Locum Doctor Compliance Documents: UK Agency Checklist

Last reviewed: 12 October 2026. This guide is general information, not legal advice.

Before a booking, a UK locum doctor's file needs ID, right to work, GMC registration with a licence, the right register entry and revalidation details. It also needs an enhanced DBS, occupational health clearance, indemnity, references, mandatory training and a life support certificate. These are the locum doctor compliance documents most NHS clients and framework audits expect. Below is what to collect, how to verify each one, how long it lasts and where files usually fail.

In short:

• Check the GMC register yourself for every booking: registration, licence to practise and any conditions or warnings.
• Check the Specialist Register for consultant work, and the GP Register plus a performers list entry for GP work.
• Record the doctor's designated body and responsible officer so appraisal and revalidation are covered.
• Hold an enhanced DBS with barred lists, and use the Update Service or an annual recheck.
• Get written occupational health clearance, indemnity cover and in-date training before the start date.

What locum doctor compliance documents does an agency need?

An agency needs evidence for all six NHS Employment Check Standards, plus the doctor-specific checks set by the GMC.

NHS Employers says the standards apply to temporary workers, including locum doctors and agency staff. Clients must get assurance that agencies meet the same standards as direct appointments, and national framework agreements build those checks in. Our guide to the NHS Employment Check Standards covers the six standards in detail.

For a locum doctor, the full file usually holds:

1. Photo ID and proof of address
2. Right to work evidence
3. GMC registration with a licence to practise
4. Specialist Register or GP Register entry, where the role needs it
5. GP performers list entry, for GP locums
6. Revalidation details: designated body, responsible officer, last appraisal
7. Enhanced DBS with adult and children's barred lists
8. Occupational health clearance and immunisation records
9. Indemnity or medical defence cover
10. References and a full employment history
11. Mandatory training certificates
12. Life support certificate (BLS, ILS or ALS) at the level the client sets

How do you check GMC registration and the licence to practise?

Search the doctor on the online register at every booking, not just at registration with your agency.

The GMC says doctors must be registered with a licence to practise to work as a doctor in the UK. Its guidance on what to check lists the questions to answer:

• Does the doctor hold registration and a licence to practise?
• Do the registration type and licence allow this post?
• Do any conditions, warnings or restrictions apply?
• Does the GMC reference number match the register?

The GMC is blunt about agencies. Its pre-employment checks guidance tells clients not to rely on a locum agency to check a doctor's status on the register. Expect your client to check too, so your record must match what they see.

What does not count as proof of registration?

The GMC says a registration confirmation letter or a retention fee due date does not prove registration with a licence. A CCT or CESR certificate does not prove Specialist or GP Register entry. Only the live register does. Save a dated screenshot or PDF of the register entry to the file.

How long does it last?

Registration has no fixed end date, but the register can change at any time, for example when conditions or warnings are added. Recheck before each booking and keep a regular check running for doctors on long assignments.

When does a locum need the Specialist Register or GP Register?

Check the Specialist Register for consultant work, and the GP Register plus a performers list entry for GP work.

The GMC's what to check guidance tells employers to confirm both. The GMC says the Specialist Register is a legal requirement for substantive, fixed term and honorary NHS consultant posts, though not in foundation trusts. Many clients expect it for locum consultant bookings too, so confirm the requirement for each post. Both registers show on the doctor's online entry.

How do you check a GP's performers list entry?

In England, search the NHS England Performers List run by PCSE, which shows a status such as Included or Suspended. Practice details only appear where the GP has told PCSE, so a missing practice is a prompt to ask, not proof of a problem. Scotland, Wales and Northern Ireland each run their own list, as the RCGP explains.

What revalidation details should a locum doctor's file hold?

Record the doctor's designated body, responsible officer, last appraisal date and revalidation due date.

Every licensed doctor who practises must revalidate. The GMC explains that doctors have an appraisal every year. Every five years, a responsible officer makes a recommendation on whether they keep their licence. The GMC also asks employers to find out who the doctor's current responsible officer is.

Is your agency a designated body?

It might be. NHS England says locum agencies on the national procurement framework are designated bodies under the responsible officer regulations. They must appoint a responsible officer and meet the statutory duties.

Other locums may be connected to an NHS employer, a deanery, an NHS England region or another body. Doctors can confirm their connection with the GMC connection tool. A doctor with no connection must send the GMC an annual return and sit a revalidation assessment, so flag it early.

Which DBS check does a locum doctor need?

Most locum doctor roles involve regulated activity, so they are usually eligible for an enhanced DBS with both the adult and children's barred lists.

The NHS Employers criminal record checks standard says barred list checks are only available where the role involves regulated activity. Confirm eligibility with the DBS eligibility tool for unusual roles, such as non-clinical medical posts.

How long does a DBS last?

