This statement by DiU is in response to the Government consultation on how the General Medical Council (GMC) regulates medical practitioners, physician associates and anaesthesia associates across the UK.
PART 1.
Co-ordinating author: Dr Brian Gibbons
COMMENCEMENT.
Doctors in Unite believe that in recent years the General Medical Council (GMC) has lost the trust and respect of a significant body of the medical profession and the wider public. This is evidenced by the views not only expressed by our members but by also other bodies such as the BMA and the Royal Colleges. Therefore there needs to be a wider debate on the role and function of the professional regulation in general and the GMC in particular.
We are concerned that the this General Medical Council Order will be seen as a definitive, reforming piece of legislation which will not need to be revisited for some time. However most of the Order’s provisions will not be enough to restore trust and confidence.
Until a wider debate takes place on the role, purpose and performance of the GMC and the Medical Act (1983), this Order should be put on hold.
Many of the proposals of this Order derive from the Williams Review, the Leng Review and the Mann Review. We have many reservations about these reviews and in particular the Leng Review and what we know of the Mann Review.
GOVERNANCE / PSA EVIDENCE GATHERING.
There should always be separate regulatory agencies for health professionals whose decision-making framework is focussed on established protocols of care and those whose decision-making framework treats protocols of care as guidelines to which they may seek to identify exemptions. The latter group includes doctors, dentists, and public health specialists, whilst the majority of healthcare professionals, including physician assistants and anaesthesia assistants, are in the former group. Both groups are essential to good healthcare but they need to work together rather than act as rivals or substitutes..For this reason, amongst others, we believe the GMC should cease to be the regulator for physician assistants and anaesthesia assistants, and we would be opposed to including the GMC in any wholescale merger of regulators.
The GMC has a poor record on promoting equality, diversity and inclusion. Indeed for too long it refused to acknowledge these deficiencies and has had to be dragged into making any significant change.
We regard the crucial role and feeble practice of the Privy Council plays in the affairs of the GMC as antiquated and anachronistic. This particular tier of governance is totally outdated in the 21st Century. The requirements that key reports from the GMC need to be funnelled through the Privy Council to the main democratically elected bodies in the UK is hard to understand and justify.
The devolved administrations have a number of important roles to play in the overall governance framework with the exception of Wales. There is no justification for this exceptionalism in the present era of Welsh devolution. In this context the absence of an explicit opportunity of the Welsh Senedd Health Committee to hold hearings with GMC, compared to UK and Scottish Parliaments, is not acceptable.
We agree that there is a role for an over-arching body such as the Professional Standards Authority (PSA) which is independent of government. In this role, the PSA should require the GMC to share relevant information. However the PSA’s own performance and accountability may also merit more attention and review.
We agree that that the GMC should function on a not-for-profit basis with due regard for the need for reserves. With fixed and free reserves equivalent to almost half of annual income, there is a case to assess fee and / or reserves levels.
We believe that the board of the GMC should be independent of government. It must reflect both professional, patient and wider general public perceptions and interests. We have major reservations about the means of appointment to the GMC and its lack of democratic accountability and transparency. This needs urgent review. Any future GMC must include democratically appointed professional representatives as well as public / patient representatives appointed by some form of electoral college / citizens’ panel.
EDUCATION AND TRAINING
We note the specific reference to the importance of regulators setting standards for professional knowledge, skills, experience and behaviours needed for safe effective care. However in recent years the GMC has chosen to pursue doctors whose behaviour is unquestionably well within these parameters.
In recent times more doctors are finding themselves facing professional disciplinary proceedings arising from acts of dissent and civil disobedience. In too many of these instances the professional competence and moral integrity of the doctors are not in question but they still find that they are falling foul of GMC disciplinary proceedings. It is a key warning sign of a slide towards authoritarianism if a state seeks to exclude its opponents from employment. The GMC should be legally prohibited from disciplining any doctor for any politically-motivated offence which does not include an action against patients, or serious violence
We are content that the GMC should continue to oversee medical training and education. It should also be able to approve overseas training provided by British medical schools and only charge for the cost of doing so. This approval process should not be an income generating exercise. We also have no objections to the reciprocal approval of medical training in the listed priority countries.
REGISTRATION / PROTECTION OF TITLE
Doctors in Unite believes that a clear distinction needs to be made between the registration of medical practitioners and the registration of physician assistants / anaesthesia assistants. We agree that the use of the title “assistants” is a step in the right direction but much of the important distinctions that this is meant to convey is undermined by the collective use of the term of “registered medical practitioner” for medical graduates and assistants.
