Probity · Conflicts of interest

Conflicts of Interest and Financial Interests in Healthcare: UK Guide

What counts as a conflict of interest, the joint principles signed by nine UK regulators, each regulator's own rules on gifts, referrals and financial interests, nine everyday scenarios, a five-step way to manage a conflict, and when a conflict becomes a criminal matter.

Reviewed October 2026 against GMC, NMC, HCPC, GDC and GPhC standards, the regulators' joint statement and legislation

9 regulators, one statement Gifts, referrals, fees Declare, manage, record

Short answer: a conflict of interest arises when your professional judgement may be influenced, or could be seen to be influenced, by a financial, personal or other interest. Having an interest is often unavoidable and is not misconduct in itself. What every UK regulator requires is that you put the person in your care first, identify the interest, declare it early, manage it, and step aside where you cannot. Gifts beyond the trivial should be refused, and patients must be told about any interest you have in a provider or product you suggest. Where an interest is hidden, it becomes a question of integrity, and at the extreme it can be bribery.

Key takeaways

Nine UK health and care regulators have signed one joint statement setting the same core expectations.
Conflicts are not only financial. Relationships, reputation and free training can create them too.
Perception matters. Every regulator's wording covers interests that "could appear to" affect your judgement.
Declaring a conflict protects you. An undeclared conflict that comes to light later is treated as a probity concern.
Under the Bribery Act 2010, offering or accepting a bribe carries up to 10 years in prison.

Conflicts of interest are one of the eight probity risk areas set out in our guide to probity in healthcare. This guide goes into them in depth: what counts, what each regulator requires, and how to handle real situations.

What counts as a conflict of interest

GMC guidance says "a conflict of interest occurs when a medical professional's interests (financial or otherwise) compete with their professional responsibilities" (para 6). The regulators' joint statement describes it as a situation where "someone's judgement may be influenced, or perceived to be influenced, by a personal, financial or other interest".

Direct financial

Interests in organisations such as private healthcare providers, primary care practices, pharmaceutical or device companies, care homes, pharmacies or dispensaries; patents; consultancy or speaker fees; payments to organisations you own or manage.

Indirect financial

Any of those interests where they benefit your employer or "anyone close to you including family members, friends, other close associates or organisations".

Non-financial

"Free education, training opportunities, research benefits, personal relationships, or enhancements to professional reputation".

Source: GMC, Identifying and managing conflicts of interest, Annex B (effective 30 January 2024).

The joint statement: nine regulators, one standard

The GMC, NMC, HCPC, GDC and GPhC, along with the General Chiropractic Council, General Osteopathic Council, General Optical Council and Pharmaceutical Society of Northern Ireland, signed a joint statement on conflicts of interest. It says health and care professionals should:

"Put the interests of people in their care before their own interests, or those of any colleague, business, organisation, close family member or friend."
"Maintain appropriate personal and professional boundaries with the people they provide care to and with others."
"Consider carefully where conflicts of interest may arise – or be perceived to arise – and seek advice if they are unsure how to handle this."
"Be open about any conflict of interest they face, declaring it formally when appropriate and as early as possible, in line with the policies of their employer or the organisation contracting their services."
"Ensure their professional judgement is not compromised by personal, financial or commercial interests, incentives, targets or similar measures."
"Refuse all but the most trivial gifts, favours or hospitality if accepting them could be interpreted as an attempt to gain preferential treatment or would contravene your professional code of practice."

The statement also expects patients to have clear information about fees and charging.

Each regulator's own rules

Regulator	What the standards say
GMC	Detailed guidance, Identifying and managing conflicts of interest (2024). Manage conflicts by avoiding them, being open, formally declaring and mitigating (para 10). "You must be open and honest with patients about any interests you have that may affect (or could be seen to affect) the way you propose, provide, or prescribe treatments" (para 17).
NMC	The Code: "refuse all but the most trivial gifts, favours or hospitality" (21.1); never ask for or accept loans from anyone in your care or anyone close to them (21.2); act with integrity in financial dealings (21.3).
HCPC	"You must declare issues that might create conflicts of interest and make sure that they do not influence your judgement" (standard 9.4).
GDC	"You must always put your patients' interests before any financial, personal or other gain" (1.7.1). "You must refuse any gifts, payment or hospitality if accepting them could affect, or could appear to affect, your professional judgement" (1.7.5). Referrals must be in "the patients' best interests rather than for your own, or another team member's, financial gain or benefit" (1.7.6). In mixed NHS and private practices, patients must be told clearly which treatments are available on the NHS and must not be pressured into private care (1.7.2 to 1.7.4).
GPhC	A signatory to the joint statement above, which applies alongside the GPhC's standards for pharmacy professionals. With the GMC and the Pharmaceutical Society of Northern Ireland, it has also published material on prescription direction: patients must be free to choose their pharmacy, and professionals must be open about any interest in a pharmacy they mention.

Gifts and hospitality

Gifts are the most common everyday conflict. The rules are worded slightly differently, but they point the same way.

From patients

Explain, and usually decline

GMC guidance says that if a patient, or someone close to them, offers an unsolicited gift, "you should explain that you can't accept it – unless the gift is of minimal value" (para 35). A box of chocolates for the team is usually fine. Money, vouchers or anything of value is not.

