GOsC Fitness to Practise: Complete Guide for Osteopaths
How the General Osteopathic Council deals with concerns about osteopaths. This guide covers the four statutory grounds and the test for "unacceptable professional conduct", what the GOsC will not take forward, and each stage from the Screener to the Investigating Committee and a Professional Conduct Committee hearing. It also covers the latest outcomes, why insurance lapses fill the hearing list, consensual disposal, sanctions, interim suspension, appeals, restoration after ten months, two High Court cases, the Osteopathic Practice Standards, CPD and free support.
Reviewed October 2026 against the Osteopaths Act 1993, GOsC threshold criteria, Hearings and Sanctions Guidance (May 2025), Rule 8 practice note, Fitness to Practise Annual Report 2024-25, the PSA's monitoring report for 2025-26 and High Court judgments
Short answer: GOsC fitness to practise is how the General Osteopathic Council decides whether an allegation against an osteopath is well founded and, if so, what sanction to impose. It receives around 75 concerns a year. A Screener reviews each one, and around half are closed. The Investigating Committee then decides whether there is a case to answer, closing about 30% of the cases it considers. Cases with a case to answer go to the Professional Conduct Committee, or the Health Committee for health matters. If an allegation is well founded, the committee must impose one of four sanctions: admonishment, conditions of practice, suspension (each up to three years) or removal. Of 12 osteopaths sanctioned in 2024-25, 9 were admonished, 1 suspended and 2 removed.
Key takeaways
- The key test is "unacceptable professional conduct". The High Court has held it requires "a degree of opprobrium", so poor notes alone are rarely enough.
- Once an allegation is found well founded, a sanction is compulsory. The fight is usually over whether the threshold is crossed at all.
- Practising without £5 million indemnity cover is a legal breach, and insurance cases were 5 of the 12 hearings in 2024-25.
- You have 28 days to send observations to the Investigating Committee, and 28 days to appeal a final decision to the court.
- A removed osteopath can apply for restoration after ten months, far sooner than at most regulators.
Osteopaths are one of nine UK professions with a statutory regulator; our UK fitness to practise guide compares all of them.
A small regulator with its own rules
The GOsC regulates 5,653 osteopaths across the whole UK, one of the smallest registers of any health regulator. Its process is set out in the Osteopaths Act 1993 and is different in ways that matter if you are the osteopath concerned:
Its own threshold
The conduct ground is "unacceptable professional conduct", not misconduct. Courts treat it as the same level, but the GOsC has published its own threshold criteria built around it.
A sanction is compulsory
Under section 22(4), if an allegation of conduct or incompetence is well founded, the committee "must" impose a sanction. There is no "impaired but no action" outcome for these grounds.
Admonishment dominates
The lowest sanction, an admonishment, was the outcome in 9 of 12 cases in 2024-25. It is published and stays on your fitness to practise record.
Interim suspension
Section 24 gives the committees power to impose an interim suspension to protect the public. It lasts until the allegation is decided, with no fixed maximum.
Restoration after 10 months
A removed osteopath can apply to be restored ten months after the removal order, compared with five years at the GMC or Social Work England.
Students are not registered
Only qualified osteopaths are on the register. Student fitness to practise is handled by osteopathic education providers.
The four statutory grounds
Section 20(1) of the Osteopaths Act 1993 allows an allegation that an osteopath:
Unacceptable professional conduct
"Conduct which falls short of the standard required of a registered osteopath."
Professional incompetence
A shortfall in clinical skill or knowledge of a serious kind.
Criminal conviction
A conviction in the UK "at any time". If the offence has no material relevance to fitness to practise, the committee can find no case to answer or take no further action.
Health
Where "his ability to practise as an osteopath is seriously impaired because of his physical or mental condition". These cases go to the Health Committee.
