. The higher levels need a role that is eligible in law, applied for through a registered body or umbrella body.

  • Training children. Teaching or training children on more than three days in any 30-day period is regulated activity, eligible for an enhanced check with a children's barred list check. Since 1 September 2026 this applies even when you are supervised. Activity relating to the employment of 16 and 17-year-olds is an exception, which can matter for young apprentices.
  • Training adults. This is not regulated activity with adults. It can still qualify for an enhanced check when it is wholly or mainly for adults receiving health or social care, often enough. The DBS eligibility tool confirms which check a role can have.
  • Freelance trainers. Since January 2026, self-employed workers in eligible roles can apply for enhanced checks through a DBS umbrella body.
  • The Update Service. For £16 a year, joined within 30 days of the certificate being issued, a trainer keeps a certificate current, and you can check its status online with their permission.

Frameworks such as the Sunderland public health training DPS expect DBS-checked trainers.

6. Safeguarding policy

Have a written safeguarding policy, a named lead, and a clear route for staff to raise a concern, fitted to how you deliver: in person, online, with young people or with adults at risk.

7. Financial standing

Buyers check that you can carry the contract, so have recent accounts ready. Under the Procurement Act 2023 they cannot demand audited accounts unless the Companies Act requires yours to be audited. Tests may look at annual turnover, cash flow and simple ratios, and can use evidence a third party verifies, such as a credit rating.

See also how to become a public sector training provider and our frameworks page, starting with the Hull learning and training DPS, the lightest entry route.

Frequently asked questions

Do I need to register with the ICO as a training provider?

Almost certainly. Organisations and sole traders that use personal information must pay the ICO's data protection fee unless exempt, and a training provider holds learner data. The ICO's fee checker confirms any exemption.

How much is the ICO registration fee?

£52 a year for micro organisations, £78 for small and medium organisations, and £3,763 for large organisations, with £5 off if you pay by direct debit.

What DBS check does a trainer need?

It depends on the role. Training children on more than three days in 30 is regulated activity and can have an enhanced check with a children's barred list check. Training adults who receive health or social care can qualify for an enhanced check. The DBS eligibility tool confirms the level.

Do I need insurance in place before I apply for a framework?

Employers' liability, yes, because the law requires it once you employ staff. For other contract insurance, procurements run under the Procurement Act 2023 cannot require it before award, though the buyer can ask you to show you could get it.

Sources

Not sure which framework fits you?

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