Fitness to practise · The investigation stage

Fitness to Practise Investigation: How the Process Works From Concern to Outcome

What happens between a regulator deciding to look into a concern and the decision on whether it goes any further. Covers what investigators collect, how long it takes, the 28-day response that matters most, and who decides your case.

GMC, NMC, HCPC, GDC, GPhC and more Official timescales Response checklist

Short answer: a fitness to practise investigation is the evidence-gathering stage of a regulator’s process. Once a concern passes the initial threshold, the regulator collects records, employer information and witness accounts, and may obtain expert advice. It then sends you the allegations and the evidence, and gives you a set period, usually 28 days, to respond in writing. Case examiners or an investigating committee then decide, on the papers, whether there is a realistic prospect of a panel finding your fitness to practise currently impaired. Most investigations do not end in a hearing.

Key takeaways

An investigation is not a finding against you. It is a structured way of establishing what happened.
The decision-makers at this stage do not decide whether allegations are true. They decide whether the case should go further.
Your written response, sent within the deadline, is often your best chance to influence the outcome before any hearing.
Decisions look at your fitness to practise now, so evidence of insight and remediation is relevant from the start.
The NMC publishes which concerns are easier to address and which evidence carries weight. Its guidance is one of the clearest maps of what decision-makers look for.
In 2025, GMC case examiners made 679 decisions. Fewer than three in ten were referrals to a tribunal.

Where the investigation sits in the process

Every UK health and care regulator follows broadly the same three-part pattern before a case could reach a hearing. This article focuses on the middle part. For the whole journey, including hearings, sanctions and appeals, see our complete guide to fitness to practise in the UK.

1Threshold checkDoes the concern fall within the regulator’s powers and meet its seriousness threshold?

2InvestigationEvidence is gathered, allegations are drafted, and you respond in writing.

3DecisionCase examiners or a committee decide whether the case goes further.

Before an investigation opens: the threshold test

Not every concern becomes an investigation. In 2025, the GMC triaged 13,465 concerns about doctors and closed 12,146 of them at that first stage, because they did not meet the legal threshold. Other regulators also filter early. The GDC, for example, aims to make its initial assessment decision within five working days in 90% of cases.

The GMC publishes the test it applies, and it shows how regulators think at this point. In summary, it asks four questions:

Is the person registered with the regulator?
Does the concern fit a legal ground, such as misconduct, deficient performance, a conviction or caution, adverse health, knowledge of English, or another regulator’s decision?
Would it, if proved, raise a question about fitness to practise? The GMC describes this threshold as relatively low.
Are there reasons not to investigate? Examples include vexatious complaints, events more than five years old without a public interest reason, or waiting for another process such as a criminal case to finish.

Where the picture is unclear, the GMC may make provisional enquiries first. These are short, targeted requests for easily obtained information, such as a clinical record or a clarification from an employer. They help decide whether a full investigation is needed. Where a concern does not meet the threshold but contains learning points, the GMC may share it with the doctor’s responsible officer to be picked up locally, for example at appraisal.

What you receive when an investigation opens

The first contact is often the most stressful moment. Knowing what usually comes, and in what order, makes it easier to respond calmly. Our guide to your first steps after a concern covers the first weeks in detail.

First contact
Notification that an investigation is open

You are told what the concern is about. The GMC now usually begins with an email from an investigation officer to arrange a phone call, followed by formal letters. Expect to be asked for your current employers and places of work.
During the investigation
Requests and updates

You may be asked for information, or told that the regulator is contacting your employer or obtaining records. The GPhC, for example, says it gives updates about every two months. Keep every letter and note every deadline.
If needed, at any point
Notice of an interim order hearing

Only where there may be a serious, immediate risk. An interim order hearing considers whether restrictions are needed while the investigation continues. It does not decide whether the allegations are true.
End of the investigation
The allegations and the evidence

You receive the formal allegations, the evidence gathered and, at some regulators, an investigation report. You are invited to respond in writing within a set period, usually 28 days. This is covered in detail below.
After your response
The decision

Case examiners or a committee consider everything, including your response, and you are told the outcome in writing.

What investigators actually gather

The investigation’s job is to establish the facts as fully as possible, from both sides. Depending on the concern, regulators may collect:

Records

Clinical and medication records, care plans, rotas and audit data. The NMC notes that evidence can include CCTV footage.

Employer information

Local investigation reports, HR and disciplinary outcomes, and information from your responsible officer or manager.

Witness accounts

Statements from the person who raised the concern, colleagues and, where relevant, patients or relatives.

Expert or clinical advice

An independent view on whether care met the expected standard. The GDC uses Clinical Dental Advisers for this.

Assessments

In some cases, a health or performance assessment, arranged by the regulator.

