Clinic policies and procedures: a CQC guide

First decide whether you need to register

CQC registration is triggered by carrying on a regulated activity listed in Schedule 1 of the Health and Social Care Act 2008 (Regulated Activities) Regulations 2014. Carrying on a regulated activity without registering is a criminal offence, so this is worth settling properly rather than assuming.

For independent clinics, four activities do most of the work:

• Treatment of disease, disorder or injury — the broadest, and the one most private clinics register for
• Surgical procedures — anything surgical, including procedures many clinics think of as non-surgical
• Diagnostic and screening procedures — imaging, endoscopy and similar
• Transport services, triage and medical advice provided remotely — one of the three activities online primary care services most commonly need

Purely cosmetic versus medical indication

The line most aesthetic clinics sit on is whether a treatment is delivered for appearance or for a medical reason. Botulinum toxin administered purely to soften lines is generally outside CQC scope. The same injection given for hyperhidrosis, chronic migraine or bruxism is treatment of disease, disorder or injury, and it brings the clinic into registration.

In practice this means a clinic can drift into registrability without noticing, simply by adding a service. If you take on one medical indication, the regulated activity applies to the clinic — not just to that one appointment.

Which clinic policies and procedures does CQC expect?

Once registered, the fundamental standards in Regulations 8 to 20A of the 2014 Regulations set what you must evidence. The policy set below maps to them:

• Person-centred care (Reg 9) and dignity and respect (Reg 10)
• Consent to care and treatment (Reg 11) — including cooling-off periods and the capacity to consent to elective cosmetic work
• Safe care and treatment (Reg 12) — clinical protocols, complications and emergency management, sepsis and anaphylaxis
• Safeguarding adults and children from abuse (Reg 13), including recognising body dysmorphia and when to decline treatment
• Meeting nutritional and hydration needs where relevant (Reg 14)
• Premises and equipment (Reg 15) — decontamination, single-use devices, servicing and calibration
• Receiving and acting on complaints (Reg 16)
• Good governance (Reg 17) — clinical audit, significant event analysis, risk register and policy review cycle
• Staffing (Reg 18) and fit and proper persons employed (Reg 19), including scope of practice and indemnity
• Duty of candour (Reg 20) and display of ratings (Reg 20A)
• Medicines management, cold chain, controlled drugs and prescription security
• Infection prevention and control, sharps and clinical waste
• Information governance, records retention and confidentiality
• Chaperoning, photography and clinical images

Separately from the fundamental standards, Regulation 5 requires directors to be fit and proper persons. It is frequently listed alongside them, but it is a requirement on those carrying on or managing the service rather than one of the fundamental standards itself — worth getting right in a governance document.

Online GP and remote clinics

Remote services carry everything above plus a set of their own, because the clinician cannot examine the patient and cannot always be certain who they are speaking to. The relevant professional standard is the GMC's guidance, renamed in 2024 to Good practice in proposing, prescribing, providing and managing medicines and devices, and updated again in December 2024. Its core position is straightforward: the same standards apply remotely as face to face.

• Identity verification, and how you satisfy yourself the patient is who they claim to be and is the age they claim
• When a remote consultation is not adequate and must be escalated to a face-to-face assessment
• Sharing information with the patient's own GP, and what you do when the patient refuses consent to share
• Safeguarding when you cannot see the patient's environment
• Prescribing of high-risk and controlled medicines, and refusing inappropriate requests
• Weight-management and GLP-1 prescribing, where the GPhC now expects prescribers to independently verify patient-supplied information rather than rely on self-reported height and weight

Two 2025 changes that reshaped aesthetic practice

First, remote prescribing for cosmetic injectables has effectively ended. Since 1 June 2025 the NMC has required independent nurse and midwife prescribers to carry out a face-to-face consultation and documented clinical assessment before prescribing any product for an elective non-surgical cosmetic procedure, and the JCCP's position is that remote prescribing for aesthetics is now unacceptable across the professional regulators. Any clinic still running a remote prescribing model needs to have changed it.

Second, following a cluster of iatrogenic botulism cases in 2025 linked to unlicensed product, the MHRA strengthened the product information for every UK-authorised botulinum toxin type A. Prescribers must ensure whoever administers the product understands the updated emergency advice, and patients must be told about botulism symptoms and the four-week risk window. That is a concrete change to your consent and documentation, not merely a warning.

Keeping the set current

One further change is worth planning for. CQC currently assesses against the Single Assessment Framework and its 34 quality statements, and that remains the live framework. Sector-specific frameworks are due to replace the quality statements, with independent healthcare falling under the primary care and community services framework. If your governance documents quote the 34 quality statements verbatim, expect to revisit them.

If you are registering for the first time, how to prepare for a CQC inspection covers what an inspector asks to see, and CQC policies and procedures: the complete guide sets out the full policy framework. For a remote primary care service, the online GP library is the closer fit.