Check the scope
People employed for regulated activities in England, using the regulations’ broad meaning of employment. Specific provisions differ where Regulation 5 applies to directors.
What the law requires
- People must be of good character and have the qualifications, competence, skills and experience needed. Their ability to perform intrinsic tasks must be considered after reasonable adjustments.
- Operate effective recruitment procedures and make the applicable Schedule 3 and other legally required information available. Required professional registration must be in place.
- If a person no longer meets the relevant criteria, take necessary and proportionate action and inform the professional regulator where the regulation requires it.
What CQC expects
- CQC guidance expects checks to be completed and assessed, qualifications and registration to be verified, and fitness to be reviewed during employment.
- Providers should satisfy themselves about checks undertaken by another party and supervise staff until competent. The guidance covers agency, bank, contracted and volunteer workers, with relevant distinctions.
Suggested checks for your review
- Sample recruitment files against the actual role and applicable requirements; check that discrepancies and employment gaps were explored where required.
- Test how agency assurance is obtained and verified before deployment, rather than relying solely on a general contract.
- Trace a concern arising after appointment through risk assessment, fair investigation, interim safeguards and any required referral.
Illustrative evidence
Choose evidence relevant to the actual service and risk. These examples are not a universal list of documents required by CQC.
- Role descriptions, verified checks and documented recruitment decisions.
- Professional-registration checks and arrangements for monitoring continued registration.
- Records of adjustments, competence assessment and action on fitness concerns.
Potential gaps to check
- Documents are present but nobody has assessed a discrepancy or recorded the appointment decision.
- The same criminal-record check is assumed appropriate for every role without considering eligibility and duties.
- Sensitive recruitment information is copied widely instead of limiting access to those who need it.
Sources and review
- cqc.org.uk — Regulation 19 (opens in a new tab)
- legislation.gov.uk — Uksi · 2014 · 2936 · regulation · 19 (opens in a new tab)
- legislation.gov.uk — Uksi · 2014 · 2936 · schedule · 3 (opens in a new tab)
Content version: 1 November 2026. Next planned review 1 December 2026. Check current primary sources before relying on a requirement.
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