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

About our submission

We have undertaken initial scoping work and engagement with voluntary organisations to inform our position on proposals included within this consultation, including:

• Engaging with voluntary organisations with a particular interest in volunteering and/or specific concerns regarding these proposals, and
• Engaging with the proposals as a member of the Cross Party Group on Volunteering.

Summary of response

SCVO supports any moves to ensure that volunteering is accessible and inclusive and, therefore, understands the proposals by Disclosure Scotland to provide waiver discounts to care experienced people and those on particular benefits. However, it is crucial that such positive steps do not come at the expense of further pressure being placed upon a voluntary sector that is already struggling.

After years of underfunding and upheaval, the pandemic and cost-of-living crisis are the latest chapters in a longer story of instability and unpredictability in voluntary sector resourcing. The cost-of-living crisis has, for many organisations, increased demand for the essential services and support the sector provides while organisations, like households, struggle with rising costs. In addition, challenges facing the recruiting and retaining of volunteers only continue to grow.

It is, therefore, in these circumstances that consideration must be given to the potential impact of Disclosure Scotland’s proposals. We believe any move to replace the Protecting Vulnerable Groups (PVG) scheme fee waiver with a fee discount will be damaging to voluntary organisations, potentially increasing financial difficulties for those organisations who seek to absorb volunteer expenses, and almost certainly exacerbating the rising level of volunteer shortages we are seeing across Scotland. If resourcing is required by Disclosure Scotland to improve the accessibility of volunteering for the identified groups, that capacity building must be met by the Scottish Government and not by volunteers, prospective volunteers, and a voluntary sector that continues to struggle.  

Our response

Do you agree with the proposal to move to a fee discount for volunteers in Qualifying Voluntary Organisations?

No.

What information do you think we need to consider when proposing moving to a fee discount for volunteers in Qualifying Voluntary Organisations?

The voluntary sector in Scotland is struggling. Readily available statistics clearly outline the current reality in which the voluntary sector in Scotland is fighting to meet increased demand for services, grappling with spiralling costs and increasing financial difficulties, and facing greater challenges in retaining staff and attracting volunteers. In such circumstances, any proposal to remove the PVG scheme fee waiver for volunteers would only exacerbate such volunteer shortages, resulting in further challenges for voluntary organisations, the people and communities they support, and volunteers, and prospective volunteers, themselves. Our sector is in an unsustainable position where it is further support that is vitally required, rather than yet more setbacks and barriers.

The most recent wave of the Scottish Third Sector Tracker has shown that, in Winter 2023, 95% of organisations reported facing challenges, up from 88% in the Spring. The issues most frequently ranked as the top challenge were that of rising costs/inflation and difficulty fundraising (both 15%), closely followed by volunteer shortages and financial or cash flow restraints (both 14%). 44% of organisations listed rising costs and/or inflation in their top three challenges, and 35% listed financial or cash flow constraints (up from 23% in Spring 2023).

The Tracker’s waves 1-6 report has also highlighted that there has been an increase in organisations listing financial difficulties as a top three challenge between August 2021 and April 2023, jumping from 47% to 71%. At the same time, demand for core services and activities has also risen from 56% to 63%.

Against this backdrop of increasing uncertainty, ongoing difficulties, and rising demand, the Tracker’s latest wave has also shown that, as of Winter 2023, 33% of voluntary organisations list volunteer shortages as one of their top three challenges. This is unsurprising, coming on the back of the Tracker’s waves 1-6 report showing that, between August 2021 and April 2023, “staffing pressures relating to paid staff and volunteers” increased significantly as a top three challenge for organisations from one-third to two-thirds. Furthermore, we know from SCVO’s recently refreshed Sector Stats that volunteer rates have fallen in recent years from 26% in 2018 to 22% in 2022.

This data is supported by Volunteer Scotland’s The State of Volunteering in 2023 report which highlighted that a shortage of volunteers was the top concern for 17% of organisations, ranking within the top three issues for 34%. The report also references a survey conducted by the Volunteer Action Plan Cost of Living Task Group, which found that 76% of participants faced difficulties recruiting volunteers, with 61% struggling to retain them.

As set out in Volunteer Scotland’s response to this consultation, there are a number of voluntary organisations who aim to take steps to ensure that volunteers are not out of pocket as a result of their volunteering, in alignment with the Volunteer Charter which includes, amongst its principles for sustainable and legitimate volunteering, a commitment to ensure that no-one should be prevented from volunteering due to their income. As a result, these changes could have serious implications for many voluntary organisations who are posed with a choice between stretching their resources further to absorb the impact of this proposal or risking even greater challenges in recruiting volunteers, with the potential for many prospective volunteers to be put off or deprived opportunity by additional costs.