In the light of public debate and concerns about physician & anaesthetic assistants, there is a case to reconsider if the GMC remains the best regulatory body. If they are to continue to be regulated by the GMC then there needs to be separate registers for medical practitioners (medical professionals) and associates who could be described by a title such as “health professional” or something similar.
In view of this, we also believe that the title Medical Practitioners Tribunal Services (MTPS) should be retained for medical practitioners / graduates and a separate tribunal service be established for assistants.
We agree that there may be a need for the register to include other information “necessary for the protection of the public”. However due to recent judgements by the GMC we cannot accept that it should have the ultimate discretion in deciding what information is required for public protection. If such inclusions are needed, a new and separate mechanism needs to be devised. The same consideration apply to any discretion that the GMC may have in making provision for requirements for inclusion on the medical register outside the well accepted parameters of knowledge, skills, understanding professional ethics and an ability to speak English.
While we acknowledge that terms such as “apothecary” as well as “licentiate in medicine & surgery” are antiquated, we would not support the removal of their title protection. To do so would create an unnecessary risk of the abuse and exploitation of vulnerable members of the public by a modern generation of charlatans and “snake oil merchants” through the unscrupulous use of such titles.
We note the proposals to include specific rules to deal with patient safety due to a registrant’s poor physical or mental health. However in doing so, we are aware of the importance of cultural variations and diversity. The GMC has not always been as alert and sensitive to these matters in the past and DiU feel that is an area that needs regular monitoring of GMC performance.
An additional concern is the consultation document’s uncritical acceptance of the formulation “antisemitism and other forms of racism”. This phrase is used up to half a dozen times. It creates a hierarchy of racism. Picking out ‘antisemitism’ for special mention as being more important than any other kind is wrong and unnecessary. All forms of racism and sectarianism are abhorrent and wrong.
We strongly believe that it is incorrect to argue that all Jews are responsible for the actions of the state of Israel or that criticism of the state of Israel is inherently anti-Semitic. Doctors in Unite’s predecessor union, the Medical Practitioners Union, had a long and honourable record in opposing anti-Semitism and fascism dating back to Cabel Street and the Spanish Civil War. We are proud to continue in that tradition. There can be no hierarchy in race hatred when one in five black and ethnic minority staff in the NHS report abuse, bullying or harassment compared to 1 in 20 white colleagues. Our profession must stand resolute and united on this key principle.
My response From reading of the draft order, this refers to
The regulated professional’s fitness to practise is impaired in accordance with—
(a) article 48 (impairment of fitness to practise due to criminal conviction), or
(b) article 49 (impairment of fitness to practise due to standard of care, misconduct or health)
where a registration measure under article 53(1)(c) (removal of registration) is imposed.
We have grave concerns about what is covered by ‘criminal conviction’ for example doctors exercising their right to protect patients from the climate catastrophe which is already destroying lives, livelihoods and the environment world wide. Also for convictions related to doctors trying to promote peace, end militarism and stop genocide. These ‘criminal convictions’ are highly politicised and resulting from the government’s criminalization of protest. They gave nob wearing on a doctor’s ability to practice.
We note the proposals to include specific rules to deal with patient safety due to a registrant’s poor physical or mental health. However in doing so, we are aware of the importance of cultural variations and diversity. The GMC has not always been as alert and sensitive to these matters in the past and DiU feel that is an area that needs regular monitoring of GMC performance.
With respect to politicisation of protest and trying to protect public health and patients, in the UK and abroad, an additional concern is the consultation document’s uncritical acceptance of the formulation “antisemitism and other forms of racism”. This phrase is used up to half a dozen times. It creates a hierarchy of racism and risks leading to sanction of doctors and health care workers for trying to protest about the bombing and genocide in Gaza, the West Bank and Lebanon. Picking out ‘antisemitism’ for special mention as being more important than any other kind is wrong and unnecessary. All forms of racism and sectarianism are abhorrent and wrong.
We strongly believe that it is incorrect to argue that all Jews are responsible for the actions of the state of Israel or that criticism of the state of Israel is inherently anti-Semitic. Doctors in Unite’s predecessor union, the Medical Practitioners Union, had a long and honourable record in opposing anti-Semitism and fascism dating back to Cable Street and the Spanish Civil War. We are proud to continue in that tradition. There can be no hierarchy in race hatred when one in five black and ethnic minority staff in the NHS report abuse, bullying or harassment compared to 1 in 20 white colleagues. Our profession must stand resolute and united on this key principle. Doctors must not be victimised for standing against racism in all its manifestations.
