CBS Response to GMC Consultation Document on Reforming the Legislative Framework

22 June 2026

The Government has consulted on the proposal to reform the legislative framework for the General Medical Council (GMC) which governs medical regulation, education, and training in the UK. The proposed changes form part of a broader programme of regulatory modernisation intended to provide the GMC with greater flexibility in setting and approving standards, curricula, and training pathways, while streamlining existing governance processes. The consultation includes proposals that could alter existing arrangements for the development, approval, and oversight of postgraduate medical education and specialty training.

Given the potential implications for surgical training, workforce planning, professional standards, and patient safety, the Confederation of British Surgery (CBS) has reviewed the consultation proposals and submitted the following response:

CBS response to GMC consultation document on reforming the legislative framework

Patient safety and maintenance of standards

CBS has highlighted that any dilution in the breadth, consistency, or standardisation of training has implications for patient safety and the consistency of clinical competence across the surgical workforce. The current system has evolved to ensure surgeons acquire a broad range of competencies before progressing to specialist practice.

In clinical practice this ensures the ability of surgeons to participate in on call rotas within their broad speciality whilst continuing to provide specialist services on an elective basis. This optimises care for the majority without loss of specialist expertise.

The consultation document infers recognition of additional speciality groups. This runs the risk of fragmentation of services and difficulties with fulfilling emergency general on call duties.

Misalignment with international training models

CBS notes that comparisons with European and North American systems are not directly applicable, given differences in training duration, case complexity, service delivery models, workforce structures, and healthcare systems. There are already examples across multiple UK specialties whereby European and overseas colleagues appointed with expertise in a subspecialist area lack the fundamental specialty skills to fulfil routine emergency on call commitments. Reforms should therefore be based primarily on the needs of the UK healthcare system and patient population.

Loss of professional ownership of standards

CBS is concerned regarding the proposed shift in the balance of responsibility for setting training standards away from the profession and Royal Colleges towards the regulator alone. Maintaining professional leadership in curriculum design and standards setting is essential to ensure that training remains clinically relevant, evidence-based, and responsive to developments in surgical practice. There needs to be recognition that demands on surgical services are not fixed. They need to evolve with changing population demographics and disease prevalence.

It is essential that surgeons are trained to meet the needs of society.

Unintended proliferation of specialty curricula and delivery challenges

Changes to approval processes risk encouraging the development of multiple specialty and sub-specialty curricula, complicating training pathways, workforce planning, and educational governance. Such proliferation could also create significant challenges for implementation and delivery within existing training structures, including Schools of Surgery, training programmes, and assessment frameworks. The resulting complexity is likely to make training pathways less transparent for trainees and employers alike.

Risk of curriculum fragmentation and challenges to implementation

CBS is concerned that reducing or removing Royal College involvement in curriculum approval may result in multiple groups within surgical specialties presenting competing or parallel curricula for assessment and approval. This risks creating inconsistency across training programmes and places significant demands on GMC infrastructure and resources. If multiple curricula were approved, implementation within the current School of Surgery structure could prove challenging, creating variation in training delivery, assessment, and workforce planning.

Threat to the breadth of UK surgical training

CBS believes the current UK system provides a comprehensive and structured training pathway, with core surgical training providing an essential broad foundation for surgeons. There is concern that reform may inadvertently move training towards narrower or shorter models, reducing breadth of training, exposure to complex cases, and operative experience within specialty areas. In the current turbulent world, a broad foundation is an imperative in the management of conflict casualties which is understood to be an established national priority.

Impact on workforce stability and planning

CBS is concerned that uncertainty or significant change in training structures will negatively affect recruitment, morale, retention, and longer-term workforce planning within surgery. Stability and clarity in training pathways are important factors in attracting and retaining high-quality trainees.

Concerns regarding regulatory power, balance of authority, and access to appeals

CBS has expressed concern about a potential imbalance of power arising from the proposed reforms, with the General Medical Council gaining increased autonomy in curriculum approval and regulatory decision-making. It is important that appropriate checks and balances remain in place to ensure fairness, transparency, accountability, and proportionality within regulatory processes, and to safeguard against the risk of disproportionate regulatory impact on individual practitioners.

CBS is also concerned that proposals allowing costs to be assigned to appeals may create equality, diversity, and inclusion risks. Residents in training, those working less-than-full-time (LTFT), and colleagues with caring responsibilities or other financial constraints may be less able to meet the costs associated with challenging decisions. This could create barriers to access to justice and disproportionately affect certain groups within the medical workforce.

Erosion of Royal College involvement and loss of established quality assurance mechanisms

CBS is concerned that proposals allowing the GMC to approve curricula without consultation with the Royal Colleges would inevitably weaken the established partnership model that underpins specialty training standards. We do not believe that the GMC currently has the infrastructure, specialty-specific expertise, or established mechanisms required to undertake detailed curriculum assessment independently. At present, curriculum development and review are delivered through the Royal Colleges, the Joint Committee on Surgical Training (JCST), and the Specialty Advisory Committees (SACs). Unless the Royal Colleges are explicitly recognised as organisations that must be consulted during curriculum approval processes, there is a risk that established checks and balances within the system will be lost, reducing professional oversight and potentially impacting the quality and consistency of training standards.

Conclusion

CBS believes that consideration should be given to deferring detailed legislative changes until the conclusions of the next phase of the Medical Training Review are available, allowing reforms to be informed by a comprehensive assessment of future training needs.

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