Physician and Anaesthesia Associates: GMC Regulation, CPD and What Changes on 13 December

Physician associates and anaesthesia associates became regulated by the General Medical Council on 13 December 2024. If you work with them, employ them, or are one, there is a date six weeks away that matters more than anything else in this post: 13 December 2026, when the transition period ends and the title offences come fully into force.

This is contested territory, and we are going to set out what the regulations say, what the Leng review recommended, what the Government accepted, and where the professional bodies actually disagree — without taking a side on whether the roles should exist.

The regulation, and the date that is still coming

The instrument is the Anaesthesia Associates and Physician Associates Order 2024, made on 13 March 2024. Most of it came into force on 13 December 2024, which is when the GMC became the regulator. But one provision was deliberately held back: the article creating the offence of using the protected titles with intent to deceive comes into force on 13 December 2026.

That two-year gap is the transition period, and it has not ended yet. Until it does, the title offences are not fully in effect. After it, using the titles with intent to deceive becomes an offence.

Registration requirements

To join the GMC register as a physician associate or anaesthesia associate you need a relevant qualification, evidence of English where the qualification was obtained outside the UK, a fitness-to-practise and health declaration, a five-year work history, employer and regulator references, and evidence of adequate indemnity and insurance.

Physician associates have one additional requirement that anaesthesia associates do not: they must have passed the national assessment. Anaesthesia associates have no equivalent national exam requirement at registration.

The register is publicly searchable, and the GMC labels each profession type prominently in its public registers and search functions so that anyone looking someone up can tell whether they are a doctor, a physician associate or an anaesthesia associate. Reference numbers for associates are seven digits beginning with the letter A.

On English language, the routes are: a UK qualification (exempt); a qualification less than two years old taught and examined solely in English with at least 75 per cent of clinical interaction in English; two years of continuous practice in an acceptable country with an employer reference; IELTS Academic at a minimum of 7.0 in each section and 7.5 overall, in the same sitting, valid for two years, with IELTS Indicator not accepted; OET Medicine at Grade B or above in all four skills in the same sitting; or a language test taken for another medical regulator in an acceptable country, under two years old.

The national assessment has been renamed

Worth getting right, because the old name is still in wide use. The Physician Associate National Examination became the Physician Associate Registration Assessment in September 2025. It is a GMC-approved assessment, and it is delivered by the Royal College of Physicians on the GMC's behalf — it has not transferred to GMC delivery. When the Faculty of Physician Associates closed on 31 December 2024, the RCP stated its Assessment Unit would continue delivering the exam on the GMC's behalf for four years.

The assessment has two parts: a 200-question single best answer knowledge paper taken online, and a 14-station OSCE. Four attempts are permitted at each part unless exceptional circumstances apply, and a pass in both parts within the last two years is required to register.

CPD and revalidation: the honest answer is not yet

This is the question we get asked most, so let us be plain about it. Physician associates and anaesthesia associates are not yet in revalidation, and no revalidation dates have been set.

The GMC says it will set individual revalidation dates in due course, that it will first develop and consult on the rules, and that once a first submission date is set individuals will get at least twelve months' notice.

The interim position is specific, though, and it is what to act on now. Registered associates should start having annual appraisals, and should collect and reflect on supporting information in six categories: continuing professional development; complaints and compliments; significant events; feedback from colleagues; feedback from patients; and quality improvement activity.

Note what is absent. The GMC specifies no CPD hours requirement and no cycle length for associates. Anyone selling you a mandatory hours figure for these roles is inventing it.

Two further things worth knowing. The GMC's chief executive told the House of Commons Health and Social Care Committee in January 2026 that the GMC would introduce a regime similar to doctors' revalidation supported by appraisal, but that it must differ because associates lack the same clinical governance structure — there are no responsible officers, for instance. And the draft General Medical Council Order 2026, consulted on from March to July 2026 with the outcome still unpublished, would put periodic assessment into GMC rules, and notes that associates could not hold the "complete restriction" that exempts some doctors from assessment.

Since the framework is being built around appraisal and supporting information, the discipline that transfers directly is the doctors' one. Our guide to the GMC appraisal supporting information checklist covers what each category actually needs, and our guide to revalidation, connection and appraisal explains how the appraisal cycle works in practice.