Police and court documents

Where there is a criminal matter, details of any charge, conviction or caution.

Everything you send can be used The HCPC makes clear that information it receives, including emails and phone calls, can be used in fitness to practise proceedings. Be accurate, measured and consistent in everything you say and send, from the first contact onwards.

How long investigations take

The investigation is usually the longest part of the process, because evidence has to be gathered from several sources. Regulators publish their own aims, and they differ:

Regulator	What it says about timing
GDC	Initial assessment within 5 working days in 90% of cases. Investigation of straightforward cases within about seven months in 75% of cases, and nearly a year for complex ones. Case examiner decisions in a further 18 to 20 weeks.
GPhC	Aims to finish investigations as soon as possible, usually within six months of receiving a concern.
HCPC	Aims to finalise the case and send the allegations within 12 weeks, though this can take longer where more information is needed.
NMC	Describes investigation as often the longest stage. Around 73% of all cases were resolved end-to-end within 15 months by December 2025.

Real cases can take longer than these aims, particularly where an employer’s own investigation, a criminal case or an expert report has to finish first. Delay is not, on its own, a sign that your case is serious.

Your formal response: the document that matters most

At the end of the investigation you are given the allegations and the evidence, and invited to respond. This is usually a written process, and at most regulators you will not be invited to speak to the decision-makers. For many professionals, it is the single best opportunity to shape what happens next.

Regulator	What you receive	Time to respond
GMC	A “Rule 7” letter setting out the allegations and the evidence	28 days from the date of the letter, under rule 7 of the GMC’s Fitness to Practise Rules
NMC	The investigator’s report and the evidence gathered	28 days to comment, before two case examiners consider the case
HCPC	A case investigation report, the formal allegations and the information gathered	28 days to send a written response

Other regulators have their own rules, so always check the deadline in your letter. If you need more time, ask for it in writing before the deadline, and explain why.

What a strong response usually covers

The HCPC publishes practical guidance for registrants on responding to allegations. Its points reflect what decision-makers across regulators tend to find useful:

Your account of events. Say what happened, why it happened, which facts you accept and which you dispute.
Each allegation in turn. Respond to each numbered allegation separately, and refer to page numbers in the evidence bundle.
Whether the facts amount to the ground alleged. For example, whether something is really misconduct or a lack of competence.
Your fitness to practise now, not just at the time of the events. This is where insight and remediation belong.
Evidence, not assertions. Include training certificates, audits, supervision records, updated protocols and records of changed practice.
References from people who know about the allegations. The HCPC says these carry more weight than general praise from referees who do not.
Current health information, where health is part of the concern.

Get advice before you send it Your response may be used later, including at a hearing. Your defence organisation, indemnity provider, union or professional body can review it before you send it. That is usually far better than sending something quickly and having to correct it later.

Preparing your response?

Our Dealing with a Complaint or Investigation course walks you through the process, how to structure your account, and how to show learning in a way decision-makers can follow.

View the course

Who makes the decision, and the test they apply

At the end of the investigation, the case is decided by one of two types of decision-maker, depending on the regulator:

Model 1

Case examiners

Used by the GMC, NMC, GDC and others. Typically two senior staff decide together, one with professional background and one lay. At the GMC, if the two case examiners cannot agree, the case goes to the Investigation Committee.

Model 2

An investigating committee

Used by the HCPC, GPhC and several smaller regulators. A panel considers the case. At the HCPC, the Investigating Committee Panel meets in private and decides on the papers.

Whichever model applies, the test is similar. The decision-makers do not decide whether the allegations are true. The HCPC describes the question as whether there is a realistic prospect of proving the facts, the grounds and current impairment. In other words, could a panel at a hearing reasonably find the facts proved, find they amount to misconduct or another ground, and find your fitness to practise impaired today?

The last part of that test is why your response matters. If you can show genuine insight and evidence of remediation, decision-makers can take that into account when they consider whether there is a realistic prospect of a finding of current impairment.

How decision-makers actually apply the test

Regulators publish the guidance their case examiners follow. Reading it closely tells you more about your case than any summary can. The GMC’s guidance on deciding the outcome of an investigation makes four points that shape most cases:

“Realistic” means genuine

A realistic prospect is a genuine possibility, not a remote or fanciful one, that a tribunal would find fitness to practise impaired to a degree that needs restrictive action. It is a deliberately modest bar, which is why a strong response matters.

Disputed witness evidence goes to a hearing

Case examiners work from documents. They should not normally try to resolve substantial conflicts of evidence. Serious disputes about what witnesses say can only be resolved by a tribunal. Contemporaneous records that support your account carry particular weight at this stage.

