New CQC registration requirements for medical services at events
An important amendment has been made to the Health and Social Care Act 2008 (Regulated Activities) Regulations 2014, which is aimed at improving the safety, quality and oversight of medical treatment services at events such as sports fixtures, concerts and festivals.
Previously, services were exempt from registration with CQC if they were:
- providing treatment in a sports ground or gym, for the benefit of those participating in or attending sporting activities or events, or
- providing treatment through temporary arrangements for sporting or cultural events
Examples of this type of service could include independent or private ambulance services, or services providing medical treatment beyond delivery of first aid, such as monitoring and diagnostics, assessment and triage, or administration of medicines and surgical procedures.
Why the exemptions were removed
The effect of the previous exemptions meant these types of services were not always regulated and inspected by CQC. Both the Manchester Arena Enquiry (November 2022) and CQC’s consultation on the state of care in independent ambulance services (March 2019) raised concerns that the lack of regulation had led to:
- variable quality and safety of these types of service
- lack of governance and oversight
- gaps in Disclosure and Barring Service and DVLA licence checks.
New CQC registration requirements from September 2026
The Health and Social Care Act 2008 (Regulated Activities) (Amendment) Regulations 2026 aim to address those concerns by requiring services to register with CQC from 7 September 2026.
It will become an offence to operate without registration from 6 December 2027.
CQC have stated that they will aim to review and determine applications received on or by 1 March 2027 before 6 December 2027. CQC have warned that, whilst they will still assess applications made after that date, the application may not be determined before 6 December 2027.
CQC guidance and consultation
CQC have issued interim guidance on registration requirements for this type of service and proposes to update its full supporting guidance shortly. Draft guidance is available on CQC’s website, and CQC are seeking feedback from providers on the draft guidance by 19 June 2026. You can do this here.
How to determine whether registration is required
In the meantime, we consider that the key factors to consider when determining the need for registration are:
- Whether the service is providing treatment of disease, disorder or injury, for example:
- emergency treatment
- treatment for longer-term physical or mental health conditions
- giving vaccinations or immunisations
- palliative care.
- whether the service is provided by or under the supervision of a listed healthcare professional, for example:
- a medical or dental practitioner
- a nurse
- a midwife
- a paramedic
- a radiographer
- The specific aim of the treatment and whether it extends beyond urgent care or first aid (an initial response to sudden illness or injury, to alleviate it or prevent it from worsening until professional medical help is available).
Services not affected by the changes
First aid and medical treatment provided by sports team doctors, pharmacists, or occupational therapists are not affected by these changes. Hempsons can provide you with further, bespoke advice on registration requirements or regulatory action by CQC.
How Hempsons can help
Hempsons can support providers of event medical services in assessing whether they fall within scope of the new CQC registration requirements. We also advise on regulatory risk, compliance obligations and engagement with CQC. If you have any questions, or we can be of any assistance, please contact us below.