Regulation

What the 2026 NMC changes mean for locum and agency nurses

Will Stocker, founder7 min read

2026 is the busiest year the NMC has had in a decade. Five things are landing or moving at once:

  1. The annual registration fee rises from £120 to £143 from 1 October 2026. First increase in 11 years.
  2. NMC Online has been replaced by MyNMC, a new portal that went live on 10 February 2026. Multi-factor authentication is now required.
  3. The Code is being refreshed. A formal public consultation is expected from September 2026, with the new Code due to publish in October 2027.
  4. Fitness to practise rules are being reformed, with new rules expected to come into force from October 2026 once Privy Council and Parliament have laid them.
  5. Practice hours, CPD, reflective accounts, indemnity and confirmer rules stay as they are. Same eight requirements, same three-year cycle. Don't let anyone tell you otherwise.

If you are a locum, bank or agency nurse, only points 1 and 2 will hit you in 2026. The rest are background changes that matter when your portfolio is next due, not today.

The new fee

The exact numbers, straight from the NMC press release of 28 April 2026:

  • Old fee: £120 per year
  • New fee: £143 per year
  • Increase: £23 per year, or £1.92 per month before tax relief
  • Effective: applies to fee notices sent on or after 1 October 2026, subject to Parliamentary approval

If your renewal lands before 1 October 2026, you pay £120. If it lands on or after that date, you pay £143. The NMC pointed out that had the fee tracked inflation since 2015, it would already be sitting around £168, so this is still below RPI.

You can claim tax relief on the fee through HMRC. For most nurses on the basic rate that knocks roughly £28 off the £143, leaving the real cost around £115 per year. If you are a locum trading through a limited company you can put the fee through the company as a business expense instead.

Revalidation in plain English

Nothing in the eight revalidation requirements has changed for 2026. They are:

  1. Practice hours: at least 450 hours over three years, in a role that uses your nursing, midwifery or nursing associate skills. Direct care, management, teaching and service development all count.
  2. CPD: 35 hours over three years, of which at least 20 must be participatory. Participatory means you interacted with at least one other professional. A study day, a workshop, a clinical supervision session, a multidisciplinary meeting all count.
  3. Practice-related feedback: five pieces. Patient thank-you cards, team feedback, complaints, audit results.
  4. Written reflective accounts: five, each linked to one or more parts of the Code. They can reflect on your CPD, your feedback or an event in practice. Use the NMC mandatory form. Do not name patients or colleagues.
  5. Reflective discussion: one conversation with another NMC registrant, signed off on the NMC form.
  6. Health and character declaration.
  7. Professional indemnity arrangement. More on this below.
  8. Confirmation from a suitable person.

Nursing associates revalidate on exactly the same cycle and exactly the same hours. 450 practice hours, 35 CPD, three years. The NMC is clear that "the requirements are the same for everyone on the NMC register".

Locum tip: keep your portfolio rolling. If you bounce between trusts and agencies, log every shift with date, hours, role and employer. When revalidation lands you do not want to be reconstructing 36 months of work from payslips.

Confirmer rules: clearing up the Band 7 myth

The biggest myth in agency staff rooms is "your confirmer must be a Band 7 or above". It is wrong. The NMC has never required a grade. What it requires is a hierarchy:

  1. First choice: your line manager. They do not need to be NMC-registered. They do not need to be a particular band.
  2. If you do not have a line manager, or yours cannot confirm: an NMC-registered nurse, midwife or nursing associate.
  3. If neither is available: another regulated UK healthcare professional, for example a GMC-registered doctor, a GPhC pharmacist, an HCPC-registered paramedic or physiotherapist.

What the NMC will not accept:

  • A family member.
  • A close friend.
  • Anyone where there is a clear conflict of interest.

For locums and agency nurses this matters. If you work mostly through an agency, your "line manager" is usually the senior nurse on the ward where you do most shifts, or the agency clinical lead if they hold an NMC pin. If you are a self-employed practice nurse, the practice manager or the lead GP can confirm.

