Osteopaths
GOsC fitness to practise: defence for osteopaths
The General Osteopathic Council works under the Osteopaths Act 1993. That Act uses different language from the other healthcare regulators. Its terms include unacceptable professional conduct, professional incompetence, admonishment, and interim suspension orders with no fixed period. This page sets out each stage from the Act and the GOsC's own guidance. It also covers what to do on day one and how we act for you on fixed fees.
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Day one
When the GOsC letter arrives
Do
- Note every date. Section 20 of the Act gives you 28 days to make written observations. Time runs from the date the notice of the allegation goes out.
- Tell your indemnity provider or professional body straight away.
- Keep the case notes, consent records and correspondence as they are, and take copies.
- Write a private note of what you remember while it is fresh.
- Speak to us before you reply or agree to any undertaking.
Do not
- Reply to the GOsC straight away to explain yourself.
- Contact the patient or the person who raised the concern.
- Change or add to records after the event.
- Discuss the case with colleagues who may become witnesses.
- Post about it online, even in a closed group.
The stages
How a GOsC case runs, in the GOsC's own terms
Screening
Section 20(1) of the Act lists four grounds of allegation. They are unacceptable professional conduct, professional incompetence and a conviction in the UK for a criminal offence. The fourth is a physical or mental condition that seriously impairs your ability to practise. A screener, an osteopath appointed by the GOsC, first considers whether the GOsC can investigate, using its threshold criteria guidance. The GOsC says a screener cannot close a concern without consulting a lay member of the Investigating Committee. Its Initial Closure Procedure is the exception.
Notice and your observations
Section 20(9) requires the Investigating Committee to notify you of the allegation. It must invite your observations within 28 days of the date the notice goes out, and it must take reasonable steps to obtain as much information as possible. The GOsC says it aims to put the case before the Investigating Committee within 26 weeks of receiving the concern.
The Investigating Committee
The committee meets in private. In the words of section 20(9), it decides whether in its opinion there is a case to answer. Its decision making guidance of April 2025 sets the test for closing a case. The committee should close it where there is no realistic prospect of proving the allegations, or of establishing the statutory ground. Where it finds a case to answer, it refers the allegation to the Professional Conduct Committee. A health allegation goes to the Health Committee instead. Its other options are to adjourn for further enquiries or to find no case to answer, with or without advice. The GOsC reports that it closes 41 per cent of the cases it considers.
Interim suspension orders
The Investigating Committee may order your suspension while it investigates. It may do so only where it is satisfied that this is necessary to protect members of the public. Section 21 and the GOsC's guidance of November 2023 set the limits. The order must specify a period of no more than two months, and the committee may make only one such order on an allegation. Under section 24, the Professional Conduct Committee or Health Committee may suspend you on the same test. It may do this before it decides the allegation, or after a decision to impose conditions, suspension or removal. An order made before the decision lasts until the committee decides the case, and the Act gives no fixed period and no review. You may appeal an order of the Professional Conduct Committee or Health Committee to the High Court. Any appeal must come within 28 days of the date of the order, and the court's decision is final.
The Professional Conduct Committee
Hearings are usually public, and witnesses give evidence on oath. The GOsC's Hearings and Sanctions Guidance of May 2025 describes three stages. First come the findings of fact, where the GOsC bears the burden on the balance of probabilities. Next comes the finding on the allegation, and sanction is the third. Where you admit the facts and an admonishment would be the proportionate outcome, Rule 8 offers another route. With your agreement, the committee can conclude the case without a hearing.
If the committee finds the allegation well founded, section 22 requires one of four sanctions. One is admonishment. Another is a conditions of practice order specifying a period, a test of competence or both. The remaining two are suspension and removal from the register. A conditions of practice order or suspension order may not exceed three years. The Health Committee may impose conditions or suspend. Any conditions or suspension must be the minimum the committee considers necessary to protect the public.
Appeal
Section 31 gives 28 days to appeal to the High Court in England and Wales. The period begins with the date of service on you of notification of the decision. Until that period ends or the court decides any appeal, the decision has no effect. The Professional Standards Authority may also appeal a decision it considers insufficient to protect the public. Appeals run through a regulated law firm we work with, and we stay involved.
How we help
What you can expect from Eloquia
Saqib Khan leads your case from the first letter. A specialist barrister works alongside him from the outset, rather than appearing only once the tribunal lists a hearing. We put the most effort in early, because the stage you can still influence is the one that repays preparation. We set a clear account of the events against the records and add evidence of what you have done since. That gives the decision maker a reason to close the case or to choose the least restrictive outcome.