From companies

Assume it is meant to influence

Hospitality, travel, meals or equipment from pharmaceutical, device or service companies are exactly what the joint statement means by gifts that "could be interpreted as an attempt to gain preferential treatment". Follow your employer's policy and declare anything you accept.

A four-question gift test

Is it more than trivial? Would a reasonable member of the public see it as of real value?
Who is giving it, and why? A grateful patient after discharge is different from a supplier before a purchasing decision.
Could it look like it affects your judgement? Perception is enough under every regulator's wording.
Would you be comfortable if it were published? If not, decline it, or declare it and ask for advice.

If the answer to any of the first three is yes, or the fourth is no, decline politely. Never accept money or a loan: the NMC Code rules out loans entirely.

Nine everyday scenarios

Situation	Risk	What to do
You suggest a private clinic, pharmacy or care home you have a financial interest in	High	Tell the patient about the interest before suggesting it. GMC guidance says "you must tell the patient about this interest" (para 23), and offer alternatives
Your employer owns the pharmacy next door and you are encouraged to send prescriptions there	High	Do not direct patients. Make sure they know they can choose any pharmacy, and be open about your employer's interest if asked. In England, the NHS Constitution gives patients the right to choose
A company pays you to speak or consult	Medium	Declare it to your employer and in any setting where you advise on that company's products. Keep a record
A relative or close friend asks you to treat or prescribe for them	High	Avoid it wherever possible. GMC prescribing guidance says you must avoid prescribing for anyone you have a close personal relationship with wherever possible
Your practice earns target or incentive payments linked to prescribing or referrals	Medium	Put each patient's needs first. GMC guidance expects you to consider "safety and needs of individual patients" and make sure patients know they can choose
You sit on a panel buying services from a company you or a relative have links with	High	Declare the interest formally and step out of the decision
A company offers free training or conference places	Medium	Check your employer's policy, declare it, and make sure it does not shape what you recommend
A patient offers a small thank-you gift for the team	Low	Usually acceptable if of minimal value. Record it if your employer requires
A patient or relative offers you money, a loan or a valuable item	High	Decline and explain why. Tell your manager and record the offer

Managing a conflict: five steps

Identify it. Ask whether any interest, financial or not, could influence your judgement or be seen to.
Declare it early. To your employer or commissioning organisation, in line with their policy, and to the patient where it affects their care.
Mitigate it. Offer alternatives, involve a colleague, or follow an agreed process for decisions.
Record it. GMC guidance says "you should make a note of any discussion about conflicts of interest in the patient's medical record" (para 25).
Step aside if needed. Be prepared to refer the patient to another professional "who doesn't have the same interest" (para 31).

If you are a director, partner or owner of a healthcare business, keep a standing register of your interests and update it whenever something changes.

When a conflict becomes a crime

Most conflicts are professional matters. But the Bribery Act 2010 makes it an offence to offer or give a bribe (section 1) and to request, agree to receive or accept one (section 2), where the advantage is intended to induce or reward improper performance. An individual convicted on indictment faces "imprisonment for a term not exceeding 10 years, or to a fine, or to both" (section 11). A criminal investigation or charge would also have to be reported to your regulator, as explained in our self-referral guide.

How conflicts reach fitness to practise

A declared and well-managed conflict rarely becomes a fitness to practise concern. Problems usually start when an interest is hidden, a gift or payment is accepted without declaring it, or a patient is steered towards something that benefits the professional. At that point it is treated as a question of integrity, and if anything misleading was said or written, of honesty. Our guide to probity vs ethics explains why that distinction affects the outcome.

Frequently asked questions

What is a conflict of interest in healthcare?

A situation where your professional judgement may be influenced, or could be seen to be influenced, by a financial, personal or other interest. GMC guidance defines it as your interests competing with your professional responsibilities.

Is it wrong to have a conflict of interest?

Not in itself. Many are unavoidable. What matters is that you identify it, declare it, manage it and step aside where needed.

Can I accept a gift from a patient?

Only if it is of minimal value. GMC guidance says to explain that you cannot accept an unsolicited gift unless it is of minimal value, and the NMC Code says to refuse all but the most trivial gifts.

Can a nurse accept a loan from a patient?

No. The NMC Code says never to ask for or accept loans from anyone in your care or anyone close to them.

Do I have to tell patients about my financial interests?

Yes, where the interest could affect the care you propose. GMC guidance requires doctors to tell patients about an interest in any provider they suggest, and to be open about interests that could affect how they prescribe or provide treatment.

Can a GP send patients to a particular pharmacy?

No. The GMC, GPhC and PSNI say patients must be free to choose their pharmacy, and professionals must be open about any interest in a pharmacy. In England, the NHS Constitution gives patients that right.

Do all UK regulators have the same rules?

The detail differs, but nine regulators signed one joint statement with the same core expectations: put patients first, be open, declare early and refuse all but the most trivial gifts.

When does a conflict of interest become bribery?

When an advantage is offered, requested or accepted to induce or reward improper performance. Under the Bribery Act 2010, an individual can face up to 10 years in prison.

Primary sources

10 official documents and laws