14 June 2026 | Reviewed September 2026 — checked against CQC's current registration, primary health services and assessment guidance
General practice and other primary care services are established parts of CQC regulation in England. What matters for providers in 2026 is understanding how registration scope, service type, regulated activities and CQC's current assessment arrangements apply specifically to primary care.
Copy link
GP practices and other primary care services in England must register with CQC when they carry on regulated activities for which registration is required. The precise registration requirements depend on who provides the service, which regulated activities are carried on, and where they are provided. Once registered, primary care services are regulated against CQC's five key questions — Safe, Effective, Caring, Responsive and Well-led — with sector-relevant quality statements and evidence categories. In 2026, providers should also be aware that CQC is testing and piloting a redesigned assessment approach, while existing inspections continue.
CQC regulates health and adult social care services in England. Primary care is not a new addition to that system, and providers should not treat adult social care requirements as a substitute for primary-care-specific guidance.
CQC currently publishes dedicated regulatory information for GPs and online primary care services. For assessment evidence, it also distinguishes between sector groups.
Its primary health services evidence guidance includes:
CQC separately publishes evidence-category guidance for independent doctors, including:
Both groups are assessed against CQC quality statements, but CQC recognises differences in how services operate and reflects those differences when considering individual sources of evidence.
The practical starting point is therefore not to ask whether primary care follows an adult-social-care inspection model. It is to establish the provider's registration scope and service type, then use the current CQC guidance relevant to that service.
CQC registration is required where a person or organisation carries on a regulated activity in England and no relevant exception or exemption applies.
The regulated activities are set out in Schedule 1 of the Health and Social Care Act 2008 (Regulated Activities) Regulations 2014.
For a GP or primary care provider, the correct registration scope depends on the services actually provided. Providers should therefore determine:
CQC's scope-of-registration guidance should be checked against the actual service model rather than assuming that every GP practice, PCN or collaborative arrangement has identical registration requirements.
The existence of a Primary Care Network does not by itself answer the registration question.
CQC publishes specific guidance for primary care networks, federations and GP services working in collaboration. The relevant issue is who is carrying on the regulated activity under the particular arrangement.
Providers working collaboratively should therefore establish the legal provider, regulated activities, locations and management responsibilities before assuming that an existing member practice's registration covers the service.
CQC updated its general provider-registration guidance on 25 August 2026.
It states that applicants must submit only when everything is in place to start providing the service, including the locations and staff needed to provide it. CQC says it cannot hold applications that are not ready.
Applications are reviewed for completeness and relevance, including the supporting documents. CQC states that incomplete applications will be rejected.
Depending on the provider structure, one or more managers may also need to register. Manager forms must be submitted with the provider application where required.
If an application passes the initial checks, CQC's assessment may include:
CQC says the registration process is rigorous and can take a few months. A provider cannot manage regulated activities until CQC has confirmed the required registration.
Every registered provider must have an accurate and up-to-date Statement of Purpose.
For primary care providers, it should accurately describe the provider, its aims and objectives, its locations, the regulated activities carried on at those locations, the people the service is for and the relevant registered-manager arrangements.
The Statement of Purpose should agree with the application and supporting documentation. It should not describe a broader or different service from the one the provider is actually applying to register.
Online primary care requires particular attention in 2026.
CQC states that, for applications submitted from 22 June 2026, online primary care services must provide additional documents alongside the documents required from all applicants:
Applicants must also complete CQC's additional form for providers of online primary care services.
Where a provider plans to offer online primary care alongside other services, CQC says it must submit the documents required for each relevant service and ensure that its documentation covers all of the services it proposes to provide.
CQC's regulatory approach is changing during 2026, so providers should avoid relying on a single historical description of how every assessment will operate.
The five key questions remain :
CQC's published primary health services guidance says it assesses evidence against quality statements and groups evidence into six categories:
CQC describes its sector evidence-category lists as guides rather than checklists and recognises differences between services when considering individual evidence sources.
