For centres and agencies · 9 min

Vulnerable sector checks and offence declarations: the timeline

Every employee needs a vulnerable sector check before starting, and volunteers and students need one before they interact with children (s. 60). The check counts only if a police service prepared it within the six months before the licensee obtained it (s. 59(2)). A new one is due on or before every fifth anniversary, and in each year without a new check an offence declaration is due no later than 15 days after the anniversary date (s. 62). A break of six months or more means a new check before the person comes back (s. 63).

Checked against e-Laws on Oct 2, 2026. Section numbers are O. Reg. 137/15 unless another instrument is named.

Who needs a check, and when (s. 60)

Centres obtain a vulnerable sector check from every employee before the person begins employment, and from every volunteer and student on an educational placement before they begin interacting with children. Home child care agencies obtain one, before signing the agreement, from the provider, from everyone ordinarily resident at the premises and from everyone regularly there; afterwards from anyone who intends to move in or be regularly present, before they start; and from home child care visitors, agency staff who may interact with children, volunteers and students.

How recent (s. 59(2))

A police record check, including a vulnerable sector check, satisfies the regulation only if it was conducted by a police service and prepared no earlier than six months before the day the licensee obtains it. A check a new hire brings from a previous job is fine if it is within that window; otherwise it is not.

Starting before the check arrives (s. 61(1))

A person may start before providing a check if the licensee requires them to apply as soon as reasonably possible, the waiting time justifies it, and the employer puts additional measures in place to protect children until the check arrives. The measures have to be in the written policy, and s. 65(e) itself gives the example: requiring the supervision of all interactions between the person and the children.

The five‑year and one‑year cycle (s. 62)

Renewal rules for a person who continues in a position interacting with children
Document	When	Notes
New vulnerable sector check	On or before every fifth anniversary of the most recent check	The six-month freshness rule applies to the new check too.
Offence declaration	Every calendar year in which no check is obtained, no later than 15 days after the anniversary of the most recent declaration or check	Covers the period since the last declaration or check.
Offence declaration after a conviction	As soon as reasonably possible after any Criminal Code conviction	s. 62(4)
Notice of a prohibition	Immediately, if the person becomes prohibited under s. 9(1) of the Act	s. 62(5), in force since July 1, 2026

The anniversary that matters for the declaration is the date of the most recent declaration or check, so the due date can drift forward by a few days each year if declarations are collected late. Many programs fix a date for everyone instead, which is allowed as long as nobody’s declaration falls later than the regulation permits. The screening dates tool works the dates out for one person.

Breaks and leaves (ss. 63, 62.1)

If the relationship ends and later resumes after six months or more, a new check is required before the person comes back. If the gap was shorter, or the person was on a leave of absence, whatever check or declaration would have fallen due during the gap is obtained before they return. While a renewal check is applied for, the person may continue with additional protective measures in place (s. 62.1).

Volunteers, students and copies (s. 60(3))

For volunteers and students, a licensee may accept a copy of a check rather than the original. If the copy is more than six months but less than five years old, the person also provides an offence declaration covering the time since; at five years or more, a new check is needed.

People under 18, and turning 18 or 19 (s. 61(2) to (4))

No check or declaration is required from anyone under 18. Someone who turns 18 in a position interacting with children provides, within a month, a statement disclosing any Youth Criminal Justice Act findings of guilt that led to an adult sentence; someone who turns 19 must apply for a vulnerable sector check within a month of the birthday.

Contractors and visiting professionals (s. 61.1, centres)

For other people who provide services to children at a centre and are employed elsewhere, such as a contracted music teacher or a cleaning contractor who works while children are present, the centre obtains either an offence declaration or an attestation from the person’s employer that it has a vulnerable sector check on file from the last five years with no listed convictions of the kinds in s. 9(1) of the Act, renewed yearly within 15 days of the anniversary (s. 61.1). Members of a regulated health profession acting in their profession, such as a visiting therapist, are among the people s. 61.1(3) exempts.

The policy (s. 65)

The written policy covers how checks and attestations are obtained, how declarations are submitted, how confidentiality is protected, how any information revealed may be considered and used, and the additional measures used while a check is outstanding.

Sources

O. Reg. 137/15 as consolidated on e-Laws (current to September 28, 2026; last amendment O. Reg. 197/26). This guide explains the regulation in plain words; it is not legal advice, and the Ministry’s program advisors decide compliance.