Do I need to be registered with the CQC as a private GP?

Who has to register

The CQC registers regulated activities, not professions. The legal entity that carries on the activity must register: an individual doctor working as a sole trader, a partnership or a company. If you work as a sole practitioner, that entity is you. If you work for a partnership or company, the entity registers and you work under its registration.

The regulated activities are listed in Schedule 1 of the Health and Social Care Act 2008 (Regulated Activities) Regulations 2014. For a private GP service the usual ones are:

• Treatment of disease, disorder or injury: almost every private GP service carries this on.
• Diagnostic and screening procedures: for example taking blood, ECGs or other tests.
• Surgical procedures: if you offer minor surgery beyond the procedures the regulations carve out.
• Family planning: if you fit coils or implants.
• Transport services, triage and medical advice provided remotely: relevant to online and telephone services.

Carrying on a regulated activity without registration is an offence under section 10 of the Health and Social Care Act 2008, punishable by a fine, imprisonment or both.

The exemption for doctors in private practice

Schedule 2, paragraph 3 of the 2014 Regulations exempts treatment given in a surgery or consulting room by a doctor (or a group of doctors) who:

1. is a registered provider of treatment of disease, disorder or injury, or is employed by one, and
2. is on the medical performers list for a designated body, or is employed by a provider that is a designated body.

In practice this most often helps an NHS GP who is on the performers list and a partner in, or employed by, a CQC-registered practice, and who sees a few private patients face to face in a consulting room. CQC guidance says the exemption does not apply:

• to treatment provided remotely by telephone, video or email
• to treatment outside a surgery or consulting room, such as home visits
• to an organisation or partnership that employs a range of staff as well as doctors
• to the procedures listed in Schedule 2, paragraph 4, including general anaesthesia or intravenous sedation, intravenous medicines, endoscopy, x-ray and other imaging, and most cosmetic surgery.

During the pandemic the CQC said it would not require registration from doctors who would have been exempt but had moved to remote consultations. Its current scope guidance is clear that remote treatment is outside the exemption, so do not rely on the pandemic statement.

Practising privileges and working for someone else

If you consult under practising privileges in a registered hospital or clinic, and the consultation runs under the host’s management, policies and records, it may be covered by the host’s registration. If the host is only your landlord and you run the service yourself, you need to register. Ask the host to confirm in writing which activities its registration covers.

If you are employed or engaged by a registered private GP provider, including an online one, the provider holds the registration. Your job is to check that it covers the activities you will carry out.

Some services are outside CQC registration altogether. These include occupational health arranged by an employer for its own staff, and assessments arranged by a government department or by an insurer for purposes such as travel or accident claims. Work paid for through private medical insurance is not exempt.

A quick way to work it out

1. Will the service be in England? If not, see the devolved regulators below.
2. Will you carry on a regulated activity? For private general practice, almost certainly yes.
3. Is another registered provider responsible for the service (employer, host hospital or online provider)? If so, confirm that its registration covers you.
4. If you run it yourself, do you meet every condition of the doctor exemption, with no remote work, no staff beyond doctors and none of the excluded procedures? If not, you must register.

If you are unsure, ask the CQC’s National Customer Service Centre before you see patients. The CQC also publishes a diagram and a text version of the exemption questions on its scope of registration pages.

NHS practices adding private services

An NHS GP practice that adds private services within activities and locations it is already registered for does not need a new registration. It must keep its statement of purpose accurate and tell the CQC when it changes. A new regulated activity or location needs an application to vary the registration. Private services run through a separate legal entity, such as a new limited company, need that company to register. The NHS contract has its own rules about private work, covered in restrictions on seeing private patients in NHS practices.

What registration involves

• An application made when everything is ready to start, using the CQC’s current application forms.
• A registered manager if the provider is a company or partnership, or an individual who will not be in day-to-day charge.
• An enhanced DBS check with the appropriate barred list, no more than 12 months old. Doctors send the original certificate.
• A statement of purpose and supporting documents, such as policies, and evidence that your premises are ready.
• Assessment, which may include a fit person interview and a site visit.

The CQC says registration “can take a few months”. It has been working through a backlog, and its 2025/26 target was to issue 80% of decisions within 10 weeks of a valid application. Plan for longer and do not book patients until you have your certificate. Details are in how to register with the CQC and how long registration takes.

There is no separate application fee, but every registered provider pays an annual fee. At the time of review the CQC’s published fee for a single-location independent doctor or clinic was £1,867 a year.

After registration

The CQC assesses services under five key questions: safe, effective, caring, responsive and well-led. It is replacing its single assessment framework with sector-specific frameworks. Its initial response to the 2025 consultation said these would bring back key lines of enquiry and drop scoring, but the final version had not been published at the time of review. Check the CQC website for the current framework before you prepare evidence. See will the CQC want to inspect me? Once you are registered, you can check your readiness with our free CQC inspection readiness scorecard.

In Wales, Scotland and Northern Ireland

Nation	Regulator	Who registers
Scotland	Healthcare Improvement Scotland (HIS)	Independent clinics, including private GP services in premises. NHS services are excluded. HIS says processing takes a minimum of six months.
Wales	Healthcare Inspectorate Wales (HIW)	Independent clinics where private-only medical services are provided regularly (at least monthly), and independent medical agencies such as online private GP services.
Northern Ireland	RQIA	Independent clinics, including a consulting room where a doctor who provides no health service work practises privately, and independent medical agencies.

The exemptions differ in each nation, so check with the regulator where the service will be delivered.