Warnings sit just below the line

A warning fits where the test is not met but there was a significant departure from professional standards, and repetition would likely lead to a finding of impairment. It falls just short of the threshold.

Undertakings need two things

The GMC can agree undertakings only where the realistic prospect test is met and there is no possibility of erasure if the case went to a tribunal. They must be agreed by you. If they are not agreed, referral to a tribunal usually follows.

Case examiners also weigh how you have responded to the concern, including evidence of insight and remediation, when they assess whether there is a current, ongoing risk. That is the link between your written response and the outcome.

What the outcomes look like in practice

The GMC publishes how its case examiners decide cases. In 2025, they made 679 decisions:

Closed, no further action309

Referred to a tribunal184

Warning110

Undertakings agreed60

Closed with advice16

Source: GMC fitness to practise data for doctors, 2025.

Put simply, about 73% of GMC case examiner decisions in 2025 ended without a referral to a tribunal. At the GDC, around 80% of cases close at the assessment and investigation stage with no further action. The possible outcomes at the end of an investigation are usually:

No further action, sometimes with advice about future practice.
A warning, where there was a significant departure from standards but fitness to practise is not impaired.
Undertakings, which are agreed commitments such as supervision, training or limits on practice, made without a hearing.
Referral to a fitness to practise committee or tribunal for a hearing.

Our complete guide explains what happens if a case is referred, and the sanctions a panel can impose.

What counts as evidence: the NMC’s insight and strengthened practice framework

The NMC publishes unusually detailed guidance on how its decision-makers judge insight and remediation. It is written for nurses, midwives and nursing associates, but the principles closely match what other regulators look for. It asks three questions:

Can the concern be addressed?
Has the concern been addressed?
Is it highly unlikely that the conduct will be repeated?

The NMC stresses that these are key points to consider, not a fixed test, and that the context in which events happened must be taken into account first.

Some concerns are easier to address than others

Usually easier to address

Clinical concerns

Isolated medication errors, poor record keeping, failings in a discrete clinical area, and incidents in the distant past followed by safe practice.

Usually harder to address

Attitudinal concerns

Serious or sustained dishonesty, sexual misconduct and harassment, discrimination, abuse of a position of power, violence or neglect, and serious criminal offences. These may point to an underlying attitude that training alone cannot fix.

Evidence the NMC says carries weight

Training that targets the concern. The NMC looks at how long a course was and how much of it focused on the relevant issues. Practical elements and formal assessments carry more weight.
Reflection that shows application. Reflection is more persuasive when it shows how you have applied the learning in practice, not only what you learned.
A completed action plan targeted at the specific failings.
Supervised practice focused on the concerns, successfully completed.
Work in a similar setting, where your employer knew about the concerns and saw improvement.
References from managers or supervisors, rather than peers. They should be signed, dated, on headed paper, and show the writer knows about the allegations.

If you are not working The NMC says that periods out of work, or work that gives no chance to show the problem task can now be done safely, will usually be of limited relevance. If you are not practising, think about how else you can show change, for example through assessed learning, structured reflection and, where possible, supervised or voluntary work.

This is also why the format of learning matters. A short, unassessed video is weaker evidence than a structured course that covers the concern in depth and ends with an assessment and a certificate. Our courses, such as the Remediation course, are built with assessed questions and a CPD certificate for this reason. But a course is only one part of the picture, alongside reflection, applied practice and references. Our guides to remediation and remediation evidence go further.

Core course

Fitness to Practise for Healthcare Professionals

Our most complete remediation course: 4 CPD hours and 40 scenario questions on impairment, insight, remediation and reflection, with a certificate when you pass.

£150 Enrol now See the full curriculum

Completing a course does not change or predict any regulator’s decision. Courses are educational and support your own reflection and development.

Working, telling people and privacy during an investigation

Can you keep working?

In most cases, yes. You can continue to practise unless an interim order restricts or suspends your registration, or your employer takes its own action. If there are interim conditions, follow them exactly. A breach would create a new and serious concern.

Who needs to know?

Regulators may contact your employer during the investigation, and you may have your own duty to tell employers and organisations you work with. The GMC, for example, usually asks doctors for details of where they work so that it can contact employers itself. Professional standards may also require you to tell the organisations you work for about any restrictions or suspension. Check your own regulator’s standards and your employment contract. Being open is itself a matter of probity.

What becomes public, and for how long?

An investigation itself is generally not made public while it is ongoing. Some outcomes are. The GMC and NMC publish their rules:

Outcome	GMC (doctors)	NMC (nurses and midwives)
Investigation in progress	Not routinely disclosed to the public or media. Current employers and responsible officers are told when a full investigation begins.	Not published while it is ongoing.
Advice	Not published.	Never made public.
Warning	Published for two years: one year on the main register entry, then a further year on the history page.	Published for 12 months on the register entry, with a summary of the concern.
Undertakings	Published while in effect, except those relating solely to managing a health condition.	Published with a summary of the concern, except in health cases.
Interim order	Published while it is in effect.	Published while it is in effect.

