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Navigating the 2027 criminal vetting deadline: What South African schools need to know

A court-backed settlement requiring the Department of Basic Education (DBE) and provincial education departments to vet all public-school employees against Part B of the National Child Protection Register (NCPR) by 31 March 2027 has renewed focus on an important aspect of school governance: ensuring that individuals who work with or have access to children are appropriately vetted.
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While the settlement specifically concerns public-school employees, it serves as a timely reminder that staff vetting is far more than an administrative formality. It is a fundamental component of child safeguarding and an important part of a school's broader governance and compliance responsibilities.

Recent criminal-screening data from TPN Credit Bureau illustrates why these processes remain necessary. The latest data also reflects growing use of screening processes within the education sector, with criminal-screening activity conducted through TPN's systems increasing by 27% between 2025 and 2026.

Findings

In 2026, 3.33% of criminal screening checks conducted for TPN-affiliated schools returned a possible illicit-activity finding. Although this represents a decrease from 4.01% in 2025 and 3.81% in 2024, it demonstrates that routine screening continues to identify matters that may warrant further consideration before an individual is granted access to a school environment.

The overwhelming majority of screening checks returned no adverse findings. However, the purpose of vetting is not to assume that risk exists across the workforce. Rather, it is to identify potential concerns before individuals are placed in positions where they may have direct or indirect access to learners.

The category breakdown of records that returned possible illicit-activity findings provides further insight into the nature of the matters identified through screening:

  • Traffic and transport-related matters: Increased from 18.44% in 2025 to 20.81% in 2026.
  • Drug-related matters: Increased from 7.09% in 2025 to 11.41% in 2026.
  • Firearms and weapons-related matters: Increased from 2.84% in 2025 to 4.70% in 2026.
  • Fraud and financial-crime matters: Increased from 1.42% in 2025 to 4.03% in 2026.
  • Serious violent-crime matters: Declined from 5.67% in 2025 to 2.68% in 2026.

It is concerning that violent and serious crimes constitute over 23% (23.49% exactly) of the total number of crimes found in 2026. This has remained consistently above 20% since 2022.

The data also indicates that a notable proportion of flagged records involved more than a single offence or matter. Records reflecting multiple convictions, a conviction together with a case awaiting trial (CAT), multiple counts or additional offences accounted for 38.46% of flagged records in 2023. The figure increased to 50.43% in 2025 before declining to 28.68% in 2026.

Importantly, the significance of these findings extends beyond risk management and speaks directly to schools' legal and safeguarding responsibilities.

Screening obligations

South Africa's child-protection framework places specific screening obligations on institutions and employers that permit individuals to work with or have access to children. In a school environment, safeguarding obligations are shared across the various parties responsible for employing and managing staff, rather than resting solely with a government department.

These obligations extend beyond a standard criminal-record check.

Section 126 of the Children's Act requires certain institutions, including schools, to establish whether individuals who will work with or have access to children appear in Part B of the National Child Protection Register before permitting them to do so.

Child protection and sex offender registers

TPN's screening processes incorporate criminal-record screening as well as verification against the National Child Protection Register (NCPR) and the National Register for Sex Offenders (NRSO), helping schools address the various safeguarding requirements established under South Africa's child-protection legislation.

Schools should also be aware that South Africa maintains separate statutory mechanisms aimed at protecting children and other vulnerable persons.

The NCPR, established under the Children's Act and administered by the Department of Social Development, records individuals who have been found unsuitable to work with children due to abuse, neglect, exploitation or related conduct.

The NRSO, maintained by the Department of Justice and Constitutional Development in terms of the Criminal Law (Sexual Offences and Related Matters) Amendment Act, serves a different purpose and records persons convicted of certain sexual offences against children and other vulnerable persons.

While the two registers serve distinct legislative functions, they form part of the same broader objective: protecting children and vulnerable persons from harm. Together, they provide safeguards that extend beyond traditional criminal-record screening and address different types of conduct that may render an individual unsuitable to work with children.

Comprehensive screening process

Schools should therefore view vetting as a layered process rather than relying on a single screening mechanism. Criminal-record checks and verification against statutory registers each serve different functions and together help build a more comprehensive safeguarding framework.

The approaching 31 March 2027 deadline has renewed attention on these requirements and serves as a reminder that safeguarding learners begins long before an individual enters a classroom. While TPN's latest data suggests that adverse findings remain relatively low, routine screening continues to identify potential concerns that may otherwise go undetected.

Ultimately, effective vetting is not simply about regulatory compliance. It is one of the most practical measures available to schools to support learner safety, manage risk and maintain the trust that parents and communities place in educational institutions every day.

About Marissa van der Merwe

Marissa van der Merwe, Legal Counsel at TPN Credit Bureau
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