CQC registration: normal rules still apply during the pandemic

Health and social care providers must review CQC registrations to ensure they remain compliant with regulatory requirements.

A provider of health or social care services must only carry on regulated activity if it is registered with CQC. Carrying on regulated activity otherwise is a criminal offence.

The coronavirus pandemic has created a number of regulatory issues that providers should be aware of as a result of efforts to meet the Department of Health and Social Care’s response to COVID-19.

Changes to regulated activity

As a consequence of coronavirus, some providers will be carrying on new regulated activity. In particular, providers screening for and diagnosing COVID-19 may now provide diagnostic and screening procedures and may also provide new triage and advice services.  Registrations must be updated to ensure that they are registered to carry on any new activity.

Changes to locations

A provider’s permission to carry on regulated activity is restricted by conditions on their registration.  This includes the locations out of which a provider is authorised to carry on regulated activity, which are listed as conditions on a provider’s registration.

The coronavirus pandemic has impacted severely on health service capacity and providers requiring additional space (or new space where they have been displaced by other providers) to accommodate patients have been forced to increase bed numbers or rapidly relocate certain services. By doing so, a provider may be providing services out of locations not listed on their registration.

Notifying changes to CQC

Providers will have understandably prioritised continuity of services during this unprecedented time and so may have overlooked regulatory matters.  As we move beyond the initial stages of the crisis, it is important providers turn their attention to regularising their regulatory position and ensure any changes are notified to the CQC. The normal rules still apply. The likelihood of enforcement action by CQC for regulatory breaches can reasonably be expected to increase over time.

CQC has published guidance which confirms that COVID-19 related applications to vary registrations should be clearly marked as such, and that it will seek to prioritise applications based on urgency of provision. 

The guidance confirms that health providers must register for any new regulated activity, but the position is less clear in respect of new locations.  New temporary locations are reportedly being treated by CQC as satellite services (and so do not need to be listed as a separate location on a registration). But a primary care provider setting up new services from a new location reportedly, may need to apply to add the new location.  Providers are encouraged to communicate with the CQC’s registration team before filing any applications in relation to new locations. 

Social care providers increasing bed numbers at a location must apply to vary the relevant condition on their registration, but are also being advised to contact CQC before applying to register a new location.

The CQC’s guidance together with links to application forms and contact details for its registration team is available here

Our content explained

Every piece of content we create is correct on the date it’s published but please don’t rely on it as legal advice. If you’d like to speak to us about your own legal requirements, please contact one of our expert lawyers.

Posted by


Mills & Reeve Sites navigation
A tabbed collection of Mills & Reeve sites.
My Mills & Reeve navigation
Subscribe to, or manage your My Mills & Reeve account.
My M&R


Register for My M&R to stay up-to-date with legal news and events, create brochures and bookmark pages.

Existing clients

Log in to your client extranet for free matter information, know-how and documents.


Mills & Reeve system for employees.