These reforms are designed to make exception reporting faster, more confidential and easier to use, while removing barriers to reporting, trusting doctors’ professional judgement, and introducing contractual fines where employers fail to provide access or protect confidentiality.
What exception reporting is
Exception reporting is the formal mechanism to log when your actual work differs from your agreed work schedule, including:
- Staying late / starting early
- Missing breaks
- Missing teaching or training opportunities
- Excessive workload / unsafe staffing
- Portfolio, mandatory training, e-learning, ARCP-related activities if required as part of the job plan
There’s no cap on how many you can submit, and you don’t need permission to submit one.
Key changes
Your supervisor is now removed from the process
For reports of up to two additional hours, the employer’s review should focus on whether the hours were worked, not determining why the doctor stayed.
These no longer go to your educational/clinical supervisor for approval, and they should not have access to personally identifiable exception reporting data unless you explicitly consent, or if one of a very limited number of exceptions apply.
Instead, they go directly to HR/Medical Workforce for actioning.
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The Guardian of Safe Working Hours (GoSWH) retains oversight and is the escalation route for disputes or unresolved reports.
This is intended to reduce conflict of interest and protect confidentiality.
Educational exception reports are reviewed by the DME, or a formally nominated deputy, within the organisation that provides your exception reporting system. In a lead employer model, a host placement or local deanery should not be notified of an individual report without your express consent, as this may constitute a breach of confidentiality.
You may wish to speak to the DME or GoSWH if you would like help reinstating missed educational opportunities.
Key rights
The focus of the employer's decision
For reports of two or fewer additional worked hours in one occurrence, the employer’s determination should focus on whether the additional hours were worked (rather than challenging the reason for the work).
You should submit an exception report as soon as possible, but no later than 28 calendar days after the occurrence (unless extenuating circumstances apply).
You can withdraw an exception report at any stage
Withdrawn reports are still retained for GoSWH review so underlying safety concerns and patterns can be identified.
All submitted exception reports should be reviewed and actioned as soon as possible
Normally this is within 7 calendar days (10 calendar days until 4 August 2026).
- You can choose PAY or TOIL, and your choice must be respected unless TOIL is mandated due to a breach of rest requirements.
Reporting systems
Below are the systems you use:
You should normally:
- use the host Trust’s exception reporting system
- follow their local induction process
- submit ERs through the system used by the department you are physically working in.
Reports will be managed by the host organisation’s HR, education departments and GoSWH.
You will usually:
- exception report via your lead employer’s exception reporting system
- even if your day-to-day work is physically in a GP practice, hospice, or community service
You should ensure that you receive details from your lead employer when you start these placements about the exception reporting system and your login details. Under the reforms, employers must provide access within 7 calendar days, and you must be able to submit a test exception report. If you tell your employer that you cannot access or submit a report and this is not remedied within 7 calendar days, fines will apply for every subsequent week it remains unfixed.
Evidence you’re expected to provide
Employers can request evidence/clarification, but the intention is not to create a high evidence threshold or for it to become a barrier to reporting. You’ll usually be asked for one of the following (depending on the situation):
- rota evidence (e.g., work schedule / rota details) and/or the minimum information needed to calculate hours claimed;
- electronic evidence of time, date and location (e.g., a timestamped location screenshot), where appropriate;
- if you cannot reasonably provide time/date/location evidence or prefer not to (e.g., home visits where you must not disclose a patient’s address), corroboration by another regulated professional (e.g., an NHS email confirming the event).
If you feel evidence requests are unreasonable or are being used to obstruct reporting, seek support from the BMA early.
New deadlines and fines
Employers can now be fined for:
- failing to provide access to exception reporting within 7 calendar days of you starting (or when you change host employer/site/rota), and failing to remedy access/completion problems within required timeframes;
- proven breaches of the confidentiality rules for personally identifiable exception reporting data (information breaches);
Access and completion breaches attract a weekly fine (£250 per doctor per week from 4 February 2026, rising to £500 per week from 4 August 2026).
Proven information breaches attract a fine of £500 per doctor per instance.
These fines are administered by the GoSWH and are used to improve training, wellbeing and the working environment (they are not paid directly to individual doctors). In lead employer models, fines are allocated to regional pots and decisions on spending this money are usually made at Resident Doctor Forums.
GP registrar FAQs
Systems and responsibility
Your lead employer should have provided details about their exception reporting system and login details at the start of your GP placement. You should submit reports directly to the lead employer.
Unless advised otherwise, these placements typically will not have their own ER system and so you should exception report via your lead employer. You should clarify this with your lead employer if you are unsure.
For exception reports when at your community placement, you should submit reports via your lead employer’s system and for exception reports whilst on the acute portion of your placement, you should submit them using the host organisation’s system, unless specific local arrangements are communicated to you within 7 days of starting a placement.
Your practice will not know that you have submitted an exception report and should not need to be involved in almost all cases. If you have chosen TOIL instead of pay, you will need to arrange with the practice for this time to be rostered after receiving a TOIL certificate once the report has been processed. This is not considered a breach of confidentiality. Similarly, for missed educational activities, you may wish to meet with your Educational Supervisor to discuss any arrangements to have these activities reinstated if you wish.
The lead employer will incur an access and completion fine for every subsequent week that you are unable to submit a test report.
Study leave / teaching / VTS days
This is classed as missing teaching or training opportunities. The relevant Director of Medical Education (whether in your acute placement organisation or lead employer) will review and work with you to determine any actions arising from the missed session.
You should complete a separate exception report for each session that is cancelled.
Necessary activities to meet your curriculum requirements and prepare for your ARCP can be submitted as exception reports if these activities are done outside of your normal work schedule. You can also submit a report if the scheduled time you have is insufficient to meet the requirements of your programme
GP-specific working patterns
We strongly encourage you and your trainer(s) to review the BMA’s guide to the training week for GP registrars while working in General Practice here.
If staying late means you work beyond your finish time on your work schedule, you should complete a staying late exception report.
You should submit an exception report for all missed breaks.
You should submit an exception report if you feel your workload is unsafe or unsafe due to staffing levels.
Safety and rest rules
Missing breaks should be exception reported. You don’t automatically get TOIL for missing a break — but if missing breaks leads to additional hours worked, you can claim pay or TOIL. Repeated missed breaks are also important evidence of unsafe workload and should trigger review.
Yes, the GoSWH should review all exception reports of this nature and meet with you to discuss the issue.
Pay vs TOIL
Usually no, unless rest rules mandate TOIL. Be mindful that if choosing TOIL, you will have to work with your local practice to have this time allocated.
Only in exceptional circumstances or towards the very end of placements should TOIL be considered impractical, in which case, payment will be made instead. You should speak to the BMA if you feel your choice of TOIL or payment isn’t being reasonably considered.
Confidentiality / fear of being “difficult”
In almost all cases, not without your express consent. In exceptional circumstances such as concerns for safety or for legal proceedings, confidentiality may be breached. You should still be informed that this is the case. If you feel confidentiality has been breached inappropriately, you should speak to the BMA.
No, exception reporting should have no impact on your ARCP or references. If you feel this has happened, you should speak to the BMA. Furthermore, you may choose to share any of your exception reports if you feel it provides context to any element of your ARCP.
The organisation will incur a confidentiality breach fine. You should speak with the GoSWH to discuss the breach or speak to the BMA.
Escalation and disputes
If your report is rejected, delayed or handled in a way that appears inconsistent with the rules, you should escalate this promptly to the GoSWH and seek BMA support.
No. Meetings should be rare. If you are asked to attend one, you may wish to seek BMA support first.