One more point that saves people a lot of effort: your confirmer can be the same person as your reflective discussion partner, as long as that person is an NMC registrant. Combine the two conversations into one meeting and you have ticked two requirements with a single hour. If they are not on the NMC register you must do the reflective discussion separately first, with someone who is.

Dual registration

If you hold dual registration, the practice hours stack. They do not blend.

  • Nurse and midwife: 900 hours total, split 450 hours of nursing and 450 hours of midwifery. You cannot pool them.
  • Nurse and nursing associate, or midwife and nursing associate: 900 hours, again 450 in each part of the register.
  • Nurse, midwife and nursing associate: 1,350 hours, 450 in each.

This is a trap a lot of dual-registered locums fall into. If you spent the last three years working as a midwife and barely picked up any nursing shifts, you might have 800 midwifery hours and 100 nursing hours. That fails revalidation for the nursing part of the register, even though you are well over the 450 single-registration figure overall.

The CPD requirement does not multiply. You still only need 35 CPD hours total, but the NMC expects them to be relevant to all parts of your registration. A pure obstetric workshop will not cover your nurse pin if you also work as a school nurse.

Return to practice

If your hours fall too low, the NMC's readmission standards say you must complete an approved Return to Practice programme or pass the Test of Competence. The thresholds:

  • Fewer than 450 hours in the last three years, and
  • Fewer than 750 hours in the last five years

If you fall below both, RtP or the Test of Competence is mandatory. If you cleared 750 hours over five years, even with a recent gap, you can usually apply for readmission directly.

Indemnity for locums and agency staff

Professional indemnity (PII) is one of the eight revalidation requirements, and it is also a legal duty under the Nursing and Midwifery Order 2001 as amended in 2014. You must have appropriate cover whenever you practise.

What counts as appropriate:

  • NHS substantive or bank work: your trust indemnity covers you for that work. Confirm in writing if you are unsure.
  • Agency work: check your agency policy. Most reputable agencies carry vicarious indemnity, but the cover only applies when you are working a shift booked through them. Off-book or "favour" shifts are not covered.
  • Locum or self-employed: you must arrange your own. RCN, Unison and the RCM include PII as part of membership. Independent policies are also available from MDU, MPS and brokers like Towergate.
  • Private aesthetic, occupational health or expert witness work: your NHS indemnity does not cover this. You need a separate policy.

You do not have to upload evidence to the NMC. You declare you have appropriate cover when you submit revalidation. They can audit, so keep the certificate or membership letter.

FAQ

Will my next renewal automatically charge £143? Only if your fee notice is sent on or after 1 October 2026. Direct debits issued before that date will still be at £120.

My old NMC Online login does not work. NMC Online closed on 6 February 2026 and was replaced by MyNMC on 10 February 2026. Go to the NMC website, click "Sign in to MyNMC", set up multi-factor authentication and your account will migrate.

Has the Code changed? Not yet. The current Code is still the 2015 version. The NMC plans a full public consultation from September 2026, with the modernised Code published in October 2027. There is nothing new to comply with this year.

I work two days a week. Can I still revalidate? Yes, as long as you clear 450 hours over three years. That is roughly seven hours per week on average. Any work that uses your registered skills counts.

Can my husband, who is a doctor, be my confirmer? No. Spouse counts as a close personal relationship, which the NMC treats as a conflict of interest, even if he is GMC-registered. Use the senior partner at the practice, your clinical lead at the agency, or another colleague.

What about V300 prescribing? No NMC changes to the V300 standards have been announced for 2026. The Standards of Proficiency for Nurse and Midwife Prescribers from 2018 are still in force.

I missed my hours. Am I struck off? No. You drop off the register and have to apply for readmission. If you are below both 450 in three years and 750 in five years, you complete an RtP programme or the Test of Competence first.

Sources

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