The threshold test: when conduct becomes "unacceptable"
Because a sanction must follow a finding, whether the conduct crosses the threshold is often the most important question in a GOsC case. The leading case is Spencer v General Osteopathic Council, decided by Mr Justice Irwin on 8 November 2012. He held that the phrase carries "an implication of moral blameworthiness, and a degree of opprobrium", that it is the same threshold as "misconduct" for doctors, and that a breach of the standards does not by itself establish it.
The GOsC's threshold criteria, approved in February 2015 and updated in June 2021, ask whether the allegation is "worthy of the moral opprobrium and the publicity which flow from a finding". They list concerns that should not generally go to the Professional Conduct Committee:
- Incompetence or negligence "of a high degree"
- Dishonesty or an intent to deceive
- Abusive behaviour or violence
- Conduct bringing the profession into disrepute
- Drugs or alcohol, or a possible health issue
- Breaches of data protection law
- Record keeping alone, without high-degree incompetence or data protection failures
- Disputes about fees, unless dishonesty is alleged
- Reasonable differences of professional opinion accepted by a responsible body of osteopaths
- Business disputes such as "patient poaching", unless confidentiality is involved
- Personal life matters, unless abuse, violence or disrepute is involved
- Vexatious or unverifiable anonymous complaints
- Minor motoring offences and penalty fares, without drugs, alcohol or health issues
Summarised from GOsC: Threshold criteria for unacceptable professional conduct (version 1.2, June 2021).
Matters better handled elsewhere, such as advertising claims for the Advertising Standards Authority, may also be redirected. Our guide to the investigation stage explains how to address seriousness in your first response.
What happens to concerns: the numbers
The GOsC deals with far fewer cases than larger regulators, so a handful of cases changes the picture each year. Its Fitness to Practise Annual Report 2024-25 shows:
| Stage | Figure | Context |
|---|---|---|
| Concerns received | Around 75 a year | Patients are "the main source of complaints" |
| Screener | About half closed | Target: review within 9 weeks of receipt |
| Investigating Committee | Closes about 30% | Median 41 weeks from receipt, against a 26-week target |
| Professional Conduct Committee | 12 osteopaths sanctioned | Median 67 weeks from receipt, against a 52-week target |
Source: GOsC Fitness to Practise Annual Report 2024-25, covering 1 April 2024 to 31 March 2025.
- Admonishment 9 (75%)
- Suspension 1 (8%)
- Removal 2 (17%)
Both removals involved criminal convictions, one for sexual assault of a patient. The admonishments covered consent and communication failures, clinical care, an intimate examination without valid consent, and five cases about professional indemnity insurance. Each case is set out below. The PSA's monitoring report for 2025-26 noted that the GOsC had its highest number of open fitness to practise cases since 2017-18. It also found that delays at the hearing stage were driven by complex cases, third-party investigations and vulnerable witnesses.
Every 2024-25 hearing, and what it teaches
Because the GOsC hears so few cases, each one is worth reading. These are the twelve cases that ended in a sanction in 2024-25, without names, as summarised in the GOsC's annual report:
| What the case was about | Sanction | The risk it shows |
|---|---|---|
| Conviction for sexual assault of a patient (three counts), with a custodial sentence | Removal | Sexual abuse of patients ends a career |
| Non-cooperation with the GOsC, refusing a fitness to practise assessment, and a conviction for describing themselves as an osteopath while suspended | Removal | Disengaging and using the title while suspended |
| Dry needling without valid consent; needles inserted too deeply into the upper chest, and signs of a pneumothorax not recognised or referred | Admonishment | Consent and recognising complications |
| Advising a patient in pain to keep exercising without considering possible vertebral collapse or imaging; incomplete records; slow reply to a patient's message | Suspension | Red flags, referral and records |
| High-velocity thrust manipulation without valid consent, where it was contraindicated | Admonishment | Consent for each technique |
| Sharing personal information with a patient, inappropriate comments and disclosing another patient's information | Admonishment | Boundaries and confidentiality |
| Intimate examination without valid consent or an offer of a chaperone, with boundary breaches | Admonishment | Consent and chaperones |
| Five separate cases of treating patients without indemnity insurance, two found misleading and lacking integrity, one with a false renewal declaration | Admonishment (each) | Insurance and honest declarations |
Source: GOsC Fitness to Practise Annual Report 2024-25.
