The letter that matters most in a GMC investigation usually arrives near its end. Under rule 7 of the General Medical Council (Fitness to Practise) Rules 2004, the Registrar writes to you. The letter sets out the allegation and the matters that appear to raise a question about your fitness to practise. The Registrar also sends you copies of the documents the GMC holds in support. It invites written representations within 28 days of its date. Rule 7 also requires the letter to tell you that the GMC may disclose your representations to the person who raised the concern for comment. Your Rule 7 response then goes to two case examiners, one medical and one lay, who decide the outcome.

In 2025 case examiners made 679 decisions. They closed 309 cases with no further action, gave advice in 16, issued 110 warnings and agreed undertakings in 60 cases. They also referred 184 to a medical practitioners tribunal. Thirteen of those referrals followed a doctor's refusal to accept undertakings. Your response is the main tool you have to move your case towards the first of those outcomes.

The test the case examiners apply

The GMC's guidance Deciding the outcome of an investigation (Doctors) sets out the realistic prospect test. The case examiners must decide, on relevant and objective evidence, whether there is a realistic prospect of establishing that your fitness to practise is impaired to a degree requiring restrictive action. Restrictive action means undertakings agreed with the GMC, or conditions, suspension or erasure imposed by a tribunal. The prospect must be genuine, not remote or fanciful.

This test has two limbs, and a good response addresses both. The first asks whether the evidence sufficiently supports the concern. A tribunal would apply the civil standard, deciding whether each fact is more likely than not. The second limb asks whether, if the facts were proved, they would show a current and ongoing risk that calls for restrictive action. That risk may be to patients, to public confidence or to professional standards. If the answer to the second question is no, the test is not met, even where you admit the facts. In that event the case examiners can close the case, give advice or issue a warning.

Answering the facts

Case examiners work from documents. The guidance tells them not to try to resolve substantial conflicts of evidence. It also tells them to proceed with caution because the evidence before them may be untested. Contemporaneous documents, it says, can lend support to one version of events. By contrast, witness evidence based on mere assertion or supposition may be weak and bound to fail before a tribunal.

That should shape how you answer. Go through each allegation in turn and say plainly which facts you accept. Where you dispute something, point to the record that supports you: the clinical notes made at the time, the rota, the message log, the audit trail in the electronic record. If an expert report criticises you, check what material the expert had. The guidance warns case examiners to take care with an expert who did not have all the information now available. So tell them precisely what the expert did not see.

You may have raised patient safety concerns locally and believe there is a link with the referral. If so, say so and attach the email or note you sent at the time. That matters because the guidance asks case examiners to look for objective evidence of this.

Answering the risk

This is where most of the work lies. Since 30 May 2025 case examiners have assessed risk by asking three questions. How serious is the concern? What is the impact of any relevant context? And how have you responded, including your insight and remediation? Your response should give them material on each.

Context means the circumstances in which the events happened. Staffing, an unfamiliar system or a health problem at the time are relevant if you can evidence them. Present context as explanation and never as blame, because an attempt to shift responsibility onto colleagues reads as a lack of insight.

Insight and remediation carry most weight when they are specific and objective. The foundation is a reflective statement showing that you understand what went wrong, what it meant for the patient and what you now do differently. Around it, put evidence that someone other than you has checked. Certificates for targeted courses and an audit of your practice since the events both qualify. So do a report from a clinical supervisor and a statement from your responsible officer. The MPTS guidance that tribunals have applied since 24 November 2025 says objective evidence of remediation is likely to carry more weight than self-certification. In addition, the GMC's guidance directs case examiners to consider evidence of insight and remediation when they assess risk.

What to leave out

Leave out anything you cannot support. Do not include criticism of the complainant. Omit character references and career histories that say nothing about the concern or the risk.

New information raised for the first time in your response can lead the case examiners to ask for further enquiries. That can help you, but it adds time.

Deciding what you are arguing for

A warning is not a sanction, but the GMC publishes it on the register for two years in total. It appears for one year on your status page and one on your history page. The GMC also discloses expired warnings to current employers indefinitely. Undertakings are an agreement about your future practice that avoids a hearing. Before you write, decide with your adviser which outcome you are arguing for. Decide too whether you would accept undertakings if the GMC offered them. That matters because a refusal can lead to a tribunal referral, as it did in 13 cases in 2025.

Start the response on the day the letter arrives. Sometimes a record or report you need will not arrive within the 28 days. If so, write to the GMC before the deadline and explain what you are waiting for.

Rule 7 belongs to the GMC's rules alone. The NMC, the GDC, the HCPC and the other regulators invite your response under rules of their own, and our pages for each profession set out each one.

Eloquia prepares Rule 7 responses and the other stages of a GMC case with you. We review the GMC's evidence, instruct our own expert where the case needs one, gather testimonials and evidence of remediation, and draft the response. A specialist barrister works on your case from the outset, and our fixed fee for each stage includes counsel's work. We state every fee plus VAT and quote any expert fees separately.

Sources

  1. The General Medical Council (Fitness to Practise) Rules Order of Council 2004, SI 2004/2608, Schedule (legislation.gov.uk, text as made)
  2. General Medical Council, Concerns about fitness to practise: Annual statistical report 2025 (published 30 July 2026)
  3. General Medical Council, Deciding the outcome of an investigation (Doctors)
  4. General Medical Council, New GMC guidance to ensure greater clarity and consistency in handling of fitness to practise concerns (29 May 2025)
  5. MPTS, Guidance for tribunals: step 2d, how the doctor has responded to the allegations (insight and remediation)
  6. Medical Practitioners Tribunal Service, Guidance for MPTS tribunals (published 30 September 2025, in effect from 24 November 2025)
  7. General Medical Council, Our fitness to practise processes: a guide for doctors (published October 2014, updated January 2025)
  8. General Medical Council, How we investigate concerns: making our decision