Designated Body, Responsible Officer & Suitable Person

The system exists so that every doctor is connected to an organisation that has responsibility for supporting and overseeing their professional practice, appraisal and revalidation.

For most doctors, the designated body will be linked to where they work. Most NHS Trusts are designated bodies, while for locum doctors it may instead be a locum agency or, in some cases, an NHS organisation where they undertake regular bank work.

The designated body is also part of the wider clinical governance and professional oversight system. Concerns about a doctor’s conduct, performance or patient safety can be raised through the organisation and, where appropriate, escalated to the Responsible Officer.

Your designated body is recorded on the GMC register, which also provides reassurance that there is an organisation formally responsible for your appraisal, revalidation and professional oversight.

A designated body is an organisation that has formal responsibility for overseeing a doctor’s appraisal, revalidation and professional governance.

Each designated body has a Responsible Officer, who reviews the doctor’s revalidation evidence and, when the revalidation date approaches, makes a recommendation to the GMC.

In practical terms, having a designated body is particularly important for revalidation. It provides the normal route through which your appraisal history and supporting information are reviewed and a recommendation is made to the GMC.

As explained in the previous section, it is possible to complete appraisals without a designated body and notify the GMC of these using a REV12 form. However, when you reach your revalidation date, you will usually need an appropriate organisation or person to review your appraisal evidence and make a revalidation recommendation.

If you do not have a designated body or another recognised revalidation connection, you may have to follow the GMC’s direct route instead, which can involve additional assessment requirements and, in some cases, a formal examination.

Ideally, every doctor with a licence to practise should have an appropriate designated body.

However, there are situations where a doctor may temporarily have no designated body. This can happen when you are applying for your first job, have recently left a post, are between roles or have not yet established enough of a working relationship with an organisation for it to become your designated body.

Some organisations, particularly locum agencies or Trusts, may also require you to complete a certain amount of work before they will accept you as having a prescribed connection.

You can remain GMC registered without a designated body, but you still need to think carefully about how you will maintain your appraisal and revalidation evidence.

If you hold a licence to practise, you should normally continue to undertake annual appraisal and maintain enough clinical activity to support meaningful appraisal. In practice, this will usually require some recent UK clinical exposure or observership activity rather than having no clinical involvement at all.

The GMC publishes a list of designated bodies and their Responsible Officers on its website:

View the GMC list of designated bodies

You can also connect to a designated body through your GMC Online account. However, it is usually sensible to contact the organisation first and only add it if you believe you have a legitimate connection to that designated body.

For many doctors, the correct designated body will be straightforward. If you work for an NHS Trust, that Trust will often be your designated body. If you work predominantly through a locum agency, the agency may be your designated body. If you work mainly in private practice, you may need to join an organisation that provides appraisal and revalidation support for independent doctors, which may involve paying a membership or annual fee.

Some doctors will not fit neatly into any designated body. This is particularly common if you are between jobs, working overseas, doing very limited clinical work or undertaking a mixture of independent roles.

If you are not currently practising and do not expect to return for some time, you may wish to consider whether maintaining your licence to practise is necessary.

If you expect to return to clinical work relatively soon, it may instead be worth maintaining an appropriate level of practice, continuing to collect supporting information and completing your annual appraisal so that your revalidation evidence remains up to date.

A Responsible Officer (RO) is a senior doctor appointed by a designated body to oversee the appraisal, revalidation and professional governance of doctors connected to that organisation.

Their role is broader than simply signing off revalidation. They review information about a doctor’s practice, including appraisal history, clinical governance information and any relevant concerns about performance, conduct or patient safety.

When your revalidation date approaches, the Responsible Officer considers whether there is enough appropriate evidence to make a recommendation to the GMC.

They can normally recommend that you are:

revalidated

deferred, while further information is collected

or, in more serious circumstances, that they are unable to recommend revalidation.

The final revalidation decision is made by the GMC.

The Responsible Officer is also an important point of escalation if significant concerns arise about a doctor’s fitness to practise, professionalism or patient safety.

For revalidation, the Responsible Officer (RO) reviews the information available across your revalidation cycle and decides what recommendation to make to the GMC.

At your revalidation point, they will consider whether there is enough evidence to recommend that you are revalidated, whether your revalidation should be deferred to allow more time or evidence, or whether there has been persistent failure to engage with revalidation requirements that needs to be reported to the GMC. Non-engagement with revalidation is different from a disciplinary or fitness-to-practise process.

In practical terms, they will normally expect to see a consistent appraisal history across the five-year revalidation cycle, together with appropriate supporting information. This will usually include evidence of quality improvement activity, and patient and colleague feedback during the cycle.

