The National Health Service (Concerns, Complaints and Redress Arrangements) (Wales) (Amendment) Regulations 2025 make significant amendments to the 2011 Putting Things Right Regulations, modernising the statutory framework for how concerns and complaints are handled across NHS Wales.
The changes are set out in Welsh Health Circular 2026/0061 and take effect as of 1 April 2026.
What do the updated procedures seek to do?
The amendments introduce a more streamlined, patient centred complaints process, including a defined early resolution stage, strengthened communication obligations, clearer and shorter procedural timescales, and an increased financial redress threshold.
These changes are intended to replace the predominantly investigation led Putting Things Right approach with a new, Wales wide complaints system focused on listening, early resolution, proportionality and learning, while retaining the core legal framework established by the 2011 Regulations. The new approach is known as Listening to People.
The new regulations:
- Create a formal Early Resolution stage before full investigation.
- Require clearer, accessible communication in a person’s preferred manner and
expanding what must be discussed with them (including the outcome they hope to
achieve). - Raise the redress cap to £50,000 (from £25,000). Crucially the duty to consider
redress remains with NHS Health Boards not contractors. - Tighten timeframes for cross‑organisation information exchange, investigation
reports and redress decisions. - Exclude vexatious/frivolous matters and those resolved at Early Resolution from
redress - Update monitoring/annual reporting duties.
Side‑by‑side comparison of the main changes
| Topic | 2011 regulations | 2025 amendment |
|---|---|---|
| Overall structure & who’s covered | The framework for handling concerns applies to Welsh NHS bodies, primary care providers and independent providers; specific sections for primary care and redress scheme duties sit mainly with Welsh NHS bodies. | Keeps same overall scope but modernises processes (communications, early resolution, timeframes, reporting). |
| What does this mean for GPs? | GPs remain in scope for handling concerns and cooperating with HBs. There is no wholesale shift of redress liability towards primary care. Expect stronger process duties and coordination asks | Same |
| Raising a concern & time to raise | Concerns can be raised in writing, electronically or verbally; the 12‑month time limit from incident/knowledge applies | Duration unchanged - focus is on how concerns are handled once raised. |
| What does this mean for GPs? | Existing intake arrangements should continue but practices should ensure they capture and document concerns raised across all channels and aim to manage concerns via Formal Early Resolution where possible | Same |
| Timeframes | The 2011 instrument sets key process steps but is lighter on specific day‑counts; time‑limit for notifying a concern is 12 months Detailed day‑counts have mainly sat in guidance/operational practice. | Amends timeframes for: (i) information exchange between bodies (including primary care), (ii) investigation report preparation, (iii) communication of redress decisions. (Specific day‑counts are in the laid instrument 120 days rather than 6 months.) |
| What does this mean for GPs? | Expect tighter clocks when an LHB requests records/comments, and clearer deadlines to finalise reports and redress decisions; ensure same‑day document retrieval protocols and a named complaints lead. | Same. |
| General handling principles | Must handle concerns efficiently/openly, involve the person and provide assistance; give a timely and appropriate response | Strengthens communication duties: keep the person informed via their preferred method and in a way they can understand (amended general principles). |
| What does this mean for GPs? | Update local policies/templates to record preferred communication method, use plain language, and offer accessible formats/Welsh language options. | Same. |
| Early resolution | Informal early resolution has long existed in practice/guidance; in 2023 the rules clarified that any concern resolved to the person’s satisfaction by the end of the next working day is excluded from the remainder of the process | If a complainant has made a complaint against a primary care provider and there has been an agreement to seek Early resolution, the primary care provider is responsible for the resolution Introduces a defined Early Resolution procedure with an “early resolution period” and duties to attempt resolution before full investigation. |
| What does this mean for GPs? | Build a structured triage pathway: record offers and outcomes and escalate on time if unresolved. ER can help resolve many issues without formal investigation, reducing burden on small teams. | Same. |
| What must be discussed with the person | 2011 requires establishing expectations and involving the person. | Expands discussions during investigation to include what resolution the person hopes to achieve; and after reporting, an offer of an in‑person discussion of the report. |
| What does this mean for GPs? | Train staff to ask about desired outcomes early, manage expectations, and offer a meeting to go through findings. This can reduce subsequent Ombudsman escalation. | Same. |
| Redress – who and how much | Duty to consider redress sits with Welsh NHS bodies not primary care contractors; redress cap set at £25,000. Sector guidance reflects that the redress requirement doesn’t apply to primary care providers. | Increases the cap to £50,000 within the Principal Regulations. The duty to consider and administer redress remains with Health Boards. |
