Anyone who has bought a dental practice in the last few years will know that registering with the Care Quality Commission (CQC) is one of the unavoidable steps between exchanging contracts and opening the door as the new owner.
What has changed is the sheer volume — and specificity — of the documentation the CQC now expects to see at the outset of a new registration application.
Where a slimmer evidence pack might once have sufficed, applicants are now being asked to demonstrate, upfront, that the whole operation — corporate, physical and clinical — meets the required standard before the CQC will even progress the application.
For a prospective buyer, this shifts a significant amount of due diligence earlier in the transaction timeline. Below is a walk-through of what’s now required, grouped by theme, and what it means in practice for someone looking to buy a practice.
1. Corporate and financial foundations
Before anything else, the CQC wants proof that the registering entity is properly constituted and financially sound:
● ICO registration certificate for each entity being registered — confirming the business is registered with the Information Commissioner’s Office for its handling of patient data.
● Public and employer liability insurance quotes or certificates for each entity — evidence that appropriate cover is either in place or has been arranged.
● Financial Viability Form — required for all registrable entities except NHS partnerships, this is essentially the CQC satisfying itself that the buyer has the financial standing to run the practice sustainably.
For a buyer, this means insurance and data protection registration can no longer be treated as “day administrative tasks” to sort out after completion. They need to be arranged, or at least well in train, before the application even goes in.
2. Premises, equipment and safety compliance
This is the largest and most technically demanding category, and the one most likely to catch buyers out if the practice’s existing paperwork isn’t in order:
● Building control final certificate — needed where the application covers locations that required building regulations approval, confirming any structural or building works were signed off.
● Critical examination and acceptance test reports — for equipment such as radiography and decontamination equipment, confirming it has passed the required commissioning tests.
● Fire risk assessment
● HSE Ionising Radiations Regulations (IRR) registration — a legal requirement for any practice using X-ray equipment.
● Health and safety risk assessment
● Legionella risk assessment
● LOLER lift safety certificate — where applicable, for any lifting equipment on site.
● Radiography risk assessment and Local Rules document — a specific regulatory requirement under the Ionising Radiations Regulations, setting out how radiation safety is managed on the premises.
● Staff organigram — a clear structure chart showing lines of accountability.
This is where buying an existing practice differs sharply from a fresh registration on a new site: a purchaser is inheriting someone else’s paperwork trail. If the seller cannot produce up-to-date certificates and test reports — particularly around radiography, fire and Legionella — the buyer will need to commission new assessments before the application can be submitted, which has real timing and cost implications for the deal.
3. Governance policies and procedures
The CQC also wants to see that a full suite of governance policies is in place and ready to operate from day one, not drafted retrospectively once the practice is live:
● Consent policy
● Equality, diversity and human rights policy and procedures
● Governance policy and procedures
● Infection control policy and procedures
● Medicines management policy and procedures
● Recruitment policy and procedures
● Safeguarding policy and procedures
● Complaints policy~
In many acquisitions, the buyer will want to bring in their own policy suite rather than simply adopting the seller’s, particularly if the buyer already operates other practices with an established set of procedures. Either way, these documents need to exist, be practice-specific, and be ready to show the CQC before registration — not something to be written in the weeks after completion.
4. Premises-specific evidence for dental use
Three further requirements are specific to the property itself and its suitability for use as a dental practice:
● Planning consent — evidence that the premises has the correct planning permission for use as a dental practice, or, where no formal consent exists, confirmation of the permitted use (for example, through a lawful development certificate or historic evidence of use).
● Building regulations certificates — copies of all building regulations sign-offs for any works carried out at the property, not just the most recent works.
● Confirmation of the number of dental chairs — a straightforward but important disclosure, since it directly affects the scope and scale of the registration.
Planning history is often the sleeper issue here. Older practices, or those that have changed hands multiple times, don’t always have a clean paper trail showing formal planning consent for dental use, especially if the building predates current planning rules or has been altered over the years without full paperwork being retained. Establishing this — or obtaining a certificate of lawful use where consent can’t be evidenced — can take time and is worth investigating early in a transaction, not left until the CQC application is being prepared.
What this means for buyers in practice
Taken together, these requirements mean that CQC registration is no longer something that can be treated as a formality to be dealt with once heads of terms are agreed and the legal process is under way. Several of these documents — planning consent, building regulations history, fire and Legionella assessments, IRR registration — depend on records the seller holds, and gaps in that paperwork can only be fixed with time, and sometimes cost, before an application will be accepted.
For anyone in the process of buying a dental practice, the practical implications are:
● Start due diligence on compliance documentation early, ideally as part of the initial due diligence exercise alongside the usual legal, financial and clinical checks — not left until the point of preparing the CQC application itself.
● Request the full CQC evidence pack from the seller as a specific line item in due diligence, rather than assuming existing certificates and policies will simply carry over or be adequate.
● Budget time (and potentially cost) for gaps — commissioning new risk assessments, obtaining lawful development certificates, or arranging insurance for a new entity can all take weeks.
● Decide early whether to adopt or replace the seller’s policy suite, since governance policies need to be practice-ready and CQC-appropriate from the point of application, not drafted after completion.
● Treat the Financial Viability Form as part of deal planning, since it will require visibility of the buying entity’s financial position, which in turn depends on how the acquisition itself is being funded and structured.
In short, the CQC’s expanded requirements push a meaningful amount of compliance and paperwork verification into the pre-completion phase of a practice sale. Buyers who engage with this early — treating the CQC evidence list as a due diligence checklist from the outset, rather than a post-completion task — are far less likely to find their registration, and therefore their ability to start treating patients under new ownership, delayed.