CQC Regulation 18: A Guide to Staffing Requirements

CQC Regulation 18 requires providers to have enough suitably qualified, competent, skilled and experienced staff to meet people’s needs safely. Compliance goes beyond maintaining training certificates: you should be able to demonstrate appropriate staffing levels and skill mix, role-specific training, practical competency, supervision, appraisal and ongoing professional development. Your systems should also cover temporary staff, locums and external practitioners where relevant, with clear evidence that staffing and competency requirements are regularly reviewed.

CQC Regulation 18 covers one of the most important parts of running a safe health or social care service: having enough people with the right skills, competence and support to do their jobs properly.

For providers going through a new CQC registration, staffing cannot simply be treated as a rota or recruitment issue. You need to be able to explain how you decide what staffing your service requires, how you check that people are competent for their roles and how you continue to support them once they start work. Registration is also an ongoing obligation rather than something that expires on a fixed renewal date, as we explain in How Often Do You Need to Renew Your CQC Registration?

At DKJ Support Services, we work with GP practices, private clinics and health and social care organisations to make CQC compliance part of normal service management rather than something that is addressed shortly before an assessment. This guide explains what Regulation 18 requires, what evidence you may need and why a folder of training certificates is not enough to demonstrate an effective workforce.

What Is CQC Regulation 18?

Regulation 18 of the Health and Social Care Act 2008 (Regulated Activities) Regulations 2014 deals specifically with staffing.

CQC states that providers must deploy sufficient numbers of suitably qualified, competent, skilled and experienced people to meet the needs of those using the service and the other regulatory requirements applying to the provider. Staff must also receive the support, training, professional development, supervision and appraisal they need to carry out their responsibilities.

There are therefore two closely connected questions for providers:

• Do you have enough staff?
  
• Do those staff have the right skills, competence, training and support?
  

A rota may appear fully staffed on paper but still present a risk if the available team does not have the required clinical skills or level of experience.

Similarly, employing highly qualified people does not resolve a staffing problem if there are not enough of them to meet people’s needs safely.

Why Regulation 18 Is About More Than Staff Numbers

CQC’s guidance says providers should use a systematic approach to determine the numbers and range of staff they require. Staffing levels and skill mix should also be reviewed as people’s needs and circumstances change.

That means you need to think about factors such as:

• the number of patients or service users;
  
• the complexity of their needs;
  
• the regulated activities you provide;
  
• the skills required during each clinic or shift;
  
• supervision requirements;
  
• leadership arrangements;
  
• staff absence and leave;
  
• changes in demand; and
  
• emergency cover.
  

Staffing compliance is therefore not simply a question of filling vacancies. It is about whether the workforce available at a particular time can safely perform the work required.

The CQC “Mandatory Training List” Myth

One misconception we regularly encounter is the belief that there is a universal list of CQC mandatory training courses that every employee must complete.

That is not how Regulation 18 works.

CQC’s own Regulation 18 guidance distinguishes between statutory training, mandatory training defined by the provider for a particular role, and additional learning needed to perform regulated activities safely. Providers are expected to assess people’s learning and development needs when they start employment and review them at appropriate intervals.

This is also why describing a training company as “CQC approved” can be misleading. CQC does not simply provide providers with an approved course catalogue to work through. DKJ’s existing guidance on training providers similarly explains that providers need to select training relevant to their services and workforce.

Training Should Reflect the Risks of Your Service

Start with the job rather than the training catalogue.

Consider:

1. What does this person actually do?
   
2. What knowledge and skills are necessary?
   
3. What could go wrong if those skills are absent?
   
4. What training, supervision or development is required?
   
5. How will you establish that the person is competent?
   
6. When should that competence be reviewed?
   

A receptionist, healthcare assistant and prescribing clinician will not necessarily have identical learning needs.

Likewise, a private surgical clinic, GP practice and domiciliary care provider operate different services with different risks.

Training should be proportionate to those differences.

Training Certificates Do Not Automatically Prove Competence

Certificates are useful evidence that somebody has completed training. But completion of a course and competence to perform a task are not necessarily the same thing.