Other regulators have their own policies. The GPhC, for example, publishes Investigating Committee outcomes. Check your regulator’s publication policy so you know what employers and the public may see.

Looking after yourself

Investigations are stressful, and regulators recognise this. The GMC has introduced personal phone contact at the start of investigations and offers support services. The HCPC says case managers can discuss adjustments and point you to support. Practitioner health services, unions and defence bodies can help too.

A hypothetical walkthrough

Hypothetical example

A physiotherapist and a disputed consultation. A patient complains to the HCPC that a physiotherapist was dismissive and failed to explain a treatment. The concern meets the threshold, and the HCPC asks the clinic for records and an account of events. Months later, the physiotherapist receives the case investigation report and the allegations, with 28 days to respond.

With help from her union, she responds to each allegation. She accepts that her explanation of the treatment was not clear enough and disputes one allegation, using her contemporaneous notes. She attaches evidence of a communication and consent course, a reflective account, a revised patient information leaflet she now uses, and a reference from her clinical lead, who knows about the complaint.

The Investigating Committee Panel then considers, on the papers, whether there is a realistic prospect of proving the facts, the ground and current impairment. Her response gives the panel a clear view of both the concern and her current practice. The decision remains the panel’s.

Mistakes to avoid at the investigation stage

Missing the response deadline, or not responding at all. Decision-makers can only weigh what you send them.
Responding before you have read all the evidence, or before you have taken advice.
Arguing with the complainant instead of addressing the allegations and your current practice.
Accepting or denying everything as a block, instead of dealing with each allegation on its own terms.
Sending generic CPD certificates with no link to the concern and no reflection on what you learned.
Using references from people who do not know about the allegations. These usually carry little weight.
Contacting witnesses about the case, or changing records after the event.

Checklist: preparing for and responding to an investigation

Read every letter in full and diary each deadline.
Contact your defence organisation, indemnity provider, union or professional body.
Tell the employers and organisations you are required to tell.
Start a file with all correspondence, a timeline of events and your own notes made at the time.
Begin honest, written reflection early, while events are fresh.
Identify learning that targets the specific concern, and keep the evidence of it.
Ask colleagues who know about the concern whether they would provide a reference.
When the allegations arrive, respond to each one, refer to the evidence bundle, and address your current practice.
Ask for an extension in writing, before the deadline, if you genuinely need one.

Frequently asked questions

Does an investigation mean the regulator thinks I am guilty?

No. An investigation means the concern met the threshold for the regulator to look into it. It is a fact-finding process, and many investigations close without any action.

What is a GMC Rule 7 letter?

It is the letter the GMC sends a doctor setting out the allegations and the evidence gathered, under rule 7 of the GMC’s Fitness to Practise Rules. It invites the doctor to send written representations within 28 days of the date of the letter, before the case examiners decide the case.

Do I have to respond to the allegations?

You are not usually obliged to respond, but it is almost always in your interest to do so, with advice. Decision-makers can only take into account the information in front of them.

Will I be interviewed or have to attend a meeting?

Usually not. At most regulators, case examiners or an investigating committee decide on the papers. An interim order hearing, if one is needed, is separate and you can usually attend.

How long does a fitness to practise investigation take?

It depends on the regulator and the case. The GPhC says investigations are usually completed within six months. The GDC aims to complete straightforward investigations within about seven months. Complex cases can take a year or longer.

Can I work while I am being investigated?

Usually, yes, unless an interim order restricts or suspends your practice, or your employer takes separate action. If you have interim conditions, you must follow them exactly.

Should I include CPD in my response?

Relevant CPD can help, especially where it targets the specific concern and you explain what you learned and how your practice has changed. Unrelated certificates on their own tend to carry little weight.

What happens if my case is referred to a hearing?

An independent panel or tribunal will decide the facts, whether your fitness to practise is currently impaired and, if so, what sanction is needed. Our complete guide to fitness to practise explains each step.

Will my investigation appear on the public register?

Usually not while it is ongoing. Some outcomes are published, such as warnings, undertakings and interim orders, for periods set by each regulator. At the GMC, warnings are published for two years and at the NMC for 12 months. Advice is not published.

Does a CPD course count as evidence of remediation?

It can be part of the evidence. The NMC says it looks at how long a course was, how much of it focused on the concern, and whether it included practical elements or formal assessment. Learning carries most weight when you also show, through reflection and practice, how you have applied it.