In June 2026, CQC announced a structured programme of pilots, testing and evaluation for its new assessment method.
The testing programme runs between June and October 2026, with final evaluation planned for November 2026.
CQC states that pilot assessments run alongside, rather than instead of, existing inspections. Participation in a pilot is voluntary and declining to participate has no regulatory consequence.
For providers, the safest approach during this transition is therefore to follow CQC's current published guidance and evidence requirements while monitoring CQC's announcements about the redesigned assessment approach. Providers should not assume that a proposed or pilot methodology is already the final operating model.
The evidence CQC considers depends on the scope and circumstances of the assessment. Providers should be prepared to demonstrate how their service meets the relevant quality statements rather than assuming that one key question will always dominate an inspection.
Relevant evidence may include effective governance arrangements — how the practice identifies risk, learns from incidents and significant events, ensures that clinical and administrative staff understand their responsibilities, and monitors the quality of care being delivered. CQC may consider systems as well as individual leadership, so providers should be able to demonstrate how governance operates in practice.
The Safe key question in primary care typically examines medicines management, safeguarding arrangements, infection prevention and control, and the systems in place for managing patients with complex or high-risk conditions. Relevant evidence may include policies, alongside staff understanding of how those policies operate in practice. A policy that no one has read is not evidence of safe practice — it is evidence of a documentation exercise.
The Effective key question in primary care encompasses clinical audit, quality improvement activity, staff training and competency, and the use of evidence-based practice. CQC may consider clinical-audit activity, documented outcomes and demonstrable learning, rather than treating a folder of completed audit forms as sufficient evidence of change.
Registered primary care providers have statutory notification duties, but the correct approach is to apply the specific notification category and legal threshold rather than treating every serious clinical incident or near miss as automatically notifiable to CQC.
CQC publishes notification requirements and forms covering specified events. Depending on the circumstances and type of provider, relevant categories can include matters such as:
The precise threshold matters.
For example, a serious clinical incident may engage NHS patient-safety reporting or other professional and organisational processes without necessarily falling within a particular CQC statutory-notification category. Conversely, an event that meets a CQC statutory threshold must be notified in accordance with the applicable requirement.
Primary care providers should therefore:
Do not use 'notify CQC of everything just in case' as a substitute for applying the statutory threshold accurately.
For details on specific notification obligations: See our article on CQC Statutory Notifications — What and When to Report , which covers the notification framework applicable to all registered providers including primary care.
The documentary infrastructure that CQC inspectors expect to find in a well-led primary care practice covers several overlapping areas.
Governance documentation — including a risk register, a significant events log, a complaints register, and evidence of learning from incidents — demonstrates that the practice has systems for identifying and responding to quality and safety concerns. This documentation is not primarily for the CQC. It is the operational record of how the practice manages itself. Inspectors read it as evidence of whether governance is genuinely embedded or performatively assembled.
Clinical policies and procedures — covering medicines management, safeguarding, infection prevention, chaperoning, and the management of high-risk clinical conditions — must be current, accessible to staff, and demonstrably implemented. A policy with a review date three years in the past is not a governance asset. It is a governance liability.
Staff records — including evidence of DBS checks, clinical competency assessments, mandatory training completion, and supervision arrangements — must be maintained systematically and available for inspection without delay.
Patient feedback — including complaints records, Friends and Family Test results, and the outcomes of any patient participation group engagement — forms part of the evidence base against which the Caring and Responsive key questions are assessed.
There is no universal CQC document checklist for every primary care assessment. The appropriate evidence depends on the quality statements being assessed, the service type and the circumstances.