The report draws learning points from these decisions and links them to specific practice standards:
Candour
"Acknowledge when things go wrong" and "ensure the patient understands the seriousness of symptoms".
Consent
"Consent is an ongoing process, not a one-off verbal exchange." "Documentation of consent is essential."
Records
"Accurate and timely record-keeping is a key part of safe and competent practice."
Insurance
"Osteopaths should maintain their own system for monitoring renewal dates and not rely on their Insurers."
The insurance trap
Five of the twelve osteopaths sanctioned in 2024-25 were there because of professional indemnity insurance. It is the most avoidable route into a GOsC hearing.
- It is the law. Section 37 of the Osteopaths Act 1993 requires cover, with a "minimum cover of £5 million", under the GOsC (Indemnity Arrangements) Rules 2015.
- Cover must be continuous, including run-off cover for periods when you are not seeing patients.
- You declare it every year on your renewal form, and the GOsC verifies a percentage of the register annually.
- If cover lapses, "you must cease practising immediately until you have obtained appropriate cover" and tell the GOsC about the gap.
- If you knowingly practise uninsured, you "could face an additional allegation of lack of integrity or dishonesty", which is far harder to defend than the lapse itself.
Check your renewal date against your registration date, set a reminder, and keep proof of continuous cover. If you discover a lapse, stop, arrange cover and tell the GOsC straight away. Being open about it is the strongest mitigation available. See our guide to self-referral.
How a GOsC case moves
- 1
Screener
A Screener checks whether the GOsC has power to deal with the concern and whether it could be well founded. Around half of cases close here.
- 2
Investigation and your observations
The GOsC gathers evidence such as records, statements and expert opinion. The Investigating Committee must invite your observations "before the end of the period of 28 days" from the date notice of the allegation is sent.
- 3
Investigating Committee
It decides whether there is a case to answer, and closes about 30% of the cases it considers. For convictions, it can find no case to answer if the offence has no material relevance to your practice.
- 4
Professional Conduct Committee or Health Committee
A panel of three, at least one osteopath and one lay member, with a lay chair. It decides the facts on the balance of probabilities, whether the allegation is well founded, and the sanction. What to expect on the day is covered in our guide to fitness to practise hearings.
Your observations to the Investigating Committee are your best chance to end the case before a hearing. Address the threshold directly: why the conduct, even if accepted, does not carry the moral blameworthiness Spencer requires, and what you have done since. Our guide to writing your response explains how to structure it.
Rule 8 consensual disposal
Since 1 February 2018, some cases referred to the Professional Conduct Committee can be dealt with without a hearing under Rule 8. You must admit the facts and that they amount to the allegation, waive a hearing, and accept an admonishment. A panel chair must consider the case suitable, and the committee then decides at a meeting. Rule 8 is not available for cases involving violence, sexual or physical abuse, vulnerable people, dishonesty, convictions with imprisonment or a suspended sentence, or "significant failings in examination or treatment of patients". The outcome is published like any other admonishment. Before agreeing, read our guide to warnings and agreed outcomes, because an admitted finding cannot easily be undone.
Interim suspension
Under section 24, the Professional Conduct Committee or Health Committee can order an interim suspension if it is "necessary to do so in order to protect members of the public". You must be given the chance to appear and argue against it, and you can be legally represented. The order lasts until the allegation is decided, or until any appeal is dealt with. You can appeal to the court within 28 days, and the court's decision is final. Preparing for an interim hearing is covered in our guide to interim and substantive suspension.
Sanctions, appeals and restoration
The Professional Conduct Committee applies the GOsC Hearings and Sanctions Guidance (May 2025). It considers sanctions in ascending order and chooses the least severe one that adequately deals with the case:
Admonishment
Published and kept on your fitness to practise record. Takes effect after 28 days unless appealed.
