How to set up as a GP locum in the UK: a 2026 practical guide

Will Stocker, founder20 April 20269 min read

Going locum sounds simpler than it is. The clinical work is the same; the operational layer underneath is not. Done properly, the setup takes a week of admin spread across a few months. Done badly, it turns into late tax bills, lost pension accrual, and a nasty CQC letter when a practice realises your performer list status was never confirmed.

This is the 2026 setup, in order, for a UK GP going freelance. Numbers are 2026/27 unless flagged.

1. Confirm GMC registration with a licence to practise

Before anything else, your GMC entry must show:

Full registration with a licence to practise (not just registered).
An up to date connection to a designated body for revalidation.
No outstanding fitness to practise matters.

Locum GPs revalidate the same way salaried and partner GPs do. The default designated body for sessional GPs in England is the local NHS England Primary Care team; in Scotland it is NHS Education for Scotland (NES); in Wales it is the Health Board that holds your performer list slot; in Northern Ireland it is the Northern Ireland Medical and Dental Training Agency (NIMDTA).

If you are between substantive roles and you have no other prescribed connection, NHS England is the fall-through.

The annual GMC ARF for full registration with a licence is published on the GMC site each year. You can claim tax relief on it through HMRC.

2. Get on the performer list before your first session

This is the step that catches most new locums. You cannot lawfully provide NHS primary medical services as a GP without being on a performer list. It is set out in the National Health Service (Performers Lists) (England) Regulations 2013 and the equivalent regs in the devolved nations.

In England the application is via NHS England (PCSE Online runs it). It involves:

Identity check
Two clinical references
DBS check at enhanced level
Occupational health clearance
Evidence of GMC registration and CCT/CCST

Allow 6 to 12 weeks. Plan it before you book sessions, not after. Practices increasingly check, and an off-list session is unlawful for both you and the practice.

If you are joining from a CCT, your post-CCT mentoring scheme provider often runs you through the application; otherwise you do it yourself.

3. Sort indemnity for every kind of work you might do

NHS clinical negligence in primary care is covered by the Clinical Negligence Scheme for General Practice (CNSGP) since 1 April 2019. CNSGP covers clinical negligence claims arising from NHS primary care work. It does not cover:

Non-NHS clinical work (private clinics, occupational health, aesthetic, sports medicine)
Regulatory matters (GMC defence, NHS England investigation)
Coronial inquests
Complaints handling
Good Samaritan acts

For everything not covered by CNSGP you need a medico-legal membership with one of the three:

MDU (Medical Defence Union)
MPS (Medical Protection Society)
MDDUS (Medical and Dental Defence Union of Scotland)

Cost varies by hours and risk. A typical sessional GP membership for 2026 lands in the £700 to £1,800 per year range depending on workload, with private and aesthetic work pushing it higher. The fees are tax deductible.

If you do NHS sessions only, with no private work and no expert witness work, you are still strongly advised to carry a personal membership for the regulatory and inquest work that CNSGP excludes.

4. Register as self employed with HMRC

You do not need a limited company to start. Most locum GPs trade as sole traders. To register:

Apply for a UTR (Unique Taxpayer Reference) at gov.uk/register-for-self-assessment.
HMRC will post your UTR within 10 working days.
Save the date you started trading; this is the start of your first basis period.

You do not pay mandatory Class 2 National Insurance from 2024/25 onwards if your profits are above the Small Profits Threshold. Compulsory Class 2 above the SPT was abolished from 6 April 2024; you still get a qualifying year for state pension automatically. If your profits are below the SPT (£6,845 for 2025/26 and 2026/27) and you want a qualifying year, you can pay voluntary Class 2 at £3.65 per week in 2026/27.

What you do pay:

Class 4 NI on profits: 6% between £12,570 and £50,270, then 2% above £50,270.
Income tax: standard 2026/27 bands; personal allowance £12,570, basic rate 20% to £50,270, higher rate 40% to £125,140, additional 45% above. Frozen until 2030/31 (Autumn Budget 2025).

You file via Self Assessment, due 31 January following the tax year end.

5. Plan for Making Tax Digital from 6 April 2026

If your gross self-employed and property income is above £50,000 in your most recent filed Self Assessment, you are in MTD for Income Tax from 6 April 2026.

That means:

Digital records, kept in HMRC-compatible software
Quarterly updates to HMRC (not just an annual return)
A Final Declaration after the tax year ends, replacing Self Assessment for in-scope income

The threshold drops to £30,000 from April 2027 and £20,000 from April 2028. Most working locum GPs will fall in scope eventually, even if the first wave misses you.

Set up cloud accounting software now, even if you fall into the 2027 or 2028 wave. The migration is much easier when there is no live deadline.

6. NHS Pension: get on Form A and Form B from session one

If you want NHS Pension accrual, the two forms are Form A (GP Locum A) and Form B (GP Locum B). Both go through PCSE Online.

