The General Medical Council began regulating physician associates and anaesthesia associates on 13 December 2024. At the time the GMC estimated that there were around 5,000 physician associates and 200 anaesthesia associates in the UK. Their regulation rests on a separate statutory instrument, the Anaesthesia Associates and Physician Associates Order 2024. It does not rest on the Medical Act 1983 that governs doctors. So the same regulator applies different fitness to practise rules to a physician associate. Anyone who works in these roles, or supervises someone who does, should know where they differ.

The end of transition on 13 December 2026

The Order gave a two-year transition period. On 14 August 2026, the GMC published its end of transition page. It states that from 13 December 2026 it will be a criminal offence to use the titles physician associate and anaesthesia associate without GMC registration. The provision behind that statement is article 19(1)(b) of the Order, which comes into force on that date. It makes it an offence to use either title without registration with intent to deceive.

The GMC's page adds a further point. Anyone not registered by that date must stop working in those roles until the GMC grants registration. It asked people to apply by 14 September 2026, the date it says gives it enough time to decide. So the GMC may not decide an application made after it before 13 December. On 13 December 2026, too, it will withdraw its transitional policies on acceptable evidence of knowledge and skills. The GMC warns that this may mean more steps, more time and more cost for later applicants.

If you have not applied, apply now and keep evidence of the date you submitted. If the GMC has asked you for more evidence or an identity check, send it promptly. That matters because a delay on your side delays the decision.

Two grounds of impairment, not six

For doctors, section 35C of the Medical Act 1983 lists the grounds on which fitness to practise may be impaired. They are misconduct, deficient professional performance, a conviction or caution, adverse health, lack of the necessary knowledge of English, and a determination by another regulator. Article 2 of the Order defines impairment for associates by reason of two matters only. These are inability to provide care to a sufficient standard, or misconduct. The Order does not list health, convictions or knowledge of English as separate grounds. So for an associate, the framing of a concern under those two headings matters from the start.

Case examiners can impose sanctions

The most important practical difference lies in article 10. After an initial assessment the GMC may refer a concern to a case examiner. The case examiner can decide there is no impairment of your fitness to practise. The examiner can then close the case or issue a warning. Or the case examiner can make a finding of impairment. The examiner can then refer the case to a panel. Alternatively, the examiner can impose what the Order calls a Final Measure: conditions, suspension or removal from the register.

A case examiner may only impose a Final Measure in one of two situations. The first is where you agree to it. In agreeing, you accept impairment of your fitness to practise and the case examiner's findings. The second is where the GMC has told you that it proposes a Final Measure and has asked for a reasoned response. It applies if you have not sent one within the period its rules prescribe. That second route means that silence can lead to a sanction without a hearing. If you receive a notice of a proposed Final Measure, treat its deadline as fixed. Send a reasoned response, even if you need to ask for more time to add to it.

Agreeing to a Final Measure can end a case quickly, which some associates will want. It also means accepting impairment and the findings on your record. Take advice on the findings before you agree. Check, too, what the GMC will publish.

Interim measures and appeals

While the GMC investigates a case, a panel can impose an interim measure of conditions or suspension. The measure can last for up to 18 months. The GMC can ask the court to extend it by up to 12 months at a time. For doctors, the equivalent step comes before an interim orders tribunal. The GMC must review an interim measure within six months and then at six-monthly intervals.

Under article 16, you can appeal to a panel against a case examiner's decision to impose a Final Measure. But you must seek permission from the GMC within 28 days of notice of the decision. Appeals against panel decisions go to the court under article 17. Diary the 28 days on the day the decision arrives.

The Leng review and the job titles

In July 2025 the Department of Health and Social Care published the Leng review. Its first recommendation was to rename the physician associate role physician assistant. It also recommended that anaesthesia associates become physician assistants in anaesthesia. The GMC's August 2026 guidance still uses physician associate and anaesthesia associate. Those are the titles the Order protects from 13 December 2026. Check the GMC's current position on titles before you change how you introduce yourself to patients.

Cover

An application for registration must include evidence of an indemnity arrangement or insurance giving appropriate and adequate cover for your practice. The evidence must show that you have that cover, or will have it when you start practising. NHS Resolution confirms the position in general practice in England. There the state scheme covers associates for clinical negligence claims arising from NHS primary medical services. But it does not cover professional regulatory matters. Now that the GMC regulates you, you need separate arrangements for advice and representation before the GMC.

Eloquia acts for physician associates and anaesthesia associates in GMC fitness to practise cases under the 2024 Order, on fixed fees by stage, each stated plus VAT. The fee includes a specialist barrister from the outset, and our fees and funding page sets out each stage.

Sources

  1. GMC: GMC regulation of physician associates and anaesthesia associates to begin (12 December 2024)
  2. GMC: End of transition for physician associates and anaesthesia associates (14 August 2026)
  3. The Anaesthesia Associates and Physician Associates Order 2024 (SI 2024/374)
  4. The Anaesthesia Associates and Physician Associates Order 2024, article 10
  5. Medical Act 1983, section 35C
  6. The Leng review: an independent review into physician associate and anaesthesia associate professions (July 2025)
  7. NHS Resolution: Clinical Negligence Scheme for General Practice
  8. The Anaesthesia Associates and Physician Associates Order 2024, articles 1 and 19 (commencement and offences)