In such a situation, organisations who would choose to stretch their resources further to absorb the impact would, given the already unsustainable and uncertain financial circumstances that plague the voluntary sector in Scotland, find those difficulties exacerbated. And, for organisations who would opt instead to risk even greater challenges in recruiting volunteers, the existence of vital services that rely on those volunteers could be threatened.

The latter option would also subsequently have a particular impact on volunteers on low incomes who would find it more difficult to volunteer due to the financial implications, missing out on the benefits of volunteering and being unable to provide their time and, where applicable, their skills and experience to the organisations and services that need it. Directly imposing barriers to volunteering on individuals on lower incomes would have a considerably negative impact on those individuals and across the voluntary sector. At a time when the voluntary sector needs respite and support to alleviate the barriers to volunteering that exist currently, it is both concerning and disappointing to be faced with a proposal that will simply worsen the situation.

SCVO also shares the concerns raised by Volunteer Scotland that this proposal could undermine the commitment to sustainable and inclusive volunteering which the Scottish Government committed to in the 2022 Volunteer Action Plan. Simply put, sustainable and inclusive volunteering in Scotland cannot be successfully achieved by erecting further barriers to volunteering, particularly by foisting increased costs on those from deprived areas or on low incomes.

SCVO recognises that this proposal has been constructed in a bid to free up resources to implement measures that would be positive for those on particular benefits and care experienced people. We support all steps taken to ensure volunteering is accessible and inclusive for everyone, including the groups that these proposals seek to support. However, such steps cannot come at the cost of inflaming an already critical situation that the voluntary sector finds itself in. It is, therefore, vitally important that the Scottish Government decides against progressing the proposal to replace the fee waiver for volunteers with a fee discount and, instead, should commit to maintain the fee waiver as it currently is.

SCVO also sympathises to some degree with the situation that Disclosure Scotland finds itself in, desiring to implement measures to make volunteering more accessible for the identified groups but not having the resources in place to do so without generating finances elsewhere, in this case by replacing the fee waiver with a fee discount. As detailed above, the challenges that arise from a lack of resourcing are not lost on Scotland’s voluntary sector and, too often, it is our sector that bears the brunt of further cuts to resourcing. Therefore, perhaps instead of seeking to introduce proposals to the detriment of the sector, the Scottish Government should consider resourcing Disclosure Scotland to the level required to implement the proposed measures designed to encourage people on particular benefits and care experienced people to volunteer, without also removing the fee waiver for volunteers.

Alternatively, if these proposals are indeed to be pursued, it is vital that the voluntary sector itself is properly resourced to be able to tackle yet another challenge. By ensuring the Scottish Government’s Fairer Funding commitment directly mirrors SCVO’s own Fair Funding calls, the voluntary sector in Scotland would hugely benefit from a funding landscape that is fair, flexible, sustainable, and accessible to ensure that organisations can provide the services and projects that are crucial to communities across Scotland. By guaranteeing Fair Funding that includes longer-term funding models, ensures processes are accessible and consistent, and provides more unrestricted funding with in-built uplifts, the voluntary sector in Scotland would at least be in a healthier position when proposals that are detrimental in some way to organisations are put forward, allowing additional costs or increased volunteer shortages to be accommodated at least to some degree. However, without a properly and fairly resourced voluntary sector, such proposals will only further punish organisations already at breaking point.

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

No.

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

As detailed previously in this response, the funding challenges facing the voluntary sector in Scotland at present are unsustainable. Therefore, SCVO is opposed to the significant fee increase for accredited body registration, given it would increase the financial burden on some voluntary organisations.

What information do we need to consider for the Business and Regulatory Impact Assessment?

As outlined above and in every wave of the Scottish Third Sector Tracker, the voluntary sector finds itself struggling against a tide of spiralling costs, increasing pressure, and rising demand for services. The situation is unsustainable and large numbers of organisations go into each year wondering if it may be the year that their very survival is at risk. And yet, despite all of that, our sector remains a vital actor in Scotland’s economy.

With over 46,500 organisations across Scotland, the voluntary sector is wide-reaching and covers every area of society. This includes 23,600 Scottish charities and over 1,000 UK-wide charities operating in Scotland, as well as over 20,000 community groups not registered as charities.

