NHS Framework Agency Compliance: The Nursing Agency Document Checklist

A trust bank office emails at 7pm: they need two band 5 nurses for a night shift on a medical ward, starting tomorrow. You have two nurses available. One has a complete file. The other is missing an in-date occupational health clearance and her mandatory training certificate for manual handling expired last week. Under your framework terms, only one of them can go.

NHS framework agency compliance is the rulebook every nursing and locum agency supplying the NHS lives by. Being on an approved framework gives you access to trusts, but it also commits you to a defined set of checks on every worker you supply, and to proving those checks during audits. Missing documents do not just delay a placement; repeated gaps can put your framework status at risk.

This is part 1 of our UK Agency Compliance Checklists series. Below we set out the core documents for nursing agency compliance, how the NMC PIN check and Enhanced DBS fit in, what locum agency compliance looks like for other clinical roles, and how to keep files audit-ready without chasing nurses by hand every evening.

What NHS framework agency compliance means in practice

NHS trusts in England generally procure agency staff through approved frameworks, such as those run by NHS procurement bodies and partners. To get onto a framework, an agency is assessed against its requirements, and once listed, it is expected to meet them for every worker it supplies.

The NHS Employment Check Standards

Most framework requirements are built on the NHS Employment Check Standards, published by NHS Employers. They cover six areas:

• Identity checks
• Right to Work checks
• Professional registration and qualification checks
• Employment history and reference checks
• Criminal record checks (DBS)
• Work health assessments (occupational health)

Frameworks then add their own expectations, such as mandatory training aligned with the Core Skills Training Framework, and audit arrangements. Requirements are updated from time to time, so always check the current NHS Employers guidance and your framework's own documentation rather than relying on an old checklist.

Why audits matter

Framework providers audit agencies to confirm that checks have been done and recorded. An auditor will typically sample worker files and look for complete, in-date evidence for each standard. If your files are inconsistent, with some workers' documents in the ATS, some in email and some in a shared drive, the audit becomes painful even if the checks were actually done.

The nursing agency compliance checklist

Use the table below as a starting point. Adapt it to your framework, the trust's local requirements and the role.

The NMC PIN check

Every registered nurse and midwife you supply must hold a current registration with the Nursing and Midwifery Council (NMC). The check is done on the NMC's online register using the nurse's PIN. Record the date you checked, the registration status, the expiry or revalidation date, and any conditions of practice or interim orders. A copy of a PIN card the nurse sends you is not a substitute for checking the register.

Enhanced DBS and the Update Service

Nursing roles in regulated activity generally require an Enhanced DBS check with the relevant barred list check. If the nurse subscribes to the DBS Update Service, you can carry out a status check online with their consent, which saves time for workers who move between agencies. You still need the original certificate details and a record of each status check.

Locum agency compliance: beyond nursing

Many agencies supply more than nurses. Locum agency compliance for doctors, allied health professionals and healthcare support workers follows the same Employment Check Standards but with different registration checks:

• Doctors: GMC registration and licence to practise, plus any specialist register entries, and evidence of appraisal and revalidation arrangements.
• Allied health professionals: HCPC registration for roles such as physiotherapists, radiographers and paramedics.
• Healthcare support workers: no professional register, so references, training and the Care Certificate (or equivalent) carry more weight.

The shared problem is the same. Each worker has a long list of items, several of which expire, and many of which sit with the worker rather than with you.

Keeping files audit-ready without chasing every evening

Most compliance teams in nursing agencies know exactly what a complete file looks like. The challenge is getting it, keeping it current, and proving it.

Where the hours go

Imagine an agency supplying 150 active nurses across several trusts. Each nurse has a dozen or more training certificates with their own expiry dates, an occupational health record, a DBS and a registration that needs rechecking. Even a modest rate of expiries means a steady stream of renewals to chase every week, on top of new starters.

Build renewal into the process

• Track every expiry date, not just the DBS and registration.
• Start renewals early, well before an item lapses, so a nurse is not stood down from a booked shift.
• Use one place for evidence: the candidate record in your ATS, not inboxes and personal drives.
• Separate collection from judgement. Compliance officers should be reviewing complete files, not chasing missing ones.

How GettingDocs helps

Amy, the GettingDocs AI assistant, handles the chasing. Amy contacts nurses on WhatsApp and on email sent from your agency's own domain, written in your voice. Each document is checked to confirm it is readable and the right document; blurred photos, cut-off pages and wrong documents are rejected and chased again. Every file is scanned for malware, and password-protected or empty files are refused. Accepted documents are filed onto the nurse's record in your ATS, with live integrations for Recruit CRM, Crelate, Zoho Recruit and JobAdder, and rejected documents are never filed. Candidates are matched to records by record ID, email or phone, never by name.

Your compliance team still carries out the NMC check, reviews references and makes the final decisions. They simply start from a complete file. You can see how this works for clinical agencies on our UK healthcare staffing page, and read about data handling on our security page.

Sharing the file with your client. If your agency uses JobAdder, Crelate or Recruit CRM, GettingDocs can also give your clients a branded Client Portal. Their contacts sign in with a one-time code sent by email, with no password, and see only their own placements and the document types you choose to share, streamed from your ATS.

Key takeaways

• NHS framework agency compliance is built on the NHS Employment Check Standards plus each framework's own requirements, so check the current guidance regularly.
• A complete nursing file covers identity, Right to Work, NMC registration, qualifications, references, Enhanced DBS, occupational health and mandatory training.
• Always check NMC registration on the register itself and record the result, conditions and revalidation date.
• Locum agency compliance follows the same standards with different registers: GMC, HCPC or none.
• Audit readiness comes from consistent files in one place and early renewal of expiring items.

If you would like to see this checklist running for your nurses and locums, book a call and we will show you how Amy collects and files every document on your list.

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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 Disclosure and Barring Service, the Nursing and Midwifery Council and GOV.UK right to work checks guidance before relying on it.