Background checks by country: what employers can see

In France, the Netherlands, the UK and Australia, an employer cannot pull your criminal record on its own. You apply for the certificate yourself and decide whether to hand it over, and what it shows depends on the country: a French extract lists only the most serious convictions, a Dutch certificate is a pass or fail judgment tied to the specific job, and a UK basic check shows only convictions that are not yet spent. In Japan, a criminal record counts as sensitive personal data that an employer generally needs your consent to collect, while in the UAE the police certificate application names the company requesting it.

Criminal records are one part of screening. Employers also verify degrees, and in the Gulf a foreign degree must be formally attested before it counts. This guide sets out the documents, fees, processing times and legal limits in seven countries as of October 2026. It covers official certificates and verification procedures, not the database searches, credit checks or social media reviews that private screening firms run, which fall under separate rules in each country.

Criminal record certificates in four countries

All four systems below make the job seeker the applicant. They differ in what the certificate discloses, what it costs, and whether the employer has any role in the request.

Country	Document	Who applies	What it shows	Fee	Typical time
France	Bulletin n°3	Only the person concerned or a legal representative	Most serious convictions only, such as unsuspended prison terms over two years	Not stated on the official page	Online or by post
Netherlands	VOG certificate	Employer starts the request; applicant completes it	A yes or no decision on whether any record conflicts with the job’s screening profile	€33.85 online, €41.35 at a municipality	Within 4 weeks, or 8 if offences need assessment
UK (England and Wales)	Basic DBS check	Applicant, aged 16 or over	Unspent convictions only	£20	Up to 3 days, then posted
Australia	National Police Certificate	Applicant, who must state the purpose	Court outcomes, pending charges and warrants; spent convictions excluded under state law, with exemptions for some jobs	A$57	Most within 48 hours

The French rules go furthest in limiting the employer. A company may look at a candidate’s bulletin n°3 but may not keep it; it can only record in the personnel file that the check took place. The Dutch system works differently: the Justis screening agency judges whether a record matters for the role, so an accountant with a fraud conviction would be refused a certificate, while a drink-driving conviction might not block the same person.

The Dutch fees above come from a government business portal last updated in March 2025, the most recent published figures this guide could confirm. The UK cut its check fees on 5 October 2026, and the £20 basic fee reflects that change; all four countries review fees periodically.

Japan and the UAE treat criminal checks in opposite ways

Japan: consent first

Japan’s Act on the Protection of Personal Information lists a criminal record, meaning a final conviction, as “special care-required” personal information. Guidelines from the Personal Information Protection Commission say that acquiring this category generally requires the person’s prior consent, with limited exceptions set out in the law.

The criminal record certificate that prefectural police issue is framed around foreign authorities, such as embassies handling visa applications. It is free, must be applied for in person with fingerprinting, and is handed over rather than posted. The published procedure does not offer a version for domestic employment, so a candidate for a job inside Japan has no direct equivalent of the UK or Australian certificate, and an employer that asks about convictions needs consent to record the answer.

UAE: the employer is named on the application

A Dubai Police Clearance Certificate costs Dh200 for residents, Dh100 for UAE citizens and Dh300 for applicants outside the country, according to Gulf News reporting updated in October 2026. Applicants choose the purpose and the requesting entity, which can be a private company, and the digital certificate is valid for three months.

Applicants abroad must have entered the UAE before. Those without a fingerprint record in the UAE system need a fingerprint document certified by a UAE embassy, which adds a step for candidates recruited from overseas.

UAE degree attestation runs through four offices

The UAE requires foreign degrees to pass through an attestation chain before they count for a work permit or a regulated job. The steps run in this order:

Notarisation and verification by the relevant authorities in the country that issued the degree.
Verification by that country’s foreign ministry.
Verification by the UAE embassy in that country.
Final attestation by the UAE Ministry of Foreign Affairs, applied for online.

The final step costs AED 150 for an individual certificate plus a courier fee of AED 40 to 150, according to a ClearTax guide to MoFA attestation updated in April 2026, and takes up to three business days. The cost and time of the first three steps depend on the issuing country and are not covered by the UAE fee, so the full chain usually takes far longer than the final stamp.

Documents not in English or Arabic need a translator approved by the UAE Ministry of Justice, and laminated originals are rejected. Both requirements apply before the ministry will process the application, which makes them the first things to check on a degree certificate issued years earlier.

Where the rules leave candidates exposed

A spent conviction does not disappear everywhere at once. The UK basic check omits spent convictions, but Australia’s certificate excludes them only under the relevant state or territory law, and some job categories are exempt. The same record can therefore appear on one application and not on another, depending on the state and the stated purpose.

Middlemen add cost without adding speed. The Justis agency warns against intermediaries that offer to handle Dutch VOG requests, since the employer and applicant must complete their own parts in any case. The UK, Australian and Dubai certificates can likewise be applied for directly through the official services listed above.

India’s consent rules for candidate data start in May 2027

India is moving to a consent-based system for personal data, including the data collected in background verification. The Digital Personal Data Protection Rules were notified on 13 November 2025, and the obligations covering notice, consent and data subjects’ rights apply from 13 May 2027, according to a summary by law firm S.S. Rana, 18 months after notification.

The rules do not set out separate provisions for recruitment. How they apply to candidates who are not yet employees, and whether employers can rely on grounds other than consent for them, remains unsettled until the Data Protection Board or the courts address it.

The next fixed date is 13 May 2027, when Indian employers and the verification firms working for them must have notice and consent processes in place for every candidate whose data they collect.