| What does this mean for GPs? | For GPs: main implications are evidence provision to LHBs and potential impact on settlement dynamics. Expect more matters resolved in‑scheme rather than via litigation; check indemnity lines and local escalation pathways. | Same. |
| Dedicated rules for concerns that involve more than one body, including primary care providers; LHB duties to coordinate/decide lead responsibility and notify decisions. | Shorter/clearer turnaround times for information sharing and coordination in multi‑body cases, including where a GP is involved. | |
| What does this mean for GPs? | Expect quicker requests from LHBs for records/chronologies; practices should build standard packs (notes, significant event analysis, timelines) to respond within the new windows. | Same. |
| Responsible bodies must oversee processes; reporting duties exist but are less granular. | Updates monitoring/annual reporting to capture early resolution volumes, timeliness and outcomes, strengthening assurance. The once for Wales concerns management system is expected to be the primary mechanism for recording and reporting complaints and incidents, ensuring consistency and transparency across Wales. | |
| What does this mean for GPs? | GPs will need to supply more structured data to LHBs (e.g., counts, time‑to‑resolution, themes); align your complaints log to new fields. Consider using the once for Wales concerns management system. | Same. |
What stays the same
- Core definitions and scope (e.g., who can raise a concern; that primary care
providers are responsible bodies for handling concerns; and the 12‑month time limit
to notify a concern) remain in place, unless specifically amended - Primary care interfaces with LHBs for multi‑body concerns and decisions over who
leads the investigation continue (regs 18–21). - The duty to consider redress remains a Welsh NHS body obligation (Part 6), with
sector guidance consistently noting that primary care contractors are outside the
direct redress scheme, even though they must engage with investigations and provide information
Key steps in the updated process
The steps of the process apply to all relevant bodies subject to the regulations – namely all Welsh NHS bodies, primary care providers, and independent providers providing care commissioned by the NHS in Wale. However, the duty to consider financial compensation and NHS redress does not apply to primary care contractors.
a) Acknowledging concerns
Timescale: Concern acknowledged within 5 working days
As part of the acknowledgement, practices must offer a “listening discussion” (telephone, video or face to face) to the patient.
The offer of a listening discussion is mandatory, but the patient can decline. If declined, this must be recorded and next steps confirmed in writing.
b) Listening discussion (if accepted)
Timescale: This should take place as soon as possible after acknowledgement.
During the discussion, the practice should:
- Listen actively and compassionately
- Confirm communication needs
- Offer advocacy support
- Explore what outcome the patient is seeking
- Keep a clear written record
After the discussion the practice should provide a written summary and set out proposed
next steps.
c) Early resolution - stage 1
Timescale: Early resolution must be completed within 10 working days from the date of
acknowledgement
The practice must consider early resolution for all concerns unless clearly unsuitable. This could be if the issue is too complex/high-risk, or if the patient does not want it. If early resolution is not appropriate, the reason should be documented.
During this phase, the practice must attempt to resolve the issue quickly and proportionately. They should agree realistic, person‑centred outcomes and communicate
these clearly. If the 10-day period is not met this must be justified and communicated.
Most routine practice complaints should conclude at this stage.
If early resolution is not suitable or fails
The practice must move to investigation without unnecessary delay and set realistic timescales and communicate them to the patient. They must also keep patients updated on progress.
d) Investigation – Stage 2 (where required)
Timescale: There is no fixed statutory deadline, but delays must be justified and explained
The practice must ensure the investigation is proportionate, person‑centred and trauma‑informed. This must be communicated clearly in writing and in plain language particularly regarding clinical explanations.
Financial compensation and formal redress decisions do not apply to GP practices. But apologies, explanations and learning actions do apply and should be documented.
Throughout the process
Practices must demonstrate equity of access, ensuring accessible formats are used alongside offers of advocacy.
Practices should identify a named point of contact for each concern. This does not have to be the person undertaking the discussion/investigation but the individual needs to be appropriately skilled.
Patients are entitled to clear explanations of their rights, options and what happens next. Practices should identify learning and improvement actions. This learning should inform practice governance, quality improvement and significant event processes.
Practices will also need to consider their obligations under Duty of Candour legislation and the overarching NHS Wales Duty of Quality.