July 3, 2026

What does CQC registration look like in 2026?

Posted in Dispute Resolution, Health and Social Care

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Anna Fee

Senior Associate

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Since early 2026, the CQC has amended its registration process in an effort to reduce delays and address the backlog of applications. Following initial validation checks, incomplete applications are now rejected and returned before they are submitted to a registration inspector for assessment. In turn, this means that providers risk losing their place in the queue and must submit a new application in full.

Applications can be rejected if:

Information is missing
Information is inaccurate or out of date
There are inconsistencies between the provider application and associated registered manager application
Supporting documents are missing

For providers, delays in obtaining registration can have a significant impact on the financial viability of a service. It is therefore essential to prepare thoroughly before submitting an application to the CQC. The validation stage should no longer be approached on the basis that issues can be addressed after submission; the CQC expects applications to be complete, accurate and ready for assessment at the point they are submitted.

To minimise the risk of delay, providers should carefully review the CQC guidance and ensure that all required documentation is complete and ready before the application is submitted. Where there is any uncertainty about the documentation required, specialist advice can help identify and resolve any gaps in advance. Taking a proactive and organised approach will help reduce the risk of delays.

Providers of services for autistic people and people with a learning disability

From February 2026, if a provider of a service for autistic people and people with a learning disability is submitting a CQC application for registration, they are required to include a Positive Behaviour Support (PBS) policy and a restraint (restrictive interventions) policy. Both these policies must explicitly align with the CQC’s Right Support, Right Care, Right Culture guidance.

Services which now fall outside the scope of registration

As of 26 March 2026, if a service or individual only offers diagnosis of ADHD or autism and does not provide treatment, they no longer fall within the scope of registration. This is because diagnostic assessments of this nature do not involve the use of equipment to measure physiological data. If a service goes beyond diagnosis to provide treatment, they are carrying out the regulated activity of the “Treatment of Disease, Disorder or Injury” and must be registered with the CQC.

What happens if the CQC refuses registration?

Once a registration application has been processed and site visits and Nominated Individual/ Registered Manager interviews undertaken, the application will either be granted by way of a Notice of Decision (“NOD”) or refused by way of a Notice of Proposal (“NOP”) to refuse registration.

The NOP sets out the CQC’s reasons for refusal and the applicant has 28 calendar days from issue of the NOP to make written representations against it. It is beneficial for providers to seek legal advice at this stage so that they can consider the CQC’s concerns and draft robust representations to the NOP.

If the provider’s representations are accepted, the CQC will withdraw the NOP. If they are not accepted, the CQC will issue a NOD and, at the point, the provider’s only right of appeal is to the First-Tier Care Standards Tribunal. Again, specialist legal advice is strongly advised at this stage as a court case will follow.

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