What associates cannot do

Two exclusions, both confirmed at source, and both frequently misstated.

Prescribing. Physician associates cannot prescribe. They cannot administer or supply medicines under a patient group direction, but may administer medicines under a patient specific direction subject to local governance. In general practice they can propose prescriptions for a GP to sign, with the prescriber remaining responsible.

Is that changing? NHS Employers states that extending prescribing is being developed by NHS England with professional representatives, and that any change must be recommended to Ministers by the Commission on Human Medicines before legislation. So: under development, not imminent, and not yet.

Ionising radiation. Associates cannot request diagnostic tests using ionising radiation such as X-rays or CT scans; any suggested investigation must be discussed with and authorised by the accountable clinician. The Royal College of Radiologists advised in January 2025 that it would be premature for associates to undertake the referrer training, and said it remained unclear whether they would be supported to act as referrers. The accepted Leng recommendations refer only to non-ionising radiation, so no change is currently proposed here.

Scope of practice: there is no national one

The GMC does not set a scope of practice for associates. Its position, recorded in a High Court judgment, is that the 2024 Order contains no express duty to impose limits, and that it relies on associates working within their competence together with employer and royal college input. The court held in September 2025 that this decision was coherent and rational.

What exists instead is interim college guidance. The Royal College of Physicians published interim scope-of-practice guidance for general internal medicine in December 2024, describing physician associates as dependent practitioners working under the direction and supervision of a consultant, associate specialist or specialist doctor, with overall clinical responsibility remaining with the supervising clinician. Its accompanying supervision guidance states that resident doctors are not, and must not be expected or asked to be, responsible for the clinical supervision of associates, and that newly qualified associates require direct supervision. It sets no associate-to-supervisor ratio, and allows on average one hour a week of job-planned time for an educational supervisor. The Royal College of Anaesthetists published an interim anaesthesia associate scope of practice in December 2024, superseding its 2016 version.

NHS England's current operational requirement is that associates should not see undifferentiated patients, with a narrow exception for triaged adults with minor ailments within clearly defined clinical protocols. Those national clinical protocols had not been published at the time of writing.

The Leng review, and what is now policy

The independent review into the physician associate and anaesthesia associate professions, led by Professor Gillian Leng, was published on 16 July 2025. It applies to England, runs to 134 pages, and makes 18 recommendations: eight for physician associates, six for anaesthesia associates and four for the wider system.

The Government accepted all 18 on the day of publication. The main ones:

• Rename physician associate to physician assistant, and anaesthesia associate to physician assistant in anaesthesia.
• Ongoing training within a formal certification and credentialling programme, with added responsibilities matching that training, including the potential to prescribe and to order non-ionising radiation.
• An "advanced" grade one Agenda for Change band higher, with national job profiles.
• Physician assistants should not see patients with undiagnosed presentations except under national clinical protocols.
• Newly qualified physician assistants should gain at least two years' experience in secondary care before moving into primary care or a mental health trust.
• A named doctor as formal line manager responsible for each one.
• National standards for clothing, lanyards, badges and staff information to distinguish them from doctors.
• A continuing national audit of anaesthesia safety outcomes, comparing teams with and without these practitioners.
• The GMC's regulation and reaccreditation requirements for these roles should be presented separately from those for doctors.

Two precision points, because both are commonly misreported. There is no Leng recommendation on induction specifically — the nearest items are the two-years-in-secondary-care point and the named supervisor. And there is no recommendation creating national scope-of-practice guidance; "national clinical protocols" for undiagnosed presentations is not the same thing, and credentialling standards were placed with the colleges and the Academy of Medical Royal Colleges.

On the evidence, the review itself describes the safety evidence as preliminary and says it should not be used alone to conclude that either role is safe or unsafe. We are going to respect that framing rather than selectively quote either side of it.

The renaming is Government policy but not yet law. The draft General Medical Council Order 2026 would protect the new titles, with protection commencing after a six-month transition once the order is in force. That consultation closed on 21 July 2026 with no outcome published. In the meantime NHS England, the Welsh Government and the RCP have all adopted the new terminology in practice — the RCP with immediate effect from 22 July 2025.