CQC’s safe and effective staffing quality statement looks at whether people are qualified, skilled and experienced, whether training is appropriate to their role and whether staff receive effective support, supervision and development.

Providers therefore need to consider what happened after the training.

For example, somebody may have completed training on significant events.

The compliance question should not stop at:

“Have they got their certificate?”

Ask:

• What did they learn?
  
• Could they explain the significant-event process?
  
• Have they applied it?
  
• Do they know how to report an event locally?
  
• Has learning from previous events resulted in changes?
  
• Does further development need to take place?
  

We often describe this as the “so what?” cycle.

Training has happened. So what changed?

Evidence of Competence

Depending on the role and activity, evidence could include:

• observed competency assessments;
  
• supervised practice;
  
• practical demonstrations;
  
• case discussions;
  
• peer review;
  
• clinical audit;
  
• prescribing audits;
  
• reflective learning;
  
• spot checks;
  
• staff questioning; and
  
• follow-up following incidents or significant events.
  

CQC’s Regulation 18 guidance specifically says staff should be supervised where appropriate until they demonstrate an acceptable level of competence and should receive ongoing or periodic supervision so that competence is maintained.

How to Build a CQC Staff Competency Matrix

A competency matrix can make this much easier to manage.

Instead of having certificates distributed between personnel files, emails and training platforms, the matrix gives you an overview of what each role requires and where there are outstanding gaps.

A simple matrix might include:

Field	What to record
Staff member	Name
Role	Current position
Required competency	Knowledge or skill required
Training	Relevant learning completed
Competency assessment	How competence was tested
Assessment date	When it was checked
Assessor	Who completed the assessment
Outcome	Competent or development required
Action	Any follow-up required
Review date	Next planned review

The exact format should reflect your organisation.

More importantly, keep it live.

A beautifully constructed spreadsheet that has not been reviewed for 18 months tells you very little about the competence of your workforce today.

Review competency through processes you already have, such as governance meetings, supervision sessions, appraisals and workforce reviews.

Oliver McGowan Training and Regulation 18

Learning disability and autism training now requires particular attention.

The Health and Care Act 2022 introduced a statutory requirement for CQC-registered health and social care providers to ensure staff receive learning disability and autism training appropriate to their role. The final Oliver McGowan code of practice came into effect on 6 September 2025.

There is an important distinction here.

The statutory requirement is for appropriate learning disability and autism training. The government describes the Oliver McGowan Mandatory Training package as its preferred and recommended package for helping registered providers meet that requirement.

Tier 1 and Tier 2 Training

The Oliver McGowan programme contains different levels according to people’s responsibilities.

Tier 1 is designed for people requiring general awareness of the support that autistic people and people with a learning disability may need.

Tier 2 is intended for health and social care staff providing direct treatment, care or support and other professionals working with greater autonomy. Government guidance gives examples including regulated health professionals, registered managers, team leaders, care assistants and support workers.

This creates an operational challenge for providers.

You may have:

• permanent employees;
  
• part-time staff;
  
• locums;
  
• contractors;
  
• visiting clinicians; and
  
• people working very different schedules.
  

A practical tracker can record each person’s role, required training level, completion status and any outstanding action.

Providers also need to plan for the delivery format. The code requires live and interactive elements involving people with lived experience, with different requirements according to the level of training required.

Leaving this until shortly before CQC contact can create avoidable workforce and scheduling problems.

Regulation 18 and Locum Staff

Temporary workers can easily fall through gaps in routine processes.

A locum may be highly experienced clinically but still know nothing about how your particular service operates.

• Where is the emergency equipment?
• How are incidents reported?
• Who is the safeguarding lead?
• Who should they contact if they need urgent clinical support?

CQC’s Regulation 18 guidance states that providers must have an induction programme that prepares staff for their role.

For temporary staff, that induction can be proportionate. It does not necessarily require hours of classroom teaching.

