Scope of Practice guidance finally revealed by the GDC: Huge Disappointment and Missed Opportunity

The GDC has revealed its new Scope of Practice Guidance that comes into force on 1^st November 2025, replacing the current guidance that has been in place since 2013. 

Many registrants were excited by the potential for the upcoming changes because they hoped that their role within the dental team might expand and that they may be able to carry out treatments that were not in their original pre-registration training, only for those hopes to be dashed by this largely unchanged guidance, which is more vague than it was originally.

The new guidance states at the outset:-

“If you want to expand your scope beyond the boundaries of your professional title, you will need to undertake further dental training and gain a formal qualification which will allow you to register under a different dental professional title.”

So that is pretty clear, no changes. The GDC has failed to take this great opportunity to revise or extend the boundaries for each registrant group. Given that this review started under the umbrella of the GDC’s Professionalism agenda, it cannot hide under the limited Scope of Practice discussions. Had the GDC taken the opportunity to review the boundaries it would have contributed constructively to the skill-mix agenda allowing competent colleagues to expand their roles within dental teams, ultimately increasing access to NHS care.

One must ask what on earth the GDC has been doing since 2019 when this piece of work started. Somewhat disingenuously when the Guidance was shared with the GDC Council at its June 2025 meeting it carefully explained that the consultation on this policy was carried out in 2024, failing to mention the full history. Had a registrant been this economical with the truth, allegations of misleading and dishonest behaviour would surely have followed.

The history of this review of the Scope of Practice goes back to 2019. It must have been in the “too hard basket” on many occasions since then. Consultations were held in March 2022 with a view to publishing the final guidance after the June 2022 Council meeting had given its approval. When the final draft of the guidance was eventually returned to the Council for approval, it was followed by a meeting with stakeholders in 2024. The stakeholders identified a number of bizarre and careless inconsistencies within the guidance, so a slice of humble pie was grudgingly chewed at the end of the meeting. This forced a further review within the GDC and the most recent consultation that took place in 2024. This part of the story has, of course, been glossed over in the Consultation Outcome Report scope-of-practice-consultation-outcome-report-2025.pdf

It is curious that some of the indemnity providers have welcomed the new guidance, given its underwhelming change. The front and centre mantra for the new guidance is that a registrant can carry out a particular task if they are “trained, competent and indemnified”. This betrays a fundamental misunderstanding within the GDC of how the indemnity/insurance business operates.

If I were to buy a top of the range Ferrari or Lamborghini none of the insurance companies would ask me whether I was trained or competent to drive such a vehicle. The insurers would carry out its usual underwriting process which looks at my claim history, age residential address etc.

Similarly, when a dental professional seeks indemnity or insurance to practise, the questions are all about risk…what is your registrant group, what types of dentistry do you plan to carry out and how much of any particularly high-risk procedures will you do? At no point does anyone ask, “are you competent to do this” nor do they seek evidence of competence. The indemnity providers and insurers are well outside their scope of competence and experience if asked to determine competence of an individual for any given clinical task.

During the Covid19 pandemic, the indemnity providers were frequently asked to give a view on whether a client or member “was indemnified” to do a particular task in the context of the pandemic. As with Scope of Practice questions, the response was to invite the client/member to reflect on their professional responsibilities and the extant guidance, always acting in the best interests of patients and their staff, even if that was on the face of it contrary to the guidance. The Covid19 experience has helped focus the thoughts of the indemnity providers as to how to approach the Scope of Practice consultation. The GDC has failed to listen when it was told on numerous occasions that much as it might want the indemnity providers to be the arbiters of competence. As Australians might say….” it’s a hard no!” but the GDC has steadfastly and oddly ignored the advice of the indemnity providers.

It is sufficient for the GDC to state, as it does, at the start of the guidance that every registrant must have the appropriate indemnity in place to practise, rather than relying upon the much-repeated mantra that a registrant must be “trained competent and indemnified” for the particular care they intend to provide/prescribe.

By putting Indemnity providers at the top if the list of people to contact to discuss whether you are “trained competent or appropriately indemnified” for a particular task, well ahead of your manager/employer/mentor devolves responsibility to those indemnity providers, first and foremost. The membership teams of the indemnity providers are not in a position to offer advice, so enquiries are diverted to the dental advice teams, diverting them from helping other members/clients deal with complaints, claims and GDC cases.

It’s not appropriate for the indemnity providers to help the GDC absolve itself of its responsibilities to set standards and issue guidance. It follows that the registrants will find this all tremendously unfair, particularly if they are the first few to be dragged through a Fitness to Practise investigation, where the GDC’s real vision for the Scope of Practice will be explored in front of the PCC.

I suppose the dental profession should be grateful for small mercies. The chaos and litigation surrounding the way the GMC and Royal Colleges have utterly failed to sort out the scope of practice of Physician Associates (or Assistants) Anaesthetists United Ltd & Ors, R (On the Application Of) v General Medical Council [2025] EWHC 2270 (Admin) (05 September 2025), not to mention the recent carnage delivered to the legal profession by the High Court concerning who can carry out litigation Mazur & Anor v Charles Russell Speechlys LLP [2025] EWHC 2341 (KB) (16 September 2025) should give the GDC a sense of achievement. The dental profession’s dispute with the GDC on its Scope of Practice is trivial in comparison. That doesn’t reduce the disappointment felt by the profession.