The GDC wants to replace the Standards with “professional judgement” – here’s what that actually means for you

The GDC’s Standards for the Dental Team have underpinned dental regulation since 2013. Now the GDC is looking to replace them entirely with a “Framework for Professionalism”, moving away from detailed, numbered rules towards broad Principles that professionals are expected to interpret and apply using their own judgement.

This is one of the most significant changes to dental regulation in over a decade. It will shape what “professional” means for every registrant, how fitness-to-practise cases are judged, and what patients can expect when they walk into a practice. Yet, much like the CQC’s own review of its assessment framework earlier this year, many in the sector may not be aware it’s happening.

At Agilio, we’ve spent the consultation period reviewing the proposal in detail and have submitted a formal response covering 20 separate questions. Here’s what could change, along with some areas we think are worth watching closely.

What’s changing and why

The GDC proposes to retire the current Standards for the Dental Team and replace them with a Framework for Professionalism comprising three statutory elements and one element to support their interpretation.

Principles of Professionalism (statutory) – These four broad tenets, down from the current nine, describe the core of what it means to be a dental professional: “treat patients with respect”, “practise safely and effectively”, “maintain trust in the profession”, and “work in partnership with others”. The intention of these is to “guide professionals in applying their skills, knowledge and experience, recognising that every patient and situation is different”.

Professional Guidance (statutory) – These are topic-specific directions on particular areas, such as consent or advertising, that outline clear obligations or boundaries and must be understood and followed by registrants. They can be considered in fitness-to-practise processes.

Expectations (statutory) – These sit underneath each Principle and describe the many ways a GDC registrant can demonstrate they’ve upheld it. Registrants are normally expected to meet them, using professional judgement to decide which apply and how best to meet them for the situation, patient, or colleagues involved. Departing from an Expectation altogether requires justification by reference to another Principle, Expectation, or Professional Guidance.

Supporting Material – This is advisory content, such as case studies and videos, designed to help registrants understand how the statutory elements can be applied in practice. It’s not mandatory and can’t serve as the basis for a fitness-to-practise allegation.

All of this will sit within a new online content hub, replacing the current PDF-based Standards document and corresponding webpages.

The GDC’s reasoning is that a detailed, rule-based document struggles to keep pace with the sheer variety of situations dental professionals encounter in practice. No two clinical situations are identical, and the GDC believes a framework built around professional judgement, rather than an attempt to write a rule for every scenario, better reflects how decisions are actually made on the ground. It also intends this shift to resolve the confusion caused by the current must/should distinction, which has long made it unclear whether a given Standard is a hard requirement or a recommendation.

We see this as a sensible direction of travel. The current Standards are repetitive in places, and the rigid must/should distinction has long been a source of confusion. A model built around professional judgement, properly supported by professional guidance and supporting materials, has real potential to improve the profession’s relationship with its own regulator.

As with any change of this scale, though, the detail matters.

The questions dental professionals should be asking

“What happens to the detail that’s being removed?”

A significant amount of prescriptive detail in the current Standards is being consolidated into broader Expectations, on the basis that Professional Guidance and Supporting Material will provide the detail underneath them. That material hasn’t yet been published, even in draft, alongside the consultation, which makes it harder for the profession to picture how things will work in practice.

Take Complaint handling as an example. The current Standards set out 19 specific expectations covering how complaints should be handled, including a requirement for private practices to operate a procedure with “similar standards and time limits to the NHS (or equivalent health service) procedure”. Under the proposed Framework, this is consolidated into a single, broader statement about managing complaints “using a clear and accessible policy”. For a private practice without a directly equivalent NHS process to benchmark against, it may be less obvious what standard they’re expected to meet.

Medical emergency preparedness is another example. The current Standards explicitly anchor training and staffing expectations to the Resuscitation Council (UK) guidelines, with specific requirements for simulated practice. Under the proposed Framework, this becomes a general Expectation to be “trained in medical emergencies and understand their role”. Given the sheer volume of guidance available, it may be unrealistic to expect every professional to independently identify the Resuscitation Council standards without a clear signpost from the GDC.

A similar pattern appears elsewhere. Requirements regarding what practices display to patients (GDC registration numbers, fee information, the Principles themselves) no longer appear explicitly in the proposed framework. With regulators such as the CQC and HIW referring to these in their own assessment frameworks, it isn’t yet clear what the GDC intends the expected norm to be, and this is an area where clearer direction at launch would help.

We’ve suggested to the GDC that, given the day-to-day impact these areas have on patient safety and public confidence, it would have been helpful for the accompanying guidance to be available alongside the Framework as part of the consultation, rather than being developed afterwards.

“How consistently will broader Expectations be interpreted?”

