The draft Order enables the GMC’s governing body to be constituted without a single medical practitioner included, should it so wish. The Schedule must be amended to ensure medical practitioner representation. Doctors must make up the majority within the membership of the GMC’s governing structures. Medical practitioner members of the governing body should be directly elected by doctors (as opposed to appointment by the Privy Council). In addition, the Order must introduce a legal duty of care to the doctors it regulates, and the GMC should also have a legal duty (rather than an overarching objective) to protect the public.

We agree with the proposal to amend the National Health Service Reform and Health Care Professions Act 2002 to allow PSA to have a power to compel information from GMC, as a mechanism to support full investigations of systemic issues. However, this power does not go far enough to ensure GMC scrutiny. Section 28 of the NHS Reform and Health Care Professions Act 2002 allows the PSA to deal with complaints, but successive governments failed to bring this clause into force. The government must now do so to enable the PSA to investigate registrant complaints into the conduct of their regulator and act upon their findings.

The Order must make clear that only a registered medical practitioner can be certified as having completed a postgraduate training programme that results in a Certificate of Completion of Training (CCT). The Order wording must also be changed to remove any possibility that it allows a CCT to be issued to a non-doctor. 

The draft Order must also be amended to ensure that medical education in the UK maintains equivalence with the European Union’s Mutual Recognition of Professional Qualifications Directive. 

Finally, the Order must specifically mention medical education and a medical degree to stop the blurring of lines between doctor and physician assistant education. The powers are so wide in the draft Order that, in theory, they could allow the GMC to determine identical standards of education and training for medical practitioners and assistants. This is completely inappropriate and must be addressed. 

We strongly opposed, and continue to oppose, the GMC’s regulation of PAs and AAs, as it blurs the distinction between doctors and non-doctors. This is a significant patient safety issue, which will only be further entrenched by the creation of a single register (even in separate parts). We maintain that the best way to address patient confusion is by returning the GMC to being a single-profession regulator, with PAs and AAs regulated by the Health and Care Professions Council. But while the GMC remains the regulator of PAs and AAs, we urge the government to ensure the GMC creates two separate registers of these distinct professionals. The Order should be amended throughout to reflect this.

We strongly agree that the title ‘registered medical practitioner’ should become a protected title to refer only to doctors. We also believe that the term ‘medical professional’ and ‘registered medical professional’ should be protected and apply to doctors only. In addition, we are calling for the protection of other medical titles, including consultant, registrar and resident. 

We agree that the regulated titles of PAs and AAs should be changed to ‘assistant’, in line with BMA policy, the recommendations of the Leng Review, and coronial reports. This must be implemented immediately as patients have been waiting since July 2025 for this safety measure. The ‘physician associate’ and ‘anaesthesia associate’ titles must not be protected alongside the proposed new assistant titles.

We support the policy aim to create a less adversarial process by enabling the GMC to resolve cases through accepted outcomes. We are pleased that the draft Order sets out health as a separate ground for action. Allowing the regulator to recognise health as a separate ground supports a compassionate approach to managing health concerns and may adversely affect a registrant’s willingness to engage with the fitness to practise process. However, we do not agree with the removal of specific grounds in relation to English language, as the GMC should have the ability to commence an investigation on that specific ground, rather than relying on a ground that calls into question a doctor’s ability to provide care more widely. In addition, we strongly believe regulations should ensure that the criminal standard of proof applies during investigations and tribunal hearings.

We strongly disagree with maintaining the GMC’s right to appeal fitness to practise decisions, and the extension of this right to cover interim measures. We support the findings of the 2018 Williams Review, commissioned in the aftermath of the case of Dr Hadiza Bawa-Garba, which concluded that the GMC’s power to appeal tribunal decisions had created “significant unwelcome and unintended consequences”. It found that the right of appeal had “undermined doctors’ trust in the GMC” and deterred openness and learning. The Review further emphasised that removing the GMC’s right of appeal would help to “mitigate the distrust felt by doctors about their professional regulator”, while maintaining public protection through the Professional Standards Authority’s existing right to appeal.