What a locum PA should have in order by 13 December 2026

From 13 December 2026 it becomes a criminal offence to practise as, or use the title of, a physician associate or anaesthesia associate in the UK without GMC registration. The GMC advised applying by 14 September 2026 for a guaranteed decision before that date, and 14 September was four weeks ago. The next two months are about verification rather than application, and about the part of regulation that arrives quietly afterwards: a named supervisor, a locally written scope, and an appraisal habit nobody else will keep for you.

The window for a guaranteed decision has already closed

NHS Employers put out a reminder on 4 September 2026. The two-year transition that began with GMC regulation on 13 December 2024 ends on 13 December 2026, and anyone not registered by then must stop working under the title. Employers are told to check the GMC register for their current PAs and AAs, and to speak to anyone who has not registered or declines to apply.

The same notice repeats the GMC's position on timing: applications submitted after 14 September 2026 cannot be guaranteed a decision before the deadline. The mechanics were covered here in May, in the piece on the PA and AA registration deadline, and they have not changed.

What has changed is the practical position. If you applied late, your decision may still arrive in time, but plan as though it might not, and tell the practices, trusts and agencies that book you now rather than in the second week of December. If you have not applied, apply anyway, but do not take bookings after 13 December assuming you will be registered by then. Employers are being told to check the register, so shifts will start to depend on your entry there.

What Leng recommended, and what has actually moved

The Leng review was published on 24 July 2025. It recommended renaming physician associates as physician assistants and anaesthesia associates as physician assistants in anaesthesia; that they should not manage undifferentiated patients except within clearly defined national clinical protocols; that each should have a named supervisor who is also their line manager; standardised national clothing, lanyards and badges; at least two years of secondary care experience for newly qualified PAs before a primary care or mental health trust role; formal credentialling to enable prescribing; and access to advanced roles one pay band higher.

NHS England's response, last updated on 15 August 2025, commits to a medium-to-longer-term implementation plan including national clinical protocols and professional standards. It sets no deadlines and gives no detail on titles, scope, undifferentiated patients, supervision or badges.

The title change needs legislation. The Department of Health and Social Care consulted on the draft General Medical Council Order 2026, which reforms how the GMC regulates doctors, PAs and AAs and carries the Leng recommendations on titles. GOV.UK records it as opening on 24 March 2026 and closing on 21 July 2026 after a four-week extension, with no government response published. Until there is one, your registered title is physician associate, and that is the title the December offence attaches to.

None of this has reached the page many employers read first: NHS England's guidance on PAs and AAs, from 13 December 2024, still says only that PAs "aren't legally required to register until December 2026".

Scope is local, which is the problem with locum work

NHS Employers updated its physician associate page on 18 August 2026. It describes postgraduate training of at least 90 weeks, around 3,200 hours split evenly between theory and clinical practice, on top of an undergraduate degree. PAs work under a named senior doctor, a consultant or a GP, within a scope of practice decided locally. They cannot prescribe or administer medicines under patient group directions, though they may administer under patient-specific directions where local governance allows.

The BMA's supervision guidance, updated on 19 January 2026, is tighter than most job descriptions. The supervisor must be named, immediately available, and a consultant, a GP or an autonomously practising SAS doctor: doctors in training and locally employed doctors are not suitable. It sets out a traffic-light system: green tasks are safe to undertake, amber tasks require direct observation and demonstrated competency first, red tasks are unsafe even with supervision. Patients are to be discussed with the supervising doctor daily and reviewed in person where necessary, and the supervisor keeps overall responsibility for delegated work.

For a salaried PA in one department, that is a conversation with one consultant. If you work a bank list or three practices, it is a different green, amber and red list in each place, agreed with a different doctor, and you are the only person who sees them all. Get the scope in writing before the first shift, and keep the supervising doctor's name against every booking in records you own, not in an email account you will lose.

The appraisal habit starts before the revalidation rules exist

GMC registration brings the appraisal culture that locum doctors already live with, and it arrives before the machinery is built. The GMC's guidance on future revalidation for PAs and AAs says it must develop and consult on rules before individual revalidation dates can be set, and that in the meantime registered PAs and AAs should have annual appraisals and collect and reflect on supporting information.

That is easy advice for someone with one employer and an appraisal lead. It is harder if your year is forty bookings across a dozen organisations, none of which holds your record. The file you want before the first cycle is announced is dull and continuous: where you worked and in what setting, case mix, significant events and what changed after them, feedback, CPD with a line of reflection rather than a certificate alone, and the supervision arrangement for each placement. If you would rather that lived in one place than in a folder of PDFs, Sessional keeps a professional record with reflections and a CPD evidence store that holds each certificate with your note about it.

What to check before 13 December

• Look up your own entry on the GMC register this week, and check the name on it matches your ID documents and your invoices. Employers are checking the register, not the CV.
• If you applied after 14 September 2026, treat December as uncertain. Tell whoever books you, and agree what happens to shifts after the 13th.
• Ask for the written scope of practice and the supervising doctor's name before each booking, and keep both. Scope is set locally, so it changes with the employer.
• Record who supervised each shift and how the daily discussion happened. No employer will assemble that for you.
• Start the supporting information file now rather than when the revalidation rules appear. There is more for physician associates on the profession page.
• If you supervise or book PAs as a GP or hospital doctor, check the register entry yourself and read the BMA guidance on who may supervise. Responsibility for delegated work stays with you.

Sources

• End of GMC transition period for PAs and AAs (NHS Employers, 4 September 2026)
• Physician associates (NHS Employers, last updated 18 August 2026)
• The Leng review: an independent review into physician associate and anaesthesia associate professions (GOV.UK, 24 July 2025)
• Reforming the General Medical Council legislative framework (GOV.UK, consultation 24 March to 21 July 2026)
• Response to the recommendations of the independent review of physician associates and anaesthesia associates (NHS England, last updated 15 August 2025)
• Update on physician associates and anaesthesia associates ahead of GMC regulation (NHS England, 13 December 2024)
• Guidance for the supervision of Medical Associate Professions (BMA, updated 19 January 2026)
• Future revalidation for physician associates and anaesthesia associates (GMC, page undated)