Conditions of practice
Up to 3 years, including any extension. Can end when you pass a specified test.
Suspension
Up to 3 years, including any extension, with a review before it ends.
Removal
Where no other sanction would protect the public. Takes effect after 28 days unless appealed.
If the committee does not find unacceptable professional conduct, it can give advice, which is not a sanction and is not recorded on the register. The guidance treats several factors as aggravating:
- Dishonesty that is "persistent and/or covered up" is likely to lead to a sanction at the higher end.
- Sexual misconduct involving vulnerable patients should be "regarded as very serious", and removal is likely to be appropriate.
- Discrimination against patients or colleagues is "very serious".
- Deliberately avoiding candour is aggravating, while sincere explanations and apologies are mitigating.
Insight means "real evidence that the osteopath has been able to look back at his or her conduct with a self-critical eye", and the guidance asks committees to allow for cultural differences in how insight is expressed. Our guides to insight and evidence of remediation explain how to show it.
You can appeal a final decision to the High Court, the Court of Session in Scotland or the High Court in Northern Ireland within 28 days of the decision being served, and the decision does not take effect until that period ends or any appeal is decided. The Professional Standards Authority also reviews every final decision and can refer one it considers too lenient to the court. If you are removed, you can apply to be restored after ten months. The Professional Conduct Committee decides, must consider the circumstances that led to removal, and can restore you with conditions of practice.
Two High Court cases every osteopath should know
Spencer v General Osteopathic Council [2012] EWHC 3147 (Admin)
What happened. An osteopath saw a patient six times in 2009. He admitted that his case notes for two consultations were inadequate. Other allegations were not proved, and the committee expressly accepted that there was no criticism of the treatment itself. It still found unacceptable professional conduct and admonished him.
The outcome. On 8 November 2012 Mr Justice Irwin allowed the appeal and quashed the finding. Two note-keeping lapses, with otherwise proper assessment and treatment, were not "incompetence or negligence of a high degree", and it was "hard to construe these failures as worthy of the moral opprobrium" that such a finding brings.
The lesson: not every breach of the standards is unacceptable professional conduct. If the facts are minor and isolated, the threshold itself is worth contesting, with advice. That does not make records optional: good notes are your best evidence when a patient complains.
Sayer v General Osteopathic Council [2021] EWHC 370 (Admin)
What happened. An osteopath treating a patient made a flirtatious phone call and later called her from his personal mobile, against clinic policy. A personal relationship developed while the professional relationship continued, and he did not hand over her care. The committee found unacceptable professional conduct and sexual motivation, in breach of standards D16 and D17, and suspended him for six months.
The outcome. On 24 February 2021 Mr Justice Morris dismissed the appeal on every ground. He found some errors in the committee's reasoning, including on patient safety risk, but held they were errors of factual assessment, not principle. The six-month suspension was within the range of reasonable decisions.
The lesson: the professional relationship must end, and care must be properly handed over, before any personal relationship begins. Using personal phones or messaging for contact with a patient is itself a warning sign. Where the lines sit is explained in our guide to professional boundaries.
Touch, consent and communication
Osteopathy is a hands-on profession, and the 2024-25 hearings show where that creates risk. Four of the twelve sanctioned cases involved consent and communication, and one involved sexual boundaries. In hands-on practice, a complaint can arise as much from what a patient did not understand, such as why they were asked to undress or why a technique involved a particular area, as from the treatment itself.
Explain before you touch
The Osteopathic Practice Standards reflect the Montgomery judgment on consent. Explain what you will do, why, the material risks and the alternatives, and check understanding before you start.
Consent is ongoing
Check in during treatment, especially before techniques near sensitive areas, and stop if the patient is uncomfortable.
Undressing and dignity
Ask only for the undressing that is clinically necessary, explain why, offer gowns or alternatives and leave the room while the patient changes.