These are practical examples, not a substitute for CQC's current sector-specific evidence guidance.
| Area | Examples of evidence that may demonstrate practice |
|---|---|
| Clinical governance | Clinical audits, quality-improvement activity, significant-event learning and evidence that actions were completed |
| Medicines | Prescribing governance, medicines reviews, monitoring processes and evidence of action where risks are identified |
| Safeguarding | Current safeguarding arrangements, staff knowledge, training and evidence of appropriate action and referral |
| Infection prevention and control | Relevant policies, audits, identified risks, actions and evidence of follow-through |
| Workforce | Recruitment records, training, competency, supervision and evidence that staffing risks are understood and managed |
| Patient experience | Complaints, feedback, patient-engagement evidence and records showing how the service responded |
| Access and responsiveness | Evidence about access, reasonable adjustments, continuity and how barriers or inequalities are identified and addressed |
| Governance and leadership | Risk oversight, meeting records, performance information, accountability and evidence that leaders act on identified concerns |
| Learning and improvement | Evidence that incidents, complaints, audits, feedback and performance information lead to identifiable changes |
| Registration accuracy | Current Statement of Purpose and evidence that regulated activities, locations and management arrangements remain consistent with registration |
A: A provider must register with CQC if it carries on a regulated activity in England and no relevant exception or exemption applies. The correct registration depends on the actual service, legal provider, regulated activities and locations.
A: No. General practice is an established part of CQC regulation. What is changing in 2026 is CQC's wider assessment approach, which is undergoing further piloting, testing and redesign.
A: They share the overarching statutory regulatory system and the five key questions, but CQC publishes sector-specific guidance and evidence categories. Primary care providers should use guidance relevant to their service rather than assuming adult social care requirements apply unchanged.
A: Safe, Effective, Caring, Responsive and Well-led.
A: People's experience of health and care services, feedback from staff and leaders, feedback from partners, observation, processes and outcomes.
A: Not simply because it is a PCN. Registration depends on the particular arrangements and who is legally carrying on the regulated activity.
A: For applications submitted from 22 June 2026, CQC requires online primary care services to provide an inclusion and exclusion criteria policy, a medical emergency policy and medical indemnity insurance evidence covering online services, in addition to the documents required from all applicants. CQC also requires its additional online-primary-care provider form.
A: No. Providers must apply the relevant statutory CQC notification category and threshold. An incident may also be reportable through NHS patient-safety or other systems, but those reporting duties should not automatically be treated as identical to CQC statutory notification requirements.
A: Not necessarily. The scope of inspection or assessment can vary according to the circumstances, risks and information available to CQC.
A: CQC announced that testing and pilot assessments would run from June to October 2026, with final evaluation in November. CQC states that pilots run alongside existing inspections. Providers should therefore distinguish current requirements from methods still being tested.
Primary care inspection readiness should be an ongoing governance discipline rather than an exercise carried out only when an inspection is announced. Current records, effective oversight, staff understanding and evidence that identified risks lead to action make it easier to demonstrate how the service operates in practice.
Documentation matters because it helps demonstrate how governance operates, but documentation should not be confused with quality itself. CQC can draw on different evidence categories, including people's experiences, staff and leader feedback, partner feedback, observation, processes and outcomes. The objective is therefore a coherent relationship between practice, governance and evidence — not simply a larger inspection folder.
For primary care providers approaching registration or preparing for assessment, the investment in governance infrastructure — policies, registers, audit programmes and notification systems — is not a regulatory compliance exercise. It is the foundation of a well-led service that can demonstrate its quality to patients, commissioners and the regulator with evidence rather than assertion.
Statement of Purpose, policies, governance frameworks, and registration support — structured from your own knowledge of your service.
Start Your CQC Registration Pack — first document free
Already registered and preparing for assessment? The CQC Inspection Prep Pack includes eight documents, document review, and the Interactive Regulatory Guidance Agent — a 30 to 45 minute walkthrough of all five CQC domains mapped to specific regulations.
Start Your CQC Inspection Prep Pack — first document free
This article aligns with PAIDS™ (Professional AI Documentation Standards) — well-sourced, thoroughly researched, and defensible with verifiable data. reporticaai.co.uk/governance
Need help choosing?