RULE MAKING POWERS & APPEALS
While it makes sense for the GMC to have its own rule making powers over much of its activities, Doctors in Unite believe that there is a need to be much more cautious making a universal provision for such flexibility. The GMC’s performance in a number of areas requires much improvement and this hardly seems to be the time to provide it with scope for extended or more flexible powers.
Rather than making a general blanket provision, DiU believes that a separate case must be made for each request for greater flexibility or extended powers in the main areas of the GMC’s activities and areas of responsibility. Each of these applications can be judged on their individual merit possibly in conjunction with the PSA or some other independent body.
In this context we are particularly concerned at the way the GMC has used its powers of appeal to circumvent and double guess a number of recent MTPS decisions. We are aware that the Williams Review recommended that this power should be removed from the GMC but that the government has chosen to take heed of the Mann Rapid Review. There needs to be a greater range of checks and balances in how the GMC uses its appeal powers. For now we feel that the present government should uphold the decision of its predecessor in this area and follow the Williams Review recommendation.
PART 2.
Co-ordinating author: Dr Jonathan Fluxman
The consultation is about reforming the GMC legislative framework, but it also mentions the NMC. GMC regulations usually set the standards and framework for all healthcare professional regulators. Our comments should therefore be seen as applying to the regulation of all healthcare professionals.
It should be noted that the GMC’s standing among Britain’s doctors has deteriorated sharply over the last several years to the point that the GMC today has lost the confidence of the majority of doctors. The BMA (which represents two-thirds of doctors) passed policy at its annual representative meeting in 2025 which stated the GMC “is no longer fit for purpose and does not represent the interests of the public or the medical profession”. It called for “the resignation of the GMC’s chief executive and a performance review of the current senior management team.”
The BMA issued an initial statement on 24 March 2026 in response to the consultation, titled “GMC changes are ‘far cry from what’s needed to fix broken regulator’”. We endorse the BMA’s statement. While welcoming two minor proposed changes, in general the BMA statement is sharply critical of the proposed reforms, stating “Rather than restoring the medical profession’s confidence in the GMC, or protecting the safety of the public, both will be further eroded.” The BMA intends to respond more fully in its formal reponse to the consultation.
The current consultation directly contradicts the recommendation of the 2018 Williams review that the GMC should lose its statutory right to appeal decisions made by the Medical Practitioners Tribunal Service (MPTS), as this contributed to doctors’ mistrust of the regulator, created a perception of unfair “second-guessing” of independent tribunal decisions and risked discouraging openness and learning from errors.
The consultation says nothing about political interference during ongoing GMC/MPTS fitness to practise proceedings. Last September lawyers for a doctor in a high-profile case before the GMC wrote to the then Health Secretary, Wes Streeting, following public comments he made which risked undermining the independence of the case, and warned that such intervention could breach the Ministerial Code, the Rule of Law and expectations of non-interference in regulatory hearings.
The section of the consultation “Lord Mann Review of antisemitism and other forms of racism in healthcare” is highly problematic. The review was commissioned by Streeting and the DHSC last October under a plan also titled, “Government to tackle antisemitism and other racism in the NHS”. Why is antisemitism separated out from other forms of racism, is it not a form of racism? The phrase is repeated 6 times in the current consultation document, underlining the exceptionalising of antisemitism from all other forms of racism. This is consistent with Mann’s stated views on racism against different communities, i.e. that “antisemitism is the worst of racisms”.
Health professionals from other racialised groups have voiced strong objections to the consultation which prioritises antisemitism above their own lived experience of racism. BIMA (the British Islamic Medical Association) said in a statement they have serious concerns that Islamophobia does not seem to be addressed despite significant and rising levels and that the proposals could censor legitimate political opinions and be abused by lobby groups to shield human rights violations of some foreign states. They say they are particularly concerned about the expansion of regulatory powers in relation to appeals, interim measures, and the retrospective consideration of allegations.
Similarly Muslim Psychiatrists UK issued a statement which said the proposals “risk creating a two-tier regulatory system, with Islamophobia conspicuously absent from the agenda.” They share concerns about the GMC retaining the right to appeal MPTS decisions to the High Court where it does not agree with them and to be able to immediately suspend a doctor at the outset of an investigation.
