Resetting the CQC: What the 2025/26 business plan and assessment framework consultation means for providers

The Care Quality Commission (“CQC”) has published its 2025/26 business plan alongside a consultation on its inspection and assessment process, setting out a reset to the regulator’s operating model after a period of intense scrutiny. Read alongside each other, they show the CQC moving to stabilise core functions, while consulting on large reforms to the assessment framework faced by health and social care providers. The regulator intends to immediately push for operational recovery, with detailed sector frameworks and inspection principles to be co‑designed and phased in over the next year.

From Operational Recovery to Assessment Framework Redesign

The 2025/26 business plan responds to the failures identified by Dr Penny Dash and Sir Mike Richards in their reviews of the regulator and the subsequent evidence to the Health and Social Care Committee about operational backlogs and platform problems, following ambitious, but ill-fated 2024 reforms. In practical terms, the plan:

• Reintroduces sector leadership through four Chief Inspectors with respective oversight over hospitals, primary care, adult social care, and mental health. A single inspector role will replace the current split ‘assessor/inspector’ functions.
• Commits to revised policies for assessment, including providing sector and service-specific guidance, a clearer regulatory model, and defined expectations on how judgements and ratings will be determined.
• Confirms interim simplification of scoring by ceasing evidence-category scoring and scoring only at the quality statement level, pending a consultation-led reset of the framework.
• Prioritises immediate operational recovery: completing more assessments, eliminating information of concern backlogs, accelerating registrations, and stabilising digital platforms while the provider portal is re-built.

Running in parallel, the consultation sets out the CQC’s proposed direction of travel on the framework and methods underpinning the future assessments that providers will face. It proposes:

• Sector specific assessment frameworks: developing assessment frameworks by sector the CQC aims to articulate what the different ratings look like, in context, for each kind of service. Whilst remaining tied to the ‘five key questions’, these frameworks hope to assist providers in knowing what to expect from a CQC inspection.
• Reintroduction of rating characteristics: by describing expectations for the quality and safety of services at each rating level, the CQC intends to restore the detail that providers valued in the pre-2024 assessment model, supported by structured ‘supporting questions’ (akin to the former ‘key lines of enquiry’) to replace the current quality statements.
• Simplification of judgment and ratings: the CQC proposes to remove the layered scoring model beneath key questions and returning to evidence-based assessment, guided by published rating characteristics and professional judgement. Instead of calculating scores for individual categories and aggregating them, inspectors would simply consider the relevant evidence for each key question, then assign a rating of Outstanding, Good, Requires Improvement and Inadequate. This approach aims to increase clarity for providers.

The consultation proposals align with the business plan’s interim simplifications and provides direction as to how the CQC intends to rebuild credibility, clarity and timeliness in its ratings. With the finer details of the new system to be confirmed, input from across the health and social care sector will assist the CQC in devising changes that are suitable for, and clearly understood by, the providers.

Frequency of Inspection and the Use of Evidence

The consultation and business plan together signal a more transparent approach to planning assessment activity. Routine planned inspections are expected to operate on a three to five‑year cycle depending on service type, supplemented by rapid response inspections for immediate and specific concerns.

Importantly, the CQC states it intends to minimise the mixing of new evidence with evidence gathered in previous inspections when updating ratings - an approach that has attracted heavy criticism. The aim is that judgements reflect up‑to‑date evidence rather than legacy findings, that may no longer be relevant.

Once the new approach to judgements is established, the CQC intends to introduce a frequency schedule tailored to individual health and care sectors, taking into account factors such as previous ratings and emerging risk. If well implemented, this could mean a more predictable inspection schedule for providers.

Practical Implications for Providers

Providers should anticipate a greater volume of assessments as the CQC works toward its targets of reducing the inspection backlog and achieving shorter completion times. The move to sector‑led teams and a single inspector role should support improved engagement and clearer feedback during assessments. As rating characteristics and sector‑specific frameworks are developed, providers should also gain improved clarity on the regulator’s expectations and align their governance, audit and improvement activity accordingly.

While routine inspection cycles are expected to be three to five years by sector, emergent risk and concerns will continue to drive rapid response inspections, and the intention to minimise mixing of legacy and new evidence underscores the importance of evidencing current compliance against the five key questions.

The CQC has indicated that they intend to significantly speed up the registration process for new providers. Moving registrations off the much-criticized digital platform, employing extra staff, and adopting new operating procedures is designed to meet a 10‑week decision target for valid applications, reducing delays to service change and market entry.

The CQC’s business plan also references planned expansion of the CQC’s regulatory remit following the Department of Health and Social Care’s announcement that providers of medical care at temporary sporting and cultural events, and higher-risk non-surgical cosmetic procedures, will be required to register with the CQC. We will discuss the potential impacts on providers affected by the proposals in a follow-up Law Now article.

What Remains to be Defined?

It is apparent that the CQC has listened to the feedback reflected in the Dash and Richards reviews. The renewed emphasis on sector expertise, clearer guidance, more impactful reports and stronger professional relationships marks a course correction many will welcome. That said, this consultation only presents a high‑level overview of the direction of travel. Several aspects of the CQC’s re-designed assessment framework are not yet fully defined in the business plan and will be shaped by responses to the consultation. Providers will pay particular attention to:

• The detail of the new sector‑specific assessment frameworks, including rating characteristics and supporting questions that will anchor judgements at each rating level.
• The sector‑by‑sector inspection frequency schedule, to be introduced after the new approach to judgements is confirmed, and what principles are employed for updating ratings over time.
• The future format of ratings for complex providers (for example, NHS trusts and groups of independent hospitals), including whether to re‑introduce group‑level quality ratings and whether to continue location‑level ratings for individual hospitals.

Alongside these assessment framework questions, the business plan highlights a large programme of work still to come, including rebuilding digital platforms and the provider portal; strengthening data quality and governance to enable better use of data; taking on an expanded remit as regulation changes take effect; and developing a clear policy position on AI, with publication aimed by spring 2026. Taken together, this points to a busy period for the regulator.

Next steps

The business plan and consultation present a phased reset for the regulator: stabilise core operations now, and consult on a clearer, sector‑specific framework and simplified rating methodology going forward. This is a step in the right direction and indicates that the CQC has taken recent criticism seriously. The elements that matter most to providers - the sector frameworks, rating characteristics, supporting questions and frequency schedules - will be shaped by responses to the consultation, which closes on 11 December 2025.

With major work also underway on the regulatory platform, data systems, expansion of regulatory scope, and an AI position statement by spring 2026, the coming year will be pivotal. It is therefore an important time for providers to engage with the CQC, as the regulator develops how it will operate in future.

We will be following further updates on the CQC’s progress and our team is on hand to assist with your regulatory queries.

Co-authored by Philip Gaffney, Graduate Solicitor Apprentice