Responsible Officer: What They Do and When They Raise a Concern

Written and reviewed by Dr Shehzad Iqbal, MBBS, MRCS, MRCGP, Postgraduate Certificate in Healthcare Law and Ethics · Updated 4 November 2026

What does a responsible officer do?

A licensed doctor connects to one organisation for revalidation, called a designated body, such as an NHS trust or health board or an independent healthcare provider that supports your appraisal. The GMC calls this a prescribed connection. The designated body appoints a responsible officer, who is a licensed doctor, in practice the medical director or a deputy. A doctor with no designated body can have a suitable person make the recommendation instead.

The GMC is clear on two points. You cannot choose your responsible officer, and the responsible officer cannot choose which doctors connect to them. The person in the role can change, for example when they move to another job, but your designated body stays the same unless you change where you work.

The duties come from law as well as from GMC guidance. In England, regulation 11 of the Medical Profession (Responsible Officers) Regulations 2010 asks the responsible officer to:

• make sure the doctors connected to the designated body have regular appraisals;
• set up and run procedures to investigate concerns about a doctor’s fitness to practise, whether a patient, a member of staff or anyone else raises them;
• refer concerns to the GMC where that is the right step;
• monitor any conditions or undertakings a doctor has agreed with the GMC;
• keep records of fitness to practise evaluations, including appraisals, and make recommendations to the GMC.

Northern Ireland has its own regulations. The GMC’s protocol for responsible officers adds that their organisation must have systems that pick up fitness to practise concerns about its doctors promptly.

The responsible officer's revalidation recommendation

Revalidation comes round once every five years. Your responsible officer bases the recommendation on your appraisals over the cycle and on what the designated body’s clinical governance systems hold about you. The GMC tells you your submission date at least three months before it, and the responsible officer must make the recommendation on or before that date.

For the full revalidation cycle and the six types of supporting information, see our guide to GMC revalidation.

When a responsible officer raises a concern

A revalidation recommendation is not the route for a fitness to practise concern. The GMC’s protocol says a recommendation should not be used to raise concerns about a doctor’s fitness to practise, and that the responsible officer should raise any such concern with their GMC Employer Liaison Adviser as soon as it arises. The adviser helps the responsible officer decide whether the concern needs a referral to the GMC or can be dealt with in the organisation.

A concern reaches the responsible officer through a complaint, an incident, a clinical governance report, a colleague or appraisal. The local procedures the responsible officer runs then decide how it is looked into, and there are two routes:

1. Dealt with in the designated body. The concern is looked into locally and addressed, for example with a plan for remediation that is reviewed at your next appraisal.
2. Referred to the GMC. Where the concern calls for it, the responsible officer refers you. What happens next is in our guide to an NHS employer referral to the GMC.

Your rights when your responsible officer acts

A concern from your responsible officer is serious, but you have a part to play at each step.

• Advice. Contact your medical defence organisation as soon as you know there is a concern, before any meeting or written reply. Your trade union or professional body may also offer support.
• A say before a non-engagement decision. If the recommendation is non-engagement, the GMC tells you it has received it and gives you the chance to make representations. If you start to engage, the GMC may defer instead of withdrawing your licence, and a decision to withdraw a licence can be appealed.
• Clarity on a deferral. You are entitled to know what you need to do by the new date, and a deferral does not appear on the register.
• The GMC process if you are referred. A referral does not mean an outcome. The first steps are in our guide to GMC investigation advice for doctors.

Remediation and CPD for your appraisal

Whatever route a concern takes, your responsible officer wants to see that you understand it and have acted on it. Remediation is the part you control: a course matched to the concern, a written reflection on what you have changed, and evidence that the change has lasted. The same work is CPD that you bring to your annual appraisal, so it counts twice: once for the concern and once for revalidation.

1. Match the course to the concern. Records, communication, consent, a boundary with a patient or a colleague, or honesty each has its own course.
2. Write the reflection. What happened, what you understand now, what you do differently and how you check it.
3. Bring both to appraisal. Your appraiser and responsible officer can then see the concern was addressed. How online CPD counts for GMC appraisal is in our guide to online CPD courses for doctors.

The course for a concern and for CPD

Courses that sit beside it

A designated body buying for its doctors can use Bulk Buy: £200 for 3 courses, £300 for 5, £500 for 10. Not sure which course fits the concern? Book a free 15-minute call or see which course do I need.

Guides that help

The CPD courses linked from this guide, How to Deal with a Complaint or Investigation, Ethics and Ethical Standards for Doctors, Professionalism in Documentation for Healthcare Professionals and Module on Insight, are by Probity & Ethics, written by Dr Shehzad Iqbal, CPD certified and accredited by The CPD Certification Service (provider no. 13197) and offered since 2020.

Questions and answers