The recommendation that a doctor can be immediately suspended by the GMC without being asked or able to make any representations to the GMC (Article 57 of the draft order) is very worrying. This means the GMC will be able to ‘fast-track’ suspension of any doctor before any independent oversight by the MPTS. Given the weaponisation of antisemitism by groups such as UK Lawyers for Israel and the Campaign Against Antisemitism, it is likely that pro-Palestinian medical staff expressing political opinions hostile to Israel or Zionism will continue to have complaints made about them and will find themselves summarily suspended.
It is therefore essential that the review takes into account the phenomenon of the weaponisation of antisemitism, i.e. the tactic of false accusations of anti-Jewish hatred against critics of Israel, the Israeli Defence Force, Zionism etc, in order to silence, censor, or delegitimise them. Such accusations often form the basis of vexatious complaints to employers and the medical regulator. A number of public figures, both Jews and non-Jews have commented on this. Kenneth Stern said “I drafted the (IHRA) definition of antisemitism. Rightwing Jews are weaponizing it … it is being used as a blunt instrument to label anyone an antisemite.” Francesca Albanese (UN Special Rapporteur) stated at a conference in Colombia: “The weaponization of antisemitism applied to Palestinian words and narratives…. has led to a global political paralysis, that has been intentional and this must be redressed“. Edward Said, the Palestinian writer, in his landmark 1979 book The Question of Palestine, critiqued the routine conflation of anti-Zionism with antisemitism, observing that this dynamic functioned to suppress criticism of Israel. Noam Chomsky noted in 2002 that conflating anti-Zionism with antisemitism “is a convenient stand that cuts off a mere 100 percent of critical comment”.
Israeli Minister of Education and Knesset Member Shulamit Aloni, remarked in a 2002 radio interview, “Well, it’s a trick, we always use it. When from Europe somebody is criticizing Israel, then we bring up the Holocaust. When in this country [the United States] people are criticizing Israel, then they are antisemitic…… it’s very easy to blame people who are criticizing certain acts of the Israeli government as antisemitic, and to bring up the Holocaust, and the suffering of the Jewish people, and that ‘justifies’ everything we do to the Palestinians.”
The journalistRachel Shabi referring to the Israeli government’s accusation that the International Criminal Court was antisemitic for indicting Benjamin Netenyahu and Yoav Gallant, noted that “The term ‘antisemitism’ is being weaponised and stripped of meaning – and that’s incredibly dangerous”. Dangerous because as Israel and those who defend it seek to obscure or justify its actions with false accusations of antisemitism, real antisemitism becomes increasingly likely to be regarded as suspect and disbelieved. This is dangerous for Jews and and the fight against all forms of racism in society. The right balance must be found – the GMC must scrutinise all accusations of antisemitism carefully and act only when it is clear that there is substance to such allegations.
There is a complete failure by Lord Mann in the consultation document to acknowledge or address where most racism occurs in the NHS. The recent NHS staff survey found that one in five Black and minority ethnic staff reported abuse, bullying or harassment from patients or the public, compared with one in 20 white staff, and one in seven Black and minority ethnic staff say they have faced similar behaviour from colleagues, managers or team leaders, which is double the rate reported by their white colleagues. The same pattern exists for patients – Black and minority ethnic patients experience significantly poorer health outcomes, greater lack of trust and negative experiences accessing primary care and more coercive and less therapeutic care especially in mental health services.
The RCN reported in October 2025 a steep increase in racist abuse faced by nurses from global south communities. The report states, “Analysis of calls to the RCN shows a surge in complaints about racism at work. The data reveals an increase of 55% in three years, with the RCN advice line receiving three calls a day from global majority nursing staff from across the UK…… The real figures are likely much higher, with most racial abuse and discrimination going unreported.”
RCN General Secretary Professor Nicola Ranger said: “These racist incidents are absolutely disgusting, and it is a mark of shame that they are rising like this across health and care services. Every single global majority nursing professional deserves to go to work without fear of being abused and employers have a legal duty to ensure workplaces are safe. These findings must re-focus minds in the fight against racism.”Tackling racism in the NHS is vital, but it must be done in ways that recognise all forms of racism are harmful, without exceptionalising one form of racism. Health service regulators need to adopt a similar approach without exceptionalising and prioritising antisemitism.
Doctors in Unite 