Do I need different CQC registration depending on the service I am delivering?
Which regulated activities common private GP services fall under, the exceptions that catch people out, and what to do when you add a service.
- England
The short answer
You need one registration for your provider, but it must list every regulated activity you carry on and every location you work from. Most private GP work falls under treatment of disease, disorder or injury, but services such as ultrasound, ambulatory monitoring, excisions, coil fitting or a slimming clinic can need further activities. If you add an activity or location later, you must have a variation of your registration granted before you start.
Key points
- A provider has one registration, with conditions listing its regulated activities and locations.
- Treatment of disease, disorder or injury covers most consultations, prescribing and referrals.
- 12-lead ECGs, spot blood pressure, peak flow and spot pulse oximetry are excepted from diagnostic and screening procedures.
- Once you are registered for another activity, taking blood, urine and swab samples is also excepted, even if they go to a lab.
- Adding an activity or location needs a variation granted before you start. Update your statement of purpose and tell your indemnity provider.
One registration, several activities
The CQC registers a provider once. Your registration then has conditions that list the regulated activities you may carry on and the locations you may carry them on from. Your statement of purpose describes the services in more detail.
So you do not need a separate registration for each service. You need the right regulated activities on your one registration. It is common to register for more than one. The activities are defined in Schedule 1 of the Health and Social Care Act 2008 (Regulated Activities) Regulations 2014, and the definitions include exceptions that decide whether a particular procedure is in or out.
This article is about England. If you are still deciding whether you need to register at all, start with do I need to be registered with the CQC?
Common private GP services and the activities they need
| Service | Regulated activity | Notes |
|---|---|---|
| Consultations, face to face or remote, with prescribing, referral and follow-up | Treatment of disease, disorder or injury | The core activity for almost every private GP service |
| Blood tests sent to a laboratory | Diagnostic and screening procedures, unless you are registered for another activity | See the exceptions below |
| 12-lead ECG, spot blood pressure, peak flow, spot pulse oximetry | None for the test itself | Excepted from diagnostic and screening procedures |
| Spirometry | None if for screening or monitoring. Diagnostic and screening procedures if diagnostic | The exception covers only screening, non-diagnostic or monitoring use |
| Ambulatory blood pressure or ECG monitoring, ultrasound | Diagnostic and screening procedures | Covers equipment to monitor physiological data, and imaging |
| Curettage, cautery or cryotherapy of warts and skin lesions under local anaesthetic | None for the procedure | Excepted from surgical procedures when done by a doctor without anaesthesia or with local anaesthesia |
| Excision of skin lesions and other minor surgery | Surgical procedures | Includes the pre- and post-operative care |
| Coil insertion or removal | Family planning | The activity is specifically the insertion or removal of an intrauterine contraceptive device |
| Weight-loss service prescribing for weight reduction in a slimming clinic | Services in slimming clinics | Defined as advice or treatment by or under a doctor, including prescribing for weight reduction |
The table is a guide to the regulations, not a ruling on your service. Where a service sits near a boundary, ask the CQC before you apply.
The exceptions that matter
Diagnostic tests. Paragraph 7 of Schedule 1 lists procedures that are not diagnostic and screening procedures. For GPs the useful ones are:
- taking blood by pin prick or from a vein, where the sample does not need to go to a laboratory
- urine samples that do not go to a laboratory, and wound swabs, hair samples or nail clippings
- non-ambulatory blood pressure, 12-lead ECG, peak flow and spot pulse oximetry
- spirometry for screening, non-diagnostic or monitoring purposes.
There is a second, wider exception. If you are registered for another regulated activity, such as treatment of disease, disorder or injury, then taking blood or urine samples, dipstick testing of urine or stool, and taking swabs or skin scrapings are also excepted. In practice, a private GP registered for treatment of disease, disorder or injury does not usually need diagnostic and screening procedures just to take bloods for a laboratory. You would need it for imaging, ambulatory monitoring or analysing samples yourself with equipment.
Minor surgery. Nail surgery on the foot, and curettage, cautery or cryocautery of warts, verrucae and other skin lesions by a doctor, are excepted from surgical procedures if done without anaesthesia or under local anaesthesia. Anything else surgical, such as an excision biopsy, needs surgical procedures.
Cosmetic injections. Subcutaneous injections to enhance appearance are excepted from surgical procedures. The Department of Health and Social Care has said it intends to bring higher-risk non-surgical cosmetic procedures into CQC regulation, so check the current position before you offer them.
Online and remote services
A private online GP service usually registers for treatment of disease, disorder or injury, like a face-to-face one. The CQC treats online primary care as a distinct service type. You complete an additional form, and applications from 22 June 2026 must include an inclusion and exclusion criteria policy, a medical emergency policy and indemnity that covers online work. Your location is the place the service is managed from. The doctor exemption for consulting rooms never covers remote consultations.
Adding a service later
- Check whether it needs a new activity or location. A new service within activities and at a location you are already registered for does not need a variation, but it must be described in your statement of purpose.
- If it does, apply to vary your registration using the CQC’s form for adding a regulated activity or a location. You must have the variation granted before you start.
- Update your statement of purpose and notify the CQC of the change.
- Update your policies and training, for example consent for procedures or infection control for minor surgery.
- Tell your indemnity provider and get written confirmation that the new service is covered. See indemnity for private GPs.
Carrying on an activity that is not on your registration is treated like carrying it on without registration, and failing to comply with registration conditions is itself an offence.
Registering for more than you need
You might be tempted to register for every activity you might offer one day. The CQC assesses whether you can deliver each activity safely, so you need policies, premises, equipment and competence for each one when you apply. Register for what you will actually provide at launch, and add activities when you are ready. The application itself is covered in how to register with the CQC.
In Wales, Scotland and Northern Ireland
Schedule 1 applies in England. Scotland, Wales and Northern Ireland define registrable services differently. Healthcare Improvement Scotland registers independent clinics, Healthcare Inspectorate Wales registers independent clinics and independent medical agencies, and RQIA does the same in Northern Ireland. Check with the regulator where you will practise.
Frequently asked questions
Do I need diagnostic and screening procedures to take bloods?
Usually not, if you are registered for treatment of disease, disorder or injury. The regulations except taking blood and urine samples for providers registered for another activity. You would need it for services such as ultrasound or ambulatory monitoring.
Do I need a separate registration for each clinic address?
No. Each location is added to your one registration. Adding a new location needs a variation granted before you start using it.
Does a menopause or ADHD clinic need a different activity?
Not usually. Assessment, prescribing and follow-up fall under treatment of disease, disorder or injury. Check any procedures or tests you add against the other activities.
What if I stop offering a service?
Apply to remove the regulated activity if you no longer carry it on, and update your statement of purpose so it stays accurate.