The mechanic in one breath:

Form A is completed by you, signed by the practice (or NHS England for appraisal work), one per session block.
Form B is your monthly summary of every Form A for the month, with contributions calculated.
Pensionable pay is 90% of your gross fee (10% in lieu of expenses).
Member contribution: 5.2% to 12.5% on a six-tier table, based on annual pensionable pay.
Employer contribution: 23.7% in England and Wales, 22.5% in Scotland and Northern Ireland.
The 10-week rule: a period of locum work that ended more than 10 weeks ago cannot be pensioned. Late forms are rejected.

A clean cadence is: invoice + Form A on the day, Form B in the first week of the next month. That keeps you well inside the 10-week limit and avoids reconstructing months of work in a panic.

OOH work follows a different route via GP SOLO forms completed by the OOH provider, not by you. You cannot opt out of pensioning OOH work if you are an active scheme member.

For full Form A and Form B mechanics, see the dedicated guide on the blog.

7. IR35 and limited company structures

Most new locum GPs start as sole traders. Some incorporate later, when income justifies the overhead.

What to know in 2026/27:

Direct GP practice locum work usually sits outside the off-payroll rules because most standalone practices clear the small-company test (after SI 2024/1303: turnover £15m, balance sheet £7.5m, 50 staff; any two of three). Determination defaults to you and your Ltd.
Direct NHS trust shifts are inside scope for off-payroll, with the trust (or agency in the chain) making the determination.
Agency PAYE and umbrella shifts already have employer NI and apprenticeship levy stripped from the rate, after the April 2025 employer NI changes.

If you incorporate, the dividend ordinary and upper rates rose by 2 percentage points from 6 April 2026, to 10.75% and 35.75%. That changes the salary/dividend split arithmetic. Run the numbers with an accountant before you assume Ltd is still cheaper.

8. Set your rates and your terms

There is no national locum rate. You set yours, and you publish a clear rate card to practices and agencies.

Components to think about:

Time rate (per session or per hour).
Cancellation terms: standard 14-day or 7-day notice; full session fee due if cancelled inside notice. Build this into your terms.
Travel and mileage: if you travel, charge mileage at HMRC rates (45p first 10,000 business miles, then 25p) or build it into the session rate.
Pension overhead: the employer 23.7% is yours to collect via Form B. Either build it in to the headline session rate or charge it as a separate pension uplift line.
VAT: clinical work to patients is VAT exempt under VAT Notice 701/57, so you do not register or charge VAT on standard locum work, even at high incomes. If you do significant non-clinical work (medico-legal reports, training delivery, retail consulting), the £90,000 threshold may bite for that work.

9. Practical tooling

What every locum GP ends up needing:

Cloud accounting that handles MTD for Income Tax (FreeAgent, QuickBooks, Xero, or a sole-trader-focused tool).
An expenses + mileage log (most accounting tools do this; a dedicated locum platform handles the regulatory categories properly).
An invoicing tool that produces clean PDFs and tracks delivery and payment.
A documents store with expiry tracking for DBS, indemnity, GMC, performer list confirmation, occupational health and revalidation evidence.
A revalidation portfolio (CPD, reflection, MSF, patient feedback, significant events).
A bookings calendar with cancellation terms baked in.

10. The first six weeks

A realistic timeline if you start setup today:

Week 1: register HMRC for Self Assessment, apply to performer list (England via PCSE), apply for indemnity membership.
Week 2 to 3: book occupational health, sort DBS through the application, gather two clinical references.
Week 3 to 4: confirm SD number with NHS Pensions, set up PCSE Online access, set up cloud accounting.
Week 4 to 6: performer list confirmation comes through, first sessions start, Form A flow begins.
End of week 6: first Form B goes in for the previous month's work.

If your performer list comes through faster, sessions can start sooner; if slower, hold the line.

FAQ

Do I have to pay Class 2 NI? Not compulsorily, since 6 April 2024, if your profits are above the Small Profits Threshold (£6,845 for 2025/26 and 2026/27). You still get a qualifying year for state pension automatically. Voluntary Class 2 at £3.65/week is available if your profits fall below the SPT.

Do I need a limited company? Not for sole-trader locum work. Many locum GPs never incorporate. Run the dividend-after-tax numbers for 2026/27 (now 10.75% ordinary, 35.75% upper) with an accountant before you assume Ltd is cheaper.

Can I start sessions before my performer list confirmation comes through? No. Off-list NHS primary medical services are unlawful. Wait for the confirmation email from the relevant body.

Do I need MTD for Income Tax in 2026/27? Only if your gross self-employed plus property income was above £50,000 in your 2024/25 Self Assessment. If you fall in scope you must be on compatible software with quarterly updates from 6 April 2026.

What is the difference between Form A and Form B? Form A is per session block, completed by you and signed by the practice. Form B is your monthly summary of all your Form As, generated through PCSE Online, with the contribution figures.

Is VAT relevant for me? Almost never. Clinical work to patients is VAT exempt under VAT Notice 701/57 regardless of turnover. The £90,000 registration threshold only applies to taxable supplies, so unless you do significant non-clinical work it is not in scope.

Sources

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