The 15-Minute Locum Induction

A simple local induction might cover:

• safeguarding leads and escalation;
  
• fire and emergency procedures;
  
• chaperone arrangements;
  
• IT and clinical-system access;
  
• incident reporting;
  
• clinical escalation;
  
• important local protocols; and
  
• location-specific safety information.

Use a standard one-page checklist rather than relying on whichever manager happens to be working that day.

Record who received the induction, when it happened, who delivered it and what was covered.

You can also test whether the information landed. Ask a locum, “What would you do if you had a safeguarding concern?” or, “How would you report an incident here?” Their response gives you much more useful information than knowing that somebody ticked an induction box.

Practising Privileges and External Consultants

Practising privileges requires the same active approach.

Consider a hypothetical private clinic that properly checks a visiting consultant’s professional registration and indemnity arrangements when they first join.

Everything is filed; nobody checks it again. A year later, one of those documents has expired.

The problem is not that the initial check was poor. The problem is that the clinic treated a time-limited assurance as permanent.

Depending on the role and arrangements, a live practising privileges process may need to keep track of matters such as:

• professional registration;
  
• indemnity arrangements;
  
• scope of practice;
  
• DBS information where applicable;
  
• relevant training;
  
• competencies;
  
• review dates; and
  
• conditions attached to practising privileges.

The key is ownership.

External practitioners can sometimes sit outside ordinary employee HR processes. Somebody therefore needs clear responsibility for ensuring that required evidence remains current.

A central tracker with advance renewal alerts is considerably more useful than individual documents sitting unnoticed in separate folders.

Clinical Supervision Is Not the Same as an HR Appraisal

Another common issue is treating clinical supervision and appraisal as though they are interchangeable.

They are connected, but they perform different functions.

Clinical supervision	Appraisal
Clinical cases and decisions	Wider performance
Clinical judgement	Development objectives
Professional practice	Role performance
Reflection and learning	Career development
Clinical risks and improvement	Wider employment matters

Regulation 18 itself refers to both supervision and appraisal, as well as training and professional development.

For clinicians, supervision might include peer-to-peer reviews, case discussions or prescribing audits where relevant to the service.

A useful record might include:

• date;
  
• participants;
  
• anonymised cases or subjects discussed;
  
• learning;
  
• concerns or risks identified;
  
• agreed actions; and
  
• follow-up.
  

Clinical discussion does not always happen in a scheduled meeting. Sometimes important supervision occurs in a five-minute conversation between patients.

Not every conversation needs minutes.

However, where an informal discussion identifies material learning, risk or an action that needs following up, create a proportionate record. Without evidence, it may be much harder later to demonstrate that effective supervision and oversight were taking place.

How to Demonstrate That You Have Enough Staff

Regulation 18 is still a staffing regulation, so providers should not allow the focus on training to obscure the requirement for adequate numbers.

CQC says providers should determine both the number of staff and the range of skills necessary to meet people’s needs. Staffing and skill mix should be continuously reviewed and adapted to changing circumstances.

Evidence might include:

• rotas;
  
• workforce planning;
  
• vacancy information;
  
• demand and capacity data;
  
• sickness and absence trends;
  
• agency use;
  
• waiting times;
  
• incidents;
  
• patient feedback;
  
• risk assessments; and
  
• governance meeting records.
  

There is no value in maintaining a staffing figure simply because that is “what we have always used” if service demand has changed significantly.

Equally, headcount alone can be misleading.

Five members of staff may be enough numerically, but not if the activity being delivered requires a particular clinical skill and nobody on that shift possesses it.

Common Regulation 18 Staffing Mistakes

Some of the most common problems are relatively simple:

1. Treating certificates as proof of competence. Training has been completed, but nobody has established whether staff can apply it.
   
2. Giving everyone the same training list. Requirements are not linked to actual responsibilities or risks.
   
3. Allowing competency records to become outdated. The organisation cannot quickly identify current gaps.
   
4. Leaving locums outside normal governance arrangements. Temporary staff receive little or no local induction.
   
5. Checking practising privileges only at appointment. Time-limited evidence is not actively monitored.
   
6. Using appraisal as a substitute for supervision. Staff receive an annual performance review but have little documented professional or clinical oversight.
   