Chaperones
Offer a chaperone or companion for intimate or sensitive examinations, and record the offer and the patient's response.
Record the conversation
Note what you explained, the patient's consent and any concerns raised. In a disputed case, the record is your evidence.
Emotional and sexual boundaries
The 2019 standards give more detail on emotional, professional and sexual boundaries. Personal contact outside treatment is where cases begin.
The Osteopathic Practice Standards
Your conduct is judged against the Osteopathic Practice Standards, in force since 1 September 2019. They replaced the 2012 standards, reflect the Montgomery judgment on consent and the joint statement on the professional duty of candour, and give more detail on boundaries. They are organised in four themes:
- Communication and patient partnership
- Knowledge, skills and performance
- Safety and quality in practice
- Professionalism
Most findings involve the communication and professionalism themes. Our guides to the duty of candour and records and probity cover two of the areas most often tested.
Related courseOsteopath Professionalism: the practice standards in action→CPD and renewal
The GOsC CPD scheme runs over a three-year cycle. You must complete:
- 90 hours of CPD, at least 45 of them learning with others
- CPD covering all four themes of the practice standards
- at least one objective activity, such as case-based discussion, patient feedback, clinical audit or peer observation
- at least one activity on communication and consent
- a Peer Discussion Review near the end of the cycle, confirming you have met every element
Each year you also renew your registration and declare your insurance. Given the consent and communication cases above, a well-chosen communication and consent activity is both a CPD requirement and practical protection. See our guide to reflective accounts.
How the GOsC performs
PSA review 2024-25
The Professional Standards Authority found the GOsC met all its Standards of Good Regulation for the fifteenth year running. The GOsC says it is the only health and care regulator with that record.
PSA monitoring 2025-26
For 1 April 2025 to 31 March 2026, the PSA found 17 of 18 standards met, including all five fitness to practise standards. It did not meet general standard 3 on equality, diversity and inclusion. The PSA found the GOsC's investigations fair and proportionate.
Support during a case
Independent Support Service
Free and confidential, run by Victim Support for osteopaths and witnesses involved in fitness to practise cases. The helpline on 0300 303 1964 is open 24 hours a day, every day, with caseworkers available Monday to Friday, 8am to 6pm.
Your insurer and professional body
Your indemnity insurer often provides legal support for regulatory cases, so notify them as soon as you hear from the GOsC. Professional associations such as the Institute of Osteopathy can also help.
If your health is part of the case, it will usually go to the Health Committee. Health Committee cases focus on managing your condition safely rather than on blame, as our guide to health and fitness to practise explains. Samaritans is free to call on 116 123, day or night, if things feel overwhelming.
If the GOsC has contacted you
- Notify your indemnity insurer straight away. Check your cover was in force when the events happened.
- Note the 28-day deadline for observations to the Investigating Committee, and ask early if you need more time.
- Secure your clinical records, including case notes, consent records and appointment history. Never alter them.
- Consider the threshold. Ask your adviser whether, even if the facts are accepted, the conduct really crosses the line set in Spencer.
- Start targeted remediation: consent and communication CPD, a records audit, peer discussion, and a reflective account linked to the practice standards.
- Ask about Rule 8 if you accept the facts and the case is eligible.
- Use the support service on 0300 303 1964.
For records-based concerns, a structured record keeping course shows targeted learning. More real decisions are in our fitness to practise case studies, and our guide to how long remediation takes helps you plan.
Frequently asked questions
How many osteopaths are struck off by the GOsC?
Very few. In 2024-25, 12 osteopaths were sanctioned: 2 removed, 1 suspended and 9 admonished. Both removals followed criminal convictions.
What is unacceptable professional conduct?
Conduct that "falls short of the standard required of a registered osteopath". The High Court has held it requires moral blameworthiness and a degree of opprobrium, the same level as misconduct for doctors.
Will the GOsC investigate poor record keeping?