Registrants are human, and humans naturally differ in how they weigh up risk, how well they know the underlying law or guidance, and how they were trained to think about a given situation. Two colleagues in the same practice, faced with the same set of circumstances, may reasonably reach different conclusions about what a broad Expectation requires of them, one erring towards caution, the other towards flexibility, both acting in good faith.

That variation has a direct, practical consequence: patients in one practice may experience a different standard of care or a different professional response than patients in another, even though both practices believe they are meeting the same Expectation. Under the current Standards, a shared numbered reference point helped keep this kind of variation in check. Under the proposed Framework, consistency will depend far more on how well Professional Guidance and Supporting Material narrow that gap, ideally with worked examples that make clear where the boundaries of reasonable interpretation sit.

“What does this mean for fitness to practise?”

The same broadening of Expectations may also change how a registrant’s judgement is assessed when it is questioned after the fact. The current Standards provide registrants with specific and identifiable professional benchmarks against which they can explain and justify their actions. Replacing detailed standards and guidance with broader expectations may increase the scope for retrospective interpretation and reduce the predictability and consistency of regulatory decision-making.

This shift asks a lot of registrants, and it will only feel fair if the GDC is equally clear about what constitutes a justifiable departure before a case ever arises, not just when reviewing one after the event. Guidance that reads primarily as a basis for regulatory action, without being equally clear about how it supports professionals in getting things right day-to-day, risks reinforcing the perception that the Framework exists to catch people out rather than help them. This is a genuine opportunity for the GDC to challenge that perception and strengthen confidence in its approach.

“Will the content hub actually work?”

The Framework places significant weight on a new online content hub, which at this stage remains a mock-up. If it’s intuitive, well-maintained, and genuinely consolidates guidance in one place, it could be a real improvement on the current PDF and corresponding webpages. If it results in professionals having to click through multiple pages to find a basic answer, it risks being harder to use than the document it replaces.

We’ve raised a more fundamental concern, too: the move to a predominantly digital platform carries implications for equality. Registrants and patients who are less confident in navigating digital interfaces, or who have visual, cognitive, or motor impairments, may face real barriers to accessing information that carries statutory weight in fitness-to-practise proceedings. We’ve asked the GDC to confirm whether they will retain a downloadable, print-accessible version of the statutory Framework and offer alternative formats, such as Easy Read, large print, or audio, on request.

What we did about it

As the UK’s leading experts in dental compliance, we’re in a position where individual practices aren’t, we see how regulatory frameworks apply across the full breadth of the sector, from independent practices to DSOs, and we have the expertise and data insight to engage with a consultation like this in real depth.

Our response was also shaped significantly by the input of Daniela Schadler, our Dental Compliance Specialist and a GDC-registered Dental Therapist. Daniela’s frontline registrant perspective was instrumental throughout, particularly in helping us stress-test how the proposed Expectations would actually land for someone practising day-to-day under them.

In total, we submitted a formal response to the GDC covering all 20 consultation questions, addressing:

• The clarity and adequacy of the Principles, Expectations, Professional Guidance and Supporting Material as a four-part structure
• Areas where prescriptive detail has been consolidated into broader Expectations, including medical emergency preparedness, display requirements and complaints handling
• The Equality Impact Assessment, with a focus on Age and Disability implications of moving to a digital-only content hub
• Our suggestion that consultation respondents would benefit from seeing the Professional Guidance and Supporting Material alongside the Framework itself, to better judge how it will work in practice

What should dental professionals do right now?

• Be aware that this is happening. The consultation closed on 31 August 2026. That doesn’t mean the Framework lands overnight, but the responses submitted will shape what “professional” means for every registrant.
• Read the proposed Framework and the accompanying online content hub prototype for yourself. A high-level look will help you understand the direction of travel and form your own view on what’s unclear or unworkable.
• Watch this space. Once the GDC has reviewed consultation feedback, we’ll report back on what they’ve heard and what happens next.

Summary

Regulatory change of this scale doesn’t happen often, and when it does, the practices that are best prepared and the sector voices that engage early shape the outcome. We’re committed to being one of those voices and to ensuring the profession has the clarity it needs to apply the Framework with confidence.

Our customers can be reassured that we’ll make the necessary changes to our systems well ahead of any implementation timeline, and that we’ll continue to keep the sector informed as this consultation progresses toward a final outcome.

If you have questions about the proposed Framework or what it might mean for your practice, feel free to reach out directly.

Rhys Jones is Head of Compliance at Agilio Software, the UK’s largest SaaS provider specialising in dental support and compliance.

With thanks to Daniela Schadler, Dental Compliance Specialist and GDC-registered Dental Therapist, for her invaluable contribution to our consultation response.