Consultation on the General Medical Council Legislative Framework Reform

The UK Government has set out to reform the way that healthcare professional regulators work to modernise and bring the regulatory system up to date.  

As part of the plans to reform, the General Medical Council (GMC) became a multiprofessional regulator responsible for the regulation of physician associates (PAs) and anesthesia associates (Aas) from December 2024.  

Following on from this, in March 2026 the government launched a consultation on the draft of the ‘General Medical Council Order 2026’ (‘the draft order’) which will reform how doctors and other healthcare professionals are regulated.  

As the consultation draws to a close on the 23rd of June 2026, associate solicitor, Martha Odysseos looks at why change is needed. 

 Why Reform Is Being Proposed  

The current legislative framework governing the GMC is widely viewed as outdated and overly rigid. The reforms aim to create a system that is faster, fairer, better placed to protect the public and help the workforce meet future challenges.  

 Key Changes  

The proposed legislation, once fully in force, will repeal the majority of provisions in the Medical Act 1983 and the entire Anaesthesia Associates and Physician Associates Order 2024.  

 The legislation will mean that there is: 

• Increased GMC Autonomy 

Part of the increased flexibility is for regulators to be provided with powers to set more of their own operating procedures through rules or guidance that do not require the approval of Parliament, or where the matter relates to devolved matters, the Scottish Parliament or the Privy Council. Article 80 of the draft order sets out that rules must be made by GMC in writing. An instrument by which rules are made must state the power that such are made and it must also be published by GMC 

This means that the GMC will be able to amend rules more efficiently without Privy Council approval.  

• Creation of a Single Register:  

Article 32 of the draft order sets out that GMC must establish a single register of the regulated professionals.   The register is to consist of only 3 parts, one for each regulated profession (medical practitioners, physician assistants in anaesthesia and physician assistants). The draft order provides that the register must be maintained by GMC’s registrar. A regulated professional must be entered in the part of the register that relates to their relevant profession. They must have only one entry in any one part of the register. 

A unified register will improve transparency for patients and employers.  

• Flexible Registration and Training Standards 

Article 34 of the draft order sets out that GMC must determine standards applicable to registration as a regulated professional whereas Article 35 provides that an application for registration must comply with such procedural requirements as may be prescribed by GMC in rules and such additional requirements as GMC’s registrar may direct.  

This means that GMC will gain powers to adapt requirements more quickly.  

• New Offences 

Article 29 of the draft order provides that a person commits an offence if the person, with intent to deceive, falsely represents a person (including himself or herself) to have a qualification approved by GMC.  

A person who commits an offence under this article is liable on summary conviction in England and Wales to a fine, or on summary conviction in Scotland or Northern Ireland to a fine not exceeding level 5 on the standard scale. 

Reform of Fitness to Practice Proceedings:  

Paragraph 8 establishes the Medical Tribunal Service (MTS), currently known as the Medical Practitioners Tribunal Service (MPTS). MTS will remain as a statutory committee.  

Paragraph 19 provides the power for GMC to convene appeal panels and for MTS to convene fitness to practise panels to exercise, on behalf of GMC, the adjudicatory functions conferred on appeal panels and fitness to practise panels respectively. For appeal panels and fitness to practise panels, GMC must make rules setting out further detail regarding, for example, the constitution of a panel and the process for making appointments.  

This should hopefully mean that processes will become faster, less adversarial, and more efficient.  

What This Means for Healthcare Professionals  

The proposed reforms represent a major shift in healthcare regulation. While aiming to improve efficiency and patient safety, they also introduce new legal considerations for practitioners.  

These reforms may lead to faster investigations, evolving regulatory rules, and increased need for early legal advice.  

How Olliers Solicitors Can Help  

Olliers Solicitors have extensive experience advising healthcare professionals facing GMC investigations and fitness to practise proceedings. Early legal advice is likely to become even more important under the evolving framework and the pro-active and engaging approach of the team at Olliers means that we are perfectly placed to assist. 

Olliers is unique in its ability to offer a truly integrated defence, seamlessly combining our top-tier expertise in criminal and regulatory law. This dual capability means we provide protection against parallel proceedings, regulatory sanctions and criminal prosecution. We manage the entire picture, preventing costly overlaps and ensuring that the defence strategy supports both sets of proceedings. 

If you are facing an investigation or the possibility of an investigation by your regulator or professional body and wish to speak to one of our team, please contact us at the earliest possible opportunity for a confidential discussion. We are able to represent you wherever you are based across England and Wales. All of our specialists have substantial experience in dealing with a range of regulatory investigations and proceedings, as well as, complex criminal cases.