Record keeping alone is not generally referred to a hearing unless it shows incompetence of a high degree or data protection failures. In Spencer, two inadequate notes were held not to be unacceptable professional conduct.
What does the GOsC Screener do?
A Screener checks whether the GOsC has power to deal with a concern and whether it could be well founded. Around half of cases close at this stage, with a target of 9 weeks.
How long do I have to respond to a GOsC allegation?
The Investigating Committee must invite your observations before the end of 28 days from the date notice of the allegation is sent to you.
How long does a GOsC case take?
In 2024-25 the median was 41 weeks from receipt to an Investigating Committee decision and 67 weeks to a Professional Conduct Committee decision.
What sanctions can the GOsC impose?
Admonishment, conditions of practice for up to three years, suspension for up to three years, or removal from the register.
What is an admonishment?
The lowest sanction. It does not restrict practice, but it is published and kept on your fitness to practise record. It was the outcome in 9 of 12 cases in 2024-25.
What is Rule 8 consensual disposal?
A way to end a case without a hearing by admitting the facts and allegation and accepting an admonishment. It is not available for dishonesty, violence, sexual or physical abuse, vulnerable people or significant treatment failings.
What insurance do osteopaths need?
Professional indemnity insurance with a minimum of £5 million cover, continuous including run-off cover, under section 37 of the Osteopaths Act 1993. You declare it at every renewal.
What happens if my insurance lapses?
You must stop practising immediately until you have cover and tell the GOsC. Knowingly practising uninsured can lead to an allegation of lack of integrity or dishonesty.
Can the GOsC suspend me before a hearing?
Yes. The Professional Conduct Committee or Health Committee can impose an interim suspension if necessary to protect the public, after giving you the chance to argue against it. You can appeal within 28 days.
How do I appeal a GOsC decision?
To the High Court, the Court of Session in Scotland or the High Court in Northern Ireland, within 28 days.
Can a removed osteopath return to the register?
Yes, by applying for restoration at least ten months after removal. The Professional Conduct Committee decides and can impose conditions.
Are osteopathy students regulated by the GOsC?
No. Only qualified osteopaths are registered. Students' fitness to practise is handled by their education provider.
What CPD do osteopaths need?
90 hours over a three-year cycle, 45 learning with others, covering all four practice standard themes, with an objective activity, a communication and consent activity and a Peer Discussion Review.
What do most GOsC hearings involve?
In 2024-25, five of twelve sanctioned cases were about practising without indemnity insurance, and four involved consent or communication, including dry needling, manipulation and an intimate examination without valid consent.
Is there support for osteopaths under investigation?
Yes. The Independent Support Service, run by Victim Support, is free and confidential on 0300 303 1964, 24 hours a day.
Primary sources
19 official documents, laws and judgments
- GOsC: Fitness to Practise Annual Report 2024-25
- GOsC: Threshold criteria for unacceptable professional conduct
- GOsC: Hearings and Sanctions Guidance (May 2025)
- GOsC: PCC practice note, Rule 8 consensual disposal (2018)
- GOsC: Professional indemnity insurance
- GOsC: Updated Osteopathic Practice Standards now in effect
- GOsC: Pocket guide to CPD
- GOsC: Independent Support Service
- GOsC: All Standards of Good Regulation met for the fifteenth year
- PSA: Monitoring report, General Osteopathic Council 2025-26
- Osteopaths Act 1993, section 8 (restoration)
- Osteopaths Act 1993, section 20 (allegations)
- Osteopaths Act 1993, section 22 (Professional Conduct Committee)
- Osteopaths Act 1993, section 24 (interim suspension)
- Osteopaths Act 1993, section 31 (appeals)
- Osteopaths Act 1993, section 37 (indemnity)
- Spencer v General Osteopathic Council [2012] EWHC 3147 (Admin)
- Sayer v General Osteopathic Council [2021] EWHC 370 (Admin)
- PSA: Regulators we oversee
