A CQC nominated individual is a named director, secretary, or other senior person who supervises the management of a dental practice’s regulated activity on behalf of the provider, and is legally required wherever the practice is registered with the Care Quality Commission as an organisation rather than as an individual or partnership. Under Regulation 6 of the Health and Social Care Act 2008 (Regulated Activities) Regulations 2014, the provider must take reasonable steps to ensure that person is of good character, has the qualifications, competence, skills, and experience to do the job properly, and is fit to do so by reason of their health.
Because most UK dental practices now operate through a limited company or LLP rather than as a sole trader or traditional partnership, this requirement applies to the majority of practices, whether newly registering, restructuring, or going through a sale. Getting the appointment right, and understanding what the role actually involves once made, matters more than most owners initially assume.
What the Nominated Individual Is Legally Required to Do
The nominated individual’s core statutory function is to supervise the management of the regulated activity being carried on by the organisation. In practice, for a dental practice, that means being the person with genuine, active oversight of how clinical governance, safety, and quality are being managed across the registered locations, not simply a name on a CQC form. CQC expects the nominated individual to understand the practice’s structure, know how information flows up to them, and be able to demonstrate that they are actively engaged in overseeing compliance, rather than delegating the substance of the role entirely to a practice manager or registered manager while retaining only the title.
This distinguishes the nominated individual from the registered manager, who is separately responsible for day-to-day operational management at a specific location. The two roles can be, and often are, held by different people. Where they are, the nominated individual still carries organisational-level accountability to CQC for the regulated activity even though someone else is managing it daily on site. We cover the registered manager role, how it differs, and how the two roles interact in our companion article on CQC registered managers in dental practices.
Who Can Be a Nominated Individual
There is no requirement that the nominated individual be a dentist or hold a General Dental Council registration, since the role is one of governance and supervision rather than clinical practice. In most incorporated dental practices, the nominated individual is a director or company secretary who is genuinely involved in running the business, often the principal dentist-owner, a managing director, or a senior partner in a group structure. What CQC is looking for is someone with real, ongoing visibility of how the practice is governed, not a passive figurehead appointed purely to satisfy the paperwork.
CQC assesses fitness for the role against the same three-part test used for registered managers under Regulation 7: good character, the necessary qualifications, competence, skills and experience, and fitness by reason of health, after reasonable adjustments are made. When assessing character specifically, CQC has regard to matters set out in Part 2 of Schedule 4 to the regulations, which includes conduct such as any caution or conviction, any exclusion from another regulated activity, and evidence of behaviour that raises a doubt about honesty or integrity.
What the Application Process Involves
To satisfy CQC that a nominated individual meets the fitness test, the provider must be able to supply, or arrange the availability of, the information set out in Schedule 3 to the 2014 Regulations. In practice this means:
- Proof of identity, including a recent photograph
- An enhanced criminal record certificate (DBS check), including barring list information where relevant
- A full employment history, with a satisfactory written explanation of any gaps
- Satisfactory references covering conduct in previous roles connected with health or social care, or with children or vulnerable adults, where applicable
- Documentary evidence of any relevant qualifications
- A satisfactory declaration of any physical or mental health condition relevant to the person’s capability to carry out the role
CQC may also conduct a fit-person interview as part of assessing a proposed nominated individual, particularly for a new registration or where CQC has queries about the evidence submitted. Since CQC changed how it handles incomplete applications from 9 February 2026, submitting a Schedule 3 evidence pack that is missing documents or contains gaps is now more likely to result in the application being rejected outright at the point of submission, rather than CQC writing back to ask for what is missing. Assembling a complete, accurate pack before submission, rather than treating it as something that can be tidied up after the fact, is now the safer and often the faster route through registration.
Why This Is a Real Legal Consideration, Not a Formality
Providing a regulated activity, such as dental treatment, without the correct CQC registration in place is a criminal offence under section 10 of the Health and Social Care Act 2008. Because the nominated individual is the named person CQC holds accountable for supervising the regulated activity on the provider’s behalf, that accountability is personal as well as organisational. If CQC identifies serious or repeated failings in how a practice is governed, the nominated individual’s fitness for the role can be reassessed, and in serious cases CQC can take enforcement action that directly affects that individual’s position, not just the corporate registration.
This has practical consequences worth thinking through before someone is put forward for the role, including:
- Who actually has the capacity to do it properly. A dentist who is fully booked with clinical sessions five days a week may not, in practice, have the time to exercise genuine oversight, whatever their title says.
- What happens on a sale or restructuring. Where a practice is bought or sold as a share sale, the existing nominated individual arrangement may need to change; where it is an asset sale, the buyer will usually need to register a nominated individual for the new provider entity from the outset. Either way, this needs to be planned alongside the transaction timetable, not left until after completion.
- Succession and long-term absence. CQC must be notified of the long-term absence of a nominated individual, so practices should have a plan for who steps in if the named individual is unexpectedly unavailable for an extended period.
- Documentation discipline. Given the tightened approach to incomplete applications, a nominated individual should expect to keep their own compliance evidence, references, and DBS renewal, current and ready rather than assembled reactively when a variation or new application is needed.
What This Means for You
Appointing a nominated individual is a legal requirement for most incorporated dental practices, and it is a role with genuine personal accountability attached, not a box to tick on a CQC form. Choosing the right person, preparing a complete Schedule 3 evidence pack, and being clear about how the role interacts with the registered manager, all matter, particularly given how much less forgiving CQC’s application process has become for incomplete submissions. For the wider compliance picture this role sits within, see our sub-hub article on CQC compliance for dental practices, and our companion piece on CQC registered managers in dental practices for how the two roles work together.
If you are appointing a nominated individual, restructuring your practice’s registration, or planning a sale or purchase where this needs to be addressed, we would be glad to help. Get in touch with our dental practices team or call us on +44 207 566 1188, or email info@gurvelegal.com.