7. Failing to ask what changed following training. Learning is recorded without assessing its impact.
   
8. Looking only at staff numbers. The rota is full, but the necessary skill mix is absent.
   

A Practical Regulation 18 Compliance Cycle

A straightforward approach is to work through six stages:

1. Assess – identify the staffing, skills and competencies your service requires.
   
2. Map – connect those requirements to individual roles.
   
3. Train and support – provide appropriate training, development, induction and supervision.
   
4. Check – establish whether staff can demonstrate competence.
   
5. Act – address gaps, incidents, audit findings and development needs.
   
6. Review – revisit your arrangements as staff, services and risks change.
   

This is not an official CQC framework. It is simply a practical way of making Regulation 18 part of everyday governance.

What Evidence Should You Keep for Regulation 18?

Your evidence should reflect the size, nature and complexity of your service, but it may include:

• staff rotas and workforce plans;
  
• job descriptions;
  
• training needs assessments;
  
• training records;
  
• competency assessments;
  
• a current competency matrix;
  
• supervision records;
  
• appraisal records;
  
• professional development evidence;
  
• professional-registration checks where required;
  
• practising privileges documentation where relevant;
  
• locum induction records;
  
• audit and peer-review evidence; and
  
• action taken when staffing or competency gaps are identified.
  

For some types of new service, CQC specifically asks for a staff training plan at registration and expects that plan to reflect the people the service intends to support.

Documentation matters, but the objective is not to create paperwork for its own sake. Your records should help you understand whether the workforce is safe, competent and properly supported.

Frequently Asked Questions About CQC Regulation 18

What Is Regulation 18 of CQC?

Regulation 18 is the staffing regulation under the Health and Social Care Act 2008 (Regulated Activities) Regulations 2014. It requires sufficient numbers of suitably qualified, competent, skilled and experienced staff, together with appropriate support, training, professional development, supervision and appraisal.

Does CQC Have a Mandatory Training List?

There is not one universal CQC course list that applies identically to every provider and every role. Providers need to consider statutory requirements, training they determine is mandatory for individual roles and any additional development necessary for their regulated activities.

Is Oliver McGowan Training Mandatory?

CQC-registered health and social care providers have a statutory responsibility to ensure staff receive learning disability and autism training appropriate to their role. The government describes Oliver McGowan Mandatory Training as its preferred and recommended package for meeting that requirement.

How Can You Prove Staff Are Competent?

Evidence may include practical observation, competency assessment, supervision, clinical audit, case discussion and demonstration that learning has been applied. The appropriate evidence depends on the person’s role.

Do Locums Need an Induction?

Providers should make sure temporary workers have the knowledge, support and local information required to perform their role safely. CQC’s Regulation 18 guidance specifically requires providers to have an induction programme that prepares staff for their role.

How DKJ Support Services Can Help With CQC Staffing Compliance

At DKJ Support Services, we support private clinics, GP practices and other health and social care organisations with practical CQC compliance and governance arrangements.

Our wider private-clinic support includes regulatory compliance and clinic governance alongside operational support.

We can support you with areas including:

• reviewing staffing and governance systems;
  
• developing practical compliance trackers;
  
• reviewing competency and training arrangements;
  
• preparing teams for CQC assessments; and
  
• understanding staffing requirements when setting up a new regulated service.
  

Our aim is to help you build CQC requirements into the work you already do, rather than creating a separate compliance exercise that only becomes important when an assessment approaches.

Conclusion

CQC Regulation 18 is not simply about counting the number of people on your rota or checking whether mandatory training certificates are in date.

You need enough of the right people, with the appropriate skills, competence, experience, training and support to perform their responsibilities safely.

That means connecting your workforce systems:

role → training → competence → supervision → evidence → action → review

A certificate can show that training took place. Your wider governance arrangements should demonstrate what staff learned, whether they can apply it and whether they continue to remain competent.

When staffing and competency become part of routine management rather than inspection preparation, Regulation 18 becomes much easier to evidence — and considerably more useful as a framework for running your service.