Whether there are restrictions on working during a GMC investigation, when an interim order prevents practice, telling your employer, locum work, and protecting your income
One of the first questions a doctor asks when they receive a GMC letter is whether they can carry on working. For the majority of doctors, the answer is yes — a GMC investigation does not automatically prevent clinical practice. But the position is more nuanced than a simple yes or no, and understanding the difference between the investigation stage and the interim order stage is essential.
No. Receiving a GMC investigation letter — whether a Rule 7 letter or a Rule 12 letter — does not automatically impose any restriction on a doctor's ability to practise. Registration remains current, and clinical work can continue unless and until a formal restriction is imposed by the GMC or an MPTS tribunal.
This is a critical distinction that many doctors get wrong. The GMC's investigation process and any restrictions on practice are legally separate.
The investigation determines whether there are fitness to practise concerns. Restrictions on practice — through interim orders or final orders — are imposed separately, through a distinct process, only when the relevant threshold is met.
Understanding the full investigation process from beginning to end — including where restrictions might arise — is set out in the step-by-step guide to GMC fitness to practise investigation.
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The main mechanism by which a GMC investigation leads to work restrictions is the interim orders tribunal. An IOT can impose an interim suspension (preventing the doctor from practising in any capacity requiring GMC registration) or interim conditions of practice (restricting but not preventing clinical work).
The GMC applies for an IOT where it considers the risk to patients or the public interest is such that restrictions cannot wait for the conclusion of a full investigation.
Common triggers for IOT applications include: serious allegations of patient harm, sexual misconduct allegations, active criminal investigations, significant health concerns, and cases where the doctor has been suspended by an employer on patient safety grounds.
An IOT can be convened urgently — sometimes within days of a complaint being received. The doctor is notified and has the right to make representations, but the hearing proceeds on an expedited basis.
Specialist legal representation at an IOT hearing is essential. The guide to the interim orders tribunal covers this process in full.
If an interim suspension is imposed, the doctor cannot practise in any capacity requiring GMC registration from the date the order takes effect. Attempting to practise while subject to an interim suspension is a criminal offence under the Medical Act 1983.
There is no automatic legal obligation on a doctor to tell their employer that they are subject to a GMC investigation — unless a specific obligation arises from the employment contract, the terms of any interim order, or a legal or professional duty of disclosure in the specific circumstances.
However, the practical position is more complicated. Many employment contracts include a requirement to disclose regulatory proceedings.
Some clinical governance frameworks require responsible officers to be notified of any GMC correspondence. And in some cases, concealing a GMC investigation from an employer — while continuing to work — can itself become a conduct concern if the matter comes to light.
The right approach depends on the specific circumstances of the case. Legal advice — from both a regulatory solicitor and an employment lawyer — should be obtained before deciding whether, when, and how to disclose the investigation to an employer. This decision should not be made unilaterally or in haste.
Where an interim order imposes conditions that require employer notification, that notification is not optional — it is a condition of registration, and failure to comply is a breach of the order.
The guide to GMC conditions of practice covers notification obligations in detail.
A doctor in private practice faces the same position as an employed doctor: absent an interim order, they can continue to practise during a GMC investigation. However, there are additional practical considerations:
Locum doctors under GMC investigation face specific challenges. Locum agencies and NHS trusts providing locum placements may have their own disclosure requirements —
and some agencies conduct GMC register checks that will reveal any interim orders. A locum doctor subject to an interim suspension cannot continue locum work in any clinical role requiring GMC registration.
Where there is no interim order, a locum doctor can continue working. But the practical reality — that agencies and trusts may become aware of the investigation — requires careful management. Legal advice on managing disclosure in the locum context is particularly important, given the transient nature of locum employment relationships.
Where a GMC investigation leads to restrictions on practice — whether through an interim order or through employer suspension — the financial impact can be severe. Steps that can help:
The guide to GMC sanctions covers the financial and career implications of different regulatory outcomes in more detail.
UK-registered doctors can access professional ethics training through Healthcare Ethics Courses.
Doctors with connections to Australia can consult ethics training for Australian doctors.
Those with connections to New Zealand can review professional development for New Zealand doctors.
10 CPD-certified courses for £500. Whether you are working or not, completing CPD during the investigation period demonstrates genuine engagement with professional standards — and strengthens your case at every stage.
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An interim order is a temporary restriction imposed by the MPTS tribunal while a GMC investigation is ongoing. An interim suspension prevents the doctor from practising in any capacity requiring GMC registration. Interim conditions restrict but do not prevent clinical work. An IOT can be convened urgently — sometimes within days of a complaint.
There is no automatic legal obligation unless the employment contract, an interim order, or specific clinical governance rules require disclosure. However, concealing an investigation while continuing to work can itself become a conduct concern if the matter comes to light. Legal advice before deciding whether and when to disclose is strongly recommended.
If there is no interim order, yes. Locum agencies and NHS trusts may conduct GMC register checks that reveal interim orders. A locum doctor subject to interim suspension cannot continue any clinical locum work. Legal advice on managing disclosure with locum agencies is particularly important.
Yes. Practising in any capacity requiring GMC registration while subject to an interim suspension is a criminal offence under the Medical Act 1983. Any doubt about what the interim order permits should be resolved with legal advice before returning to clinical work.
Contact your MDO immediately — most provide income protection support. Check your employment contract for sick pay or garden leave provisions. The BMA provides financial guidance. Some non-clinical work may be possible during suspension. Seek financial advice about NHS pension implications.
Potentially. Check whether your indemnity policy requires notification of GMC proceedings. Contact your indemnity provider on receipt of a GMC letter. Failure to notify an indemnity provider as required could affect cover for clinical incidents occurring during the investigation period.
Yes, absent an interim order — but check indemnity coverage, CQC notification obligations, and the terms of any private hospital practising privileges agreement. Each may have disclosure requirements triggered by a GMC investigation.
Not during the investigation stage. Interim orders imposed by the MPTS — and final orders — are recorded on the public medical register. The investigation itself, before any order is imposed, is not publicly recorded.
An employer suspension is an employment law matter — imposed by the employing trust or practice, not the GMC. An employer suspension does not affect GMC registration unless accompanied by a GMC interim order. A GMC interim suspension is a regulatory matter — imposed by the MPTS — and prevents any clinical work requiring GMC registration, regardless of employment status.
Absent an interim order, there is no formal bar on taking new roles. However, some employers conduct GMC register checks and may discover the investigation. New roles may trigger disclosure obligations under employment contracts. Legal advice before taking new appointments during an active investigation is advisable.
Complete your clinical duties safely. Do not discuss the letter with colleagues during the shift. After the shift, contact your MDO immediately. Do not respond to the GMC until you have received advice. There is no obligation to respond immediately.
Many NHS consultant contracts and GP contracts include provisions requiring disclosure of regulatory proceedings to the employer or responsible officer. The specific obligations depend on the contract terms. Employment law advice — alongside regulatory legal advice — is important for employed doctors under GMC investigation.
This guide is for educational purposes only and does not constitute legal advice. Seek independent legal advice from a solicitor experienced in GMC regulatory proceedings.