Before each stage starts, we confirm in writing what it covers and what it costs. You then decide whether to go ahead, and you deal with the same people throughout. Where a hearing follows, we prepare the evidence, the witness statements and any expert report. We also prepare you to give evidence, and we present your case.
You may also face a police investigation, an inquest or a disciplinary process at work. If so, we run every track as one strategy, so that nothing said in one forum harms you in another.
Fees
The same fixed fee approach as for doctors
We quote a fixed fee for each stage before it starts, in the same way as we do for doctors, and we state every fee plus VAT. You pay stage by stage, so you never pay in advance for a hearing that may not happen. We do not act on conditional fee agreements. Our fee menu for GMC cases shows how we price the stages of a doctor's case. We price the stages of your case on the same basis. If your indemnity provider, union or defence organisation has declined to help, read our page on cover refused or limited.
We state every fee plus VAT, and each includes a specialist barrister. We involve the barrister from the outset to give you additional support and advice. Fees do not include additional expenses such as expert fees, which we quote separately.
Read at source
The rules and guidance this page draws on
Sources
- Osteopaths Act 1993, section 20 (allegations and the Investigating Committee)
- Section 22 of the Osteopaths Act 1993 (Professional Conduct Committee)
- Osteopaths Act 1993, section 24 (interim suspension orders)
- Section 31 of the Osteopaths Act 1993 (appeals)
- Investigation stages explained (GOsC)
- Investigating Committee Decision-Making Guidance, April 2025 (GOsC)
- Hearings and Sanctions Guidance, May 2025 (GOsC)
- Guidance for Fitness to Practise Committees on imposing Interim Suspension Orders, November 2023 (GOsC)
- Appeals (GOsC)
Questions and answers
Questions osteopaths ask
How long do I have to respond to a GOsC allegation?
Section 20(9) of the Osteopaths Act 1993 gives you 28 days to make written observations to the Investigating Committee. Time runs from the date the notice of the allegation goes out. The committee considers your observations with the information the GOsC has gathered, and the GOsC aims to put the case before the committee within 26 weeks of receiving the concern.
What does the GOsC Investigating Committee decide?
Whether, in its opinion, there is a case to answer. Under its April 2025 guidance, it should close the case where there is no realistic prospect of proving the allegations. The same applies where there is no realistic prospect of establishing the statutory ground. It can refer the allegation to the Professional Conduct Committee or the Health Committee. Its other options are to adjourn for further enquiries, close the case, or close it with advice.
Can the GOsC suspend me while it investigates?
Yes, but only where the committee is satisfied that suspension is necessary to protect members of the public. An interim suspension order made by the Investigating Committee may not exceed two months, and the committee may make only one on an allegation. An order made by the Professional Conduct Committee or Health Committee before its decision lasts until it decides the case. The Act provides for no review. You can appeal such an order to the High Court within 28 days of the date of the order.
What sanctions can the Professional Conduct Committee impose?
If it finds the allegation well founded, it must choose one of four sanctions. It can admonish you, impose a conditions of practice order, suspend your registration or remove your name from the register. A conditions of practice order or suspension order may not exceed three years. Any conditions order must specify a period, a test of competence or both, and any restriction must be the minimum necessary to protect the public.
How long do I have to appeal a GOsC decision?
28 days under section 31 of the Osteopaths Act 1993, beginning with the date of service of notification of the decision. The appeal goes to the High Court in England and Wales. Until the period ends or the court decides the appeal, the decision has no effect.
Does Eloquia act for osteopaths on fixed fees?
Yes. We quote a fixed fee for each stage before it starts, stated plus VAT. Each fee includes a specialist barrister from the outset, and we quote expert fees separately. Our fees and funding page explains how staged payment works.
More answers sit on our questions and answers page, and our glossary explains the terms regulators use.
Read more
Guides on this subject
The GMC process
Insight and remediation: what tribunals look for and how to evidence it
How the GMC and the MPTS define insight and remediation, and how to build evidence of both from the start.
Police and criminal
Allegations of a sexual nature by patients
How a patient's allegation of sexual misconduct runs on parallel police and GMC tracks. Why your records decide more of these cases than you expect.
Police and criminal
Criminal convictions and cautions: what you must tell the GMC
The cautions and convictions you must tell the GMC about without delay, and how the GMC then treats them.
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