The overall picture matters more than any single document: the RO needs to be satisfied that you have engaged appropriately with appraisal and revalidation and that there are no unresolved concerns preventing a positive recommendation.

If you do not have a prescribed connection to a designated body, a GMC-approved Suitable Person may, in some circumstances, be able to oversee your revalidation and make a recommendation to the GMC on your behalf.

Their role is broadly similar to that of a Responsible Officer. They review your appraisal history and supporting information and, when appropriate, make a revalidation recommendation.

Suitable Persons are relatively uncommon. They are normally experienced senior doctors with substantial knowledge of appraisal, revalidation and medical governance.

Unlike the Responsible Officer provided through an employer or designated body, a Suitable Person arrangement may also involve a private fee, particularly where the service is being provided independently.

Ideally, this arrangement should be established before you reach your revalidation date, rather than trying to find a Suitable Person at the last minute.

Working for several organisations does not mean you have several designated bodies. You should normally have one prescribed connection and therefore one Responsible Officer overseeing your revalidation.

It is tempting to assume that your designated body is simply the organisation where you spend the most time, but this is not always the case. The correct designated body is determined by the prescribed connection rules.

For many doctors this will naturally be their main NHS employer. For others, particularly locums or doctors combining NHS, agency and private work, the position may be less obvious.

Remember that even though you have one designated body, your appraisal should cover your whole scope of practice, including work undertaken for other organisations.

Working overseas can make appraisal and revalidation more complicated.

If you spend only part of your revalidation cycle overseas and subsequently return to substantive UK practice, this is very different from living and working overseas for the entire five-year period.

Similarly, if you live overseas but continue to undertake meaningful UK clinical practice, it may still be possible to maintain appropriate appraisal and revalidation arrangements.

The important issue is whether your Responsible Officer has enough appropriate information to understand and oversee your whole scope of practice, including any work undertaken outside the UK.

If a substantial proportion of your practice is overseas, I would strongly recommend discussing this with your Responsible Officer well before your revalidation date. Ask specifically what evidence they will accept, what UK practice they expect you to maintain and whether they are likely to be able to make a revalidation recommendation.

Do not wait until the end of the five-year cycle to establish this.

Having no designated body is not necessarily an immediate problem, particularly if it is temporary. The important thing is to avoid allowing your appraisal and revalidation evidence to lapse.

If you are new to the UK and applying for your first post, continue building appropriate evidence and keep your appraisal arrangements up to date.

If you are locuming or between jobs, again, try to continue with annual appraisal while you establish a prescribed connection.

If the majority of your work is independent or private practice, you should think more long term. You may need to identify an organisation that can provide appropriate appraisal, governance and ultimately revalidation support.

If having no designated body is only temporary, my general advice would be to continue with appraisal and supporting information rather than allowing a gap to develop.

The closer you get to your revalidation date, the more important it becomes to establish who will actually be able to review your evidence and make the recommendation to the GMC.

It depends entirely on the nature of the concern.

If the issue is simply poor engagement with appraisal or missing revalidation evidence, the first approach will often be supportive. The doctor may be given additional time, advice about what is missing or a clear plan for completing the required evidence.

If there is persistent failure to engage despite repeated opportunities and support, the Responsible Officer may eventually need to inform the GMC that the doctor is not engaging with revalidation.

Concerns about professionalism, conduct, performance or patient safety are different. Depending on their seriousness, the Responsible Officer may agree an action or support plan with the doctor, seek further information, liaise with employers or other organisations, or use the relevant local governance processes.

Where the concern is sufficiently serious or raises a potential fitness-to-practise issue, referral to the GMC may be appropriate.

A concern being raised with the Responsible Officer does not therefore automatically mean a GMC referral. The response should be proportionate to what the concern actually is and how serious it is.

Sources:

GMC – Revalidation

GMC – Designated Bodies and Responsible Officers

GMC – Prescribed Connections

GMC – Guidance for Doctors Without a Responsible Officer or Suitable Person

GMC – Suitable Persons

NHS England – Medical Appraisal Guide

NHS England – Responsible Officer Guidance

These sources explain how designated bodies, Responsible Officers and Suitable Persons fit into the appraisal and revalidation system, including prescribed connections, revalidation recommendations and what happens where concerns or non-engagement arise.

The exact organisation responsible for your revalidation will depend on your individual working arrangements and prescribed connection. If your situation is unusual — for example, you work mainly overseas, privately, through several agencies or have no obvious designated body — it is sensible to confirm your position directly with the GMC or the relevant Responsible Officer.

Last reviewed: August 2026