Consulting, diagnosing, and prescribing online are regulated activities in most of the UK, and registering the service is the provider's responsibility. Not the website builder's, and not your professional regulator's. Your General Medical Council (GMC) or Nursing and Midwifery Council (NMC) registration covers you. It doesn't cover the clinic.
The UK has 4 system regulators, one for each nation. Which one an online clinic registers with depends on where the service is run from, not where its patients live. Whether it needs to register at all depends on who delivers the care.
This guide covers which regulator applies, what "based" actually means, which online services fall outside scope, and how long registration takes. It's general guidance, so confirm your own position with the regulator before you apply.
Key takeaways
- 01Register the service as well as yourself: your professional registration covers you, and a system regulator covers how the clinic is run.
- 02Where you're run from decides the regulator: an online clinic registers in the nation it operates from, not the nations its patients live in.
- 03A virtual office doesn't count: the CQC looks at where the service is actually run, not where the company is registered.
- 04Who delivers the care decides whether you're in scope: a doctor-led online service is regulated in every nation, while some led by pharmacists or psychologists aren't.
- 05Allow at least 3 months: apply while your website is being built, because registration usually sets the launch date.
- 06Ask early if you work across nations: one email to each regulator settles it before you've built around a guess.
Isn't my professional registration enough?
No. An online clinic sits under more than one kind of registration, and most clinicians only have the first.
| What's registered | With whom | What it covers |
|---|---|---|
| You, as a clinician | GMC, NMC, General Pharmaceutical Council (GPhC), or Health and Care Professions Council (HCPC) | Your fitness to practise, anywhere in the UK |
| The clinic, as a service | The system regulator for the nation it's run from | How the service is run, from safety and staffing to records and consent |
| A pharmacy, if you dispense | GPhC in Great Britain, or the Pharmaceutical Society of Northern Ireland (PSNI) | The premises that dispense and supply medicines |
| How you handle data | Information Commissioner's Office (ICO) | The clinic as a data controller, with a fee from £52 a year at the smallest tier |
Doctors also need a licence to practise alongside their GMC registration, because the licence is what allows them to prescribe. Online pharmacies have a separate question about premises, covered in your GPhC registration is tied to your domain.
Which regulator covers each nation?
Each nation has its own regulator, its own law, and its own name for an online-only service.
| Where the clinic is run from | Regulator | What an online-only service registers as | Whose services are in scope |
|---|---|---|---|
| England | Care Quality Commission (CQC) | A provider of regulated activities, with its business address as the location | Treatment by doctors, dentists, nurses, midwives, paramedics, radiographers, physician associates, and a few others, or a team that includes one |
| Scotland | Healthcare Improvement Scotland (HIS) | An independent medical agency | Services by doctors, dentists, dental care professionals, nurses, midwives, pharmacists, and pharmacy technicians |
| Wales | Healthcare Inspectorate Wales (HIW) | An independent medical agency | Services by doctors |
| Northern Ireland | Regulation and Quality Improvement Authority (RQIA) | An independent medical agency | Services by doctors |
An independent medical agency is the category for a service without a hospital or clinic of its own, which is what most online clinics are. HIS puts it simply: "Online services (such as an online GP) are IMA."
Why does it depend on where you're based?
Each regulator's powers stop at its own border. In England, the law says an activity is only a regulated activity "if it is carried on in England", and the other nations work in the same way. An online clinic carries on its activity where it's run from, so that's the regulator it registers with.
The regulators say so in their own guidance:
- CQC: for online-only services, "your HQ or business address is the location".
- HIS: a service run from Scotland with patients across the UK is an independent medical agency, and a provider based in England doesn't have to register with HIS.
- HIW: for services that only see patients online, its registration enquiry asks whether the company or business address is in Wales.
"Based" means where the clinic is actually run
A registered office isn't enough. The CQC says, "We do not consider virtual offices to be a location", and a provider based outside England that carries on regulated activity in England is expected to give an address in England.
The CQC looks at where the work actually happens. In 2022 it prosecuted an online doctor service whose doctors were based abroad, because its medicines were sent out from premises in England and the service wasn't registered.
What if you work across nations?
The borders aren't perfectly tidy. The CQC tells England-based providers that if they "plan to also offer services in Scotland, Wales, or Northern Ireland, you may have to register with the relevant local regulatory authority as well." RQIA has previously registered online providers from Great Britain that supplied medicines through pharmacies in Northern Ireland.
If your clinicians work from different nations, your medicines are dispensed in another, or you plan to treat patients across the UK from day one, email each regulator with a short description of the service before you apply. It's 4 emails, and it settles the question before you've built around a guess.
Does every online clinic need to register?
No. Whether a service is in scope depends on who delivers the care, and the 4 nations draw the line in different places.
In England, treating disease, disorder, or injury is a regulated activity when it's done "by or under the supervision of a health care professional, or a team which includes a health care professional", and the regulations list exactly who counts. The list includes doctors, dentists, nurses, midwives, paramedics, radiographers, and physician associates. It doesn't include pharmacists, clinical psychologists, physiotherapists, occupational therapists, or dietitians, and the CQC's guidance says a standalone treatment service run by one of them doesn't need to register for this activity. Once a doctor or nurse joins the team, it does.
In Scotland, the definition covers doctors, dentists, dental care professionals, nurses, midwives, pharmacists, and pharmacy technicians. It leaves out therapy given only by talking.
In Wales and Northern Ireland, an independent medical agency is a service provided by doctors.
| Who delivers the care | England | Scotland | Wales | Northern Ireland |
|---|---|---|---|---|
| Doctors, or a team with a doctor | In scope | In scope | In scope | In scope |
| Nurses or midwives, no doctor | In scope | In scope | Usually outside | Usually outside |
| Pharmacists, no doctor or nurse | Usually outside | In scope | Usually outside | Usually outside |
| Psychologists, physiotherapists, or dietitians on their own | Usually outside | Outside | Usually outside | Usually outside |
If you're a pharmacist prescriber, our guide to whether pharmacist prescribers need CQC registration covers what being outside scope means in practice, from what your website should show to who checks your service is safe.