In 2022, the sector had a turnover of £9.2bn, with spending increased by nearly £1bn over 2021/22 reaching £8.8bn. In the same year, the voluntary sector in Scotland employed just over 133,000 people, making up 5% of the Scottish workforce. The sector saw a nominal rise in overall income between 2021 and 2022 of £560m, or 7.8%. Adjusting for inflation, real income growth was just over 4%. 64% of Scottish charities increased their spending, rising to 70%-80% for larger charities. This is a big change from 2020/21, when 72% of Scottish charities decreased expenditure.

The sector now manages total assets of £39bn, up from £30bn in 2018. Net assets held by the sector are now worth £24bn, having more than doubled over the last decade, up from £9bn in 2011. Around £31bn of the sector’s assets are made up of fixed assets such as buildings, up from £25bn in 2018. Almost half of the sector’s fixed assets are managed by just 140 housing associations.

The figures above are staggering, particularly given the breaking point the sector has reached in terms of funding and capacity, showing clearly that the voluntary sector is a crucial economic actor in Scotland, and yet this is something that is seldom heard in debates and discussions about our economy. The voluntary sector creates and distributes wealth on a scale that is consistently ignored. We would ask that the Business and Regulatory Impact Assessment does not ignore this economic contribution and, instead, considers the impact these proposals could have on the sector’s contribution to Scotland’s economy, given the increased pressures they will undoubtedly place upon voluntary organisations.

What information do we need to consider for the Equality Impact Assessment?

As outlined above, SCVO believes that these proposals will negatively impact on steps being taken to improve accessibility to volunteering, adding extra barriers to volunteering for those on low incomes or from deprived areas in particular. The proposal to remove the fee waiver for volunteers could also lead to further increased volunteer shortages faced by voluntary organisations who provide volunteer-led services that support vulnerable people. Therefore, we would ask that the Equality Impact Assessment considers the potential impact of the proposal to remove the fee waiver for volunteers on the equality of access to volunteering opportunities, and how this could particularly impact individuals, families, and communities who rely on volunteer-led services and support.

What information do we need to consider for the Children’s Rights and Wellbeing Impact Assessment?

With over a half of all voluntary organisations involved in social care, culture and sport, or community development, our sector provides support and services in a number of areas, including supporting children and young people across Scotland. As outlined above, it should be assumed that these proposals will directly lead to further challenges faced in the recruitment and retention of volunteers across the sector. Therefore, we would ask that the Children’s Rights and Wellbeing Impact Assessment considers the potential impact of the proposal to remove the fee waiver for voluntary organisations who provide volunteer-led services for children and young people.

What information do we need to consider for the Island Communities Impact Assessment?

In Scotland, 36% of voluntary organisations are based in rural or remote areas, with more organisations per head of population than in urban areas. Therefore, we know that any proposals that will negatively impact on voluntary organisations will have a disproportionate impact on rural or remote areas, including island communities. We would ask that the Islands Communities Impact Assessment considers this disproportionate impact.

About Scotland's voluntary sector

Our sector is a powerful force for positive change and a significant part of our economy. From grassroots volunteer-run community groups like village halls and playgroups to major providers of public services in social care and housing, the voluntary sector is present in every aspect of our society. Together the over 46,500 voluntary organisations that make up Scotland’s voluntary sector work with over 1 million volunteers and employs over 133,000 paid staff.

Our sector provides practical and emotional lifelines for people and communities, supports people on their journey out of poverty, highlights the causes of poverty, and shares solutions. We employ 5% of Scotland’s workforce, support people to be economically active, work with 1.2 million volunteers, and undertake vital environmental and medical research. Our sector is also a vital part of Scotland’s public service infrastructure, providing a range of essential public services.

About us

The Scottish Council for Voluntary Organisations (SCVO) is the national body representing the voluntary sector (sometimes referred to as the third sector). We champion our sector’s social and economic contribution, provide essential services, and debate big issues.  

SCVO and our community of 3,500+ members understand that charities, social enterprises, and voluntary groups work with people and communities across Scotland to make Scotland a better place. Find further details about SCVO at scvo.scot.    

Our policy team work closely with the voluntary sector, the Scottish Government, COSLA, and the Scottish Parliament on a wide range of issues relating to the voluntary sector’s operating environment, including funding, partnership, and regulations.

Contact

Jason Henderson 
Policy and Public Affairs Officer 
jason.henderson@scvo.scot
scvo.scot