A DBS certificate has no expiry date, but it only reflects what was known when it was issued. For temporary workers not on the Update Service, NHS Employers says contracts should require an annual DBS check as a minimum.

How do you use the Update Service?

With the doctor's consent, run a free status check online. The DBS Update Service employer guide says you must see the original certificate, as copies or viewing over video are not enough. The certificate must also be the right level and workforce for the role. Our guide to DBS checks for agency workers covers levels and portability.

What occupational health evidence does a locum need?

You need written confirmation that the doctor is fit for the role, plus the immunisation evidence the role requires.

The NHS Employers work health assessments standard says clients should tell agencies which clearances each post needs. Clients should get written confirmation that an assessment was done and the worker is fit to start. For framework workers, a SEQOHS-accredited occupational health provider may carry out the assessment.

Which immunisations and clearances?

NHS trusts screen their own staff against the NHS England screening and vaccinations framework. Clients often ask locums to match it:

• Hepatitis B, with serology, for anyone in contact with blood or body fluids
• MMR: two doses or positive measles and rubella antibodies
• Varicella: a definite history or serology
• TB screening or a documented recent test
• EPP clearance for doctors doing exposure-prone procedures

EPP blood results must come from identified and validated samples tested by a UK-accredited lab. A results printout the doctor emails you is not enough.

How long does it last?

NHS Employers says a new assessment is only needed if the nature of the work or the working environment changes significantly. Some clients set their own review dates, so check the contract.

What indemnity does a locum doctor need?

A locum doctor must have adequate and appropriate cover for their whole scope of UK practice.

The GMC can remove a licence if a doctor does not have adequate cover. NHS indemnity covers clinical negligence claims against the NHS body for hospital work. It does not cover private work, inquests or regulatory proceedings.

For GP locums in England, the Clinical Negligence Scheme for General Practice has covered NHS GP work since 1 April 2019. It does not cover regulatory matters. Ask for a current certificate from the doctor's medical defence organisation or insurer and note the renewal date.

How many references and how much history do you need?

You need a full employment history with gaps explained, and references that cover recent clinical work.

The NHS Employers reference standard asks employers to validate three consecutive years of employment or training. For agency workers, it allows a proportionate approach and suggests a reference from the agency itself. References must be in writing, with the referee's name, job title and a main landline number.

Your framework or client may set a minimum number of clinical references and how recent they must be. Check the contract rather than guessing.

What about right to work and identity?

Check identity and right to work yourself, before the first shift, and keep the evidence.

The GMC says you must make your own identity checks, and a GMC registration certificate is not proof of identity. The GMC can send you the photo it holds if you have doubts. The NHS Employers identity standard applies to agency staff too.

The Home Office guide, updated on 1 October 2026, treats the agency supplying temporary workers as their employer for the right to work check. For a manual check over a live video call, you must already have the original document in your possession. A scan or screenshot is not enough. See the Home Office employer's guide and our guide to UK right to work checks.

Which training and life support certificates are required?

Clients expect statutory and mandatory training mapped to the Core Skills Training Framework, plus a life support certificate at the right level.

The Core Skills Training Framework from Skills for Health covers 11 subjects in England. They include fire safety, infection prevention, information governance, resuscitation and safeguarding. The refresher interval is set by the client's training policy.

Life support level depends on the post. Acute specialties often ask for ALS, while others accept BLS or ILS. A Resuscitation Council UK ALS certificate is valid for four years. Check the course provider and expiry date, not just the course name.

Locum doctor compliance documents checklist

Use this table as your printable file check before each booking.

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Frequently asked questions

Can an agency rely on a client to check GMC registration?

No. Both the agency and the client should check the online GMC register before each booking. The GMC tells employers not to rely on a locum agency to check status for them. The same logic applies the other way round.

Does a locum consultant need to be on the Specialist Register?

The Specialist Register is a legal requirement for substantive, fixed term and honorary NHS consultant posts, except in foundation trusts. Many clients also expect it for locum consultant work. Check the doctor's register entry for the specialty and confirm the client's requirement before you book.

How often should a locum doctor's DBS be renewed?

A DBS certificate has no expiry date. NHS Employers says contracts for temporary workers not on the Update Service should require an annual DBS check as a minimum. Doctors on the Update Service can be status checked online with their consent.

Who is a locum doctor's responsible officer?

It depends on the doctor's connection. Locum agencies on the national framework are designated bodies with their own responsible officer, while other locums connect to an employer or other body. Doctors can confirm theirs with the GMC connection tool.

Do GP locums need their own indemnity?

NHS GP work in England has been covered by the Clinical Negligence Scheme for General Practice since April 2019. It does not cover regulatory matters or private work, so most GP locums also hold medical defence membership. Keep a current certificate on file.

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Please note: this article is general information, not legal advice, and was correct at the time of writing (October 2026). Rules and guidance change, so please check the latest guidance from the General Medical Council, NHS Employers and NHS England before relying on it.