The independent doctor exemption doesn't cover online work
Some doctors assume they're covered by the CQC's exemption for independent doctors. It only applies to treatment from a surgery or consulting room, and the CQC says it doesn't apply to treatment provided remotely by telephone, video consultation, or email.
Outside scope isn't the same as unregulated
A service outside a system regulator's scope still has to meet a lot of the same expectations:
- Your professional standards still apply, including the high level principles for remote consultations and prescribing, agreed by the GMC, NMC, GPhC, and all 4 system regulators, among others.
- Pharmacies will check. The GPhC's guidance for pharmacies that dispense for online prescribers says the UK businesses they work with must be registered with the appropriate regulator.
- Payment providers will ask. Healthcare is a closely watched sector for card payments, and payment providers usually ask for your registration details as part of their checks.
- Other activities can bring you into scope. The CQC regulates several activities besides treatment, including some diagnostic and screening procedures, so check the full list if you arrange tests. Our guide to connecting a virtual clinic to labs and scan centres covers how testing works.
What does registering with the CQC involve?
An application to the CQC names who's responsible and what the service does.
- The provider: usually your company, or you as an individual.
- A registered manager: needed for a company, or for an individual who isn't in full-time day-to-day charge of the service.
- A nominated individual: a director, manager, or company secretary who supervises how the regulated activity is managed.
- A statement of purpose: your aims, the services you provide, who they're for, and where you run them from.
- A location: for an online-only service, your business address.
How long it takes. The CQC says registration "can take a few months". It has been working through a backlog: its June 2026 board papers show 987 applications, about 16% of those in its system, had been waiting more than 10 weeks, down from 3,933 a year earlier.
Fees. The CQC charges an annual fee, set by the type and size of your service.
Once you're rated. You must show your CQC rating on your website, with a link to the latest report, no later than 21 days after the CQC publishes it.
If you're launching an online weight loss service, there are extra checks covered in how to run a compliant online weight loss clinic.
What about Scotland, Wales, and Northern Ireland?
Scotland
HIS has regulated online independent medical agencies since 19 June 2024, and running one without registering has been an offence since 19 June 2025. If your online clinic is run from Scotland and started before then, check that it's registered now.
HIS says registration currently takes about 3 months, as long as the application is complete when you send it. For 2026/27, an independent medical agency pays £3,996 to apply and £1,907 a year after that.
Wales
HIW describes an independent medical agency as "a service that doesn't have a fixed establishment (remote/online)" where the individual or company is based in Wales. In law, it's a service provided by doctors. HIW takes registration enquiries through its website, so describe your service there before you apply.
Northern Ireland
RQIA registers independent medical agencies under the 2003 Order, which defines them as services provided by doctors. It has previously registered online providers from Great Britain where medicines were supplied through pharmacies in Northern Ireland, so if any part of your service runs there, ask RQIA directly.
What does a regulator expect to see on your website?
Several requirements land on your website, not just in your policies.
- Who's treating the patient. The remote prescribing principles ask clinicians to tell patients "their name, role and (if online) professional registration details".
- Prescriber details, if a pharmacy dispenses for you. The GPhC's guidance for pharmacies providing services at a distance expects the prescriber's name, the prescribing service's address and contact details, the prescriber's registration number and the country they're registered in, and how to check that registration, to be shown prominently.
- Your CQC rating, once you have one, with a link to the report.
- Nothing that advertises a prescription-only medicine. The law doesn't allow an advert likely to lead to the use of one, so your pages should describe the consultation and the service. Our guide to marketing a virtual clinic covers what to advertise instead.
- The standard pages: privacy, terms, cookies, complaints, safeguarding, and accessibility, written to what your regulator asks for.
When should you apply?
As early as you can. For most online clinics, registration sets the launch date, not the build. You can apply while the website is being built, and the clinic can be built and tested in the meantime, so nothing is waiting on it once registration comes through.
A sensible order:
- Set up the business that will be the provider, in the nation you'll run it from.
- Ask the regulator whether your service is in scope, if there's any doubt, especially if your team spans nations or isn't led by a doctor.
- Register with the ICO as a data controller.
- Apply to the regulator, with your registered manager and nominated individual named and your statement of purpose ready.
- Start the payment and dispensing checks at the same time, because both partners will ask for your registration details.
- Set the launch date once registration is through.
The wider setup, from the patient journey to the platform, is covered in how to start an online clinic in the UK. And if you're comparing who should build it, mistake 5 in our list of launch mistakes is assuming the regulatory responsibility comes with the build. It stays with you.
Launch a registered online clinic on Clinic Pro
Registration is yours as the provider. Clinic Pro builds the clinic around what your regulator will ask to see.
- Compliance pages for privacy, terms, cookies, complaints, safeguarding, and accessibility, written to your regulator's list.
- Clinician details on the website, with names, roles, and registration numbers.
- Records, consent, the audit trail, and correspondence, all things you can show an inspector on screen.
- Separate roles for clinicians, prescribers, and administrators, with prescribing behind a PIN and signature.
- A build that runs alongside your application, so the clinic is ready when registration comes through.
Planning an online clinic and working out where to register? See how a virtual clinic launches on Clinic Pro.
Register where you're run from
Your professional registration covers you. The clinic needs its own, with the regulator for the nation it's run from, as long as the people delivering the care bring it into scope.
Work out where the service is actually run, check who's in scope there, ask the regulator if you're unsure, and apply while the website is still being built.