Numbers, and pay

The best-dated registration figures come from the GMC's chief executive in evidence to the Health and Social Care Committee in January 2026: about 3,900 physician associates and nearly 200 anaesthesia associates registered as at the end of December 2025, around 4,000 in total. He estimated this at upwards of 80 per cent of those in practice, while acknowledging the exact denominator is unknown.

The Leng review reported over 3,500 full-time equivalent physician associates working in primary and secondary care in England, with primary care peaking at over 2,000 FTE in June 2024, secondary care rising from about 100 FTE in September 2015 to over 1,600 FTE in March 2025, and anaesthesia associates rising from fewer than 14 FTE in 2015 to 120 FTE in March 2025. The report notes these figures combine sources collected differently.

On pay, there is no single nationally mandated Agenda for Change band. The Leng review explicitly excluded pay bands from its scope. In secondary care the NHS job evaluation scheme determines banding; in primary care local processes set pay. The accepted recommendations include a new advanced grade one band higher, with no implementation date.

Qualification route

UK-trained physician associates complete postgraduate study lasting at least 90 weeks, about 3,200 hours split equally between theory and clinical practice, on an intensive two-year programme aligned to the national curriculum and quality-assured by the GMC. Applicants must already hold an undergraduate degree, usually in a biomedical, health or life science field, and need some prior health or social care experience. Anaesthesia associate training is a two-year postgraduate programme.

The GMC approved 36 courses — 33 for physician associates and three for anaesthesia associates — with four approved subject to conditions and one not approved. Together the approved courses can qualify up to 1,101 people a year.

There is an apprenticeship, and it needs stating carefully. ST0518, physician associate integrated degree, sits at Level 7. Its status is approved for delivery but paused for starts, and it is in revision with a revised assessment plan published for information only pending a funding decision. Separately, since 1 January 2026 Level 7 apprenticeship funding has been restricted to apprentices aged 16 to 21, or under 25 with an education, health and care plan or care experience. Anyone who started before that date keeps funding to completion. So the accurate statement is that the apprenticeship exists, is paused, and would in any case be closed to most career changers by the funding restriction.

Where the professional bodies actually disagree

The coverage makes this look like a straight fight. It is narrower than that, and it is worth being accurate about.

The BMA, the Royal College of Physicians and the Royal College of Anaesthetists all want clearer role identification, senior-doctor supervision, and limits on independent decision-making. None argues that associates should substitute for doctors.

They diverge on four things. Who should regulate: the BMA wants regulation by the HCPC rather than the GMC; the colleges have not called for that. Whether recruitment should continue: the BMA says all recruitment must be halted until there is clarity and material assurance on scope, while the Royal College of Anaesthetists lifted its own recruitment pause in February 2026 while stating it does not support and sees no justification for rapid expansion of the role, and the RCP accepts a limited role subject to a nationally agreed scope. Undifferentiated patients: the BMA opposes the position that associates may see triaged adults with minor ailments under clinical protocols, which the Government and NHS England have adopted. And pace: the BMA says implementation has taken too long, while the GMC says litigation slowed progress and that it is confident of delivering the recommendations it owns.

Three legal challenges have been heard and all were unsuccessful: the BMA's challenge to the GMC's use of "medical professionals" as an umbrella term and its single Good Medical Practice was dismissed on all three grounds in April 2025; a challenge by Anaesthetists United and others over the GMC's failure to set scope limits was dismissed in September 2025; and a challenge to the Leng review's implementation was refused permission in July 2026, with all grounds found unarguable.

What to do before 13 December

If you employ associates: check every one of them is on the GMC register, review job descriptions against the undifferentiated-patients position, confirm each has a named supervisor who is a consultant, specialist or associate specialist, and make sure the language used with patients does not imply they have seen a doctor.

If you are an associate: make sure your registration is in order before the transition period ends, start the annual appraisal cycle now even though revalidation has no date, and keep supporting information in all six categories from this year rather than from whenever a submission date is eventually announced. Twelve months' notice sounds generous until you are twelve months from a submission date with nothing collected.