Why locum nurses and midwives should answer the NMC consultation

The Nursing and Midwifery Council is rewriting the Code for the first time since 2015 and rebuilding revalidation for the first time since 2016. Council approved a 12-week public consultation on 21 July 2026, and the NMC says it opens in late September and runs through to December, with the findings going back to Council in May 2027. If you work as a locum, on the bank or through an agency, the revalidation half of that consultation lands on the parts of the process that are already awkward for you: who confirms you, how you evidence practice hours spread across several employers, and where your feedback comes from.

What the NMC is consulting on

Two things at once: a new draft Code, and a refreshed revalidation process.

On the Code, the NMC's announcement of 22 July 2026 sets out proposals strengthening expectations on anti-discrimination, including anti-racism, bias and stigma; public protection and safeguarding, including inappropriate access to patient records; working cultures and the wellbeing of registrants; professional accountability; conduct outside professional practice; the safe use of digital technologies including AI; and public health and health inequalities.

On revalidation, the NMC lists five areas: a clearer statement of what the three-yearly process is for; a strengthened role for confirmers and reflective discussion partners; embedding the new Code and the Standards of Proficiency in the process; automatic 12-week extensions for professionals with a valid reason; and doubling the number of registrants selected for verification, with that selection made fully at random.

The regulator describes the wider period as "a year of significant transition" in its 2025/26 annual report, published on 15 July 2026. It also set out fitness to practise process improvements on 9 September 2026 and is recruiting four new Council members. This is a regulator changing several things at the same time, which is a reason to read the consultation document rather than the headlines.

The confirmer proposal is the one to read closely

Confirmation is the step where someone who has sight of your practice signs to say you have met the requirements. If you hold a substantive post, that person is usually your line manager and the request is routine. If you have worked in nine settings over three years, there is no obvious candidate, and choosing one is a negotiation with whichever manager saw enough of your work to sign honestly.

The NMC proposes to strengthen that role rather than soften it. Nursing Times, reporting on the same Council decision on 22 July 2026, said the proposals give line managers a larger part in confirmation. The NMC's own announcement does not use that framing, so the detail is worth checking in the consultation document rather than taking second hand. Either way, asking more of confirmers asks most of the registrants whose confirmer only ever saw a slice of their practice. The same applies to the reflective discussion partner you talk your written reflective accounts through with.

If the redesigned process assumes a single employer and a stable line manager, it will work badly for a large part of the temporary workforce. That is precisely the kind of thing a consultation exists to hear about, and it will only be heard if locum, bank and agency registrants write it down.

Practice hours still have to be added up across employers

Nothing in the consultation proposes changing the hours totals, which remain as they are.

Alongside the hours sit 35 hours of CPD, of which 20 must be participatory, five pieces of practice-related feedback, five written reflective accounts, a reflective discussion, a health and character declaration, indemnity cover and confirmation. Fall short on hours and the route back is a return to practice programme or the Test of Competence, which is a much larger undertaking than keeping a record as you go.

The online application opens 60 days before your revalidation date. Sixty days is enough time to fill in a form. It is not enough time to reconstruct three years of shifts across a dozen organisations, chase five people for feedback and write five reflective accounts from memory. A plain walkthrough of the current requirements is in the guide to NMC revalidation.

A doubled verification sample, drawn at random

Verification is the check the NMC runs on a sample of applications, asking for the evidence behind the declaration. The proposal doubles the size of that sample and makes selection fully random.

For a registrant with one employer, being selected means one phone call to one office. For a locum, it means producing dated records from every organisation where the hours were worked, feedback that can be traced to real placements, and reflective accounts that match the dates. Random selection also removes the quiet assumption that an uncomplicated registration is unlikely to be picked. If the sample doubles, the practical question is no longer whether your evidence would survive a check but how long it would take you to assemble it.

Keeping hours, feedback and reflective accounts in one place as the work happens, rather than at the end of a cycle, is what a professional record is for.

What is not changing yet

Nothing in this consultation changes the revalidation you are completing this year. Nursing Times reported on 22 July 2026 that the eight current requirements stand for 2026. The same report put the new Code going live in October 2027 and the updated revalidation process from April 2028. Those dates come from the trade press: the NMC's own announcement did not carry them, and the regulator has not confirmed them, so treat them as an outlet's reporting rather than settled policy.

One related piece of context: the NMC's work on advanced practice standards has slipped, with the consultation moved to the 2027/28 financial year and advanced practitioner requirements folded into the Code and revalidation reviews instead. If you practise at an advanced level, this consultation is where those expectations are now being shaped.

On money rather than process, the registration fee rises to £143 from 1 October 2026, which is covered separately in the NMC changes for 2026.

What to do before the consultation closes in December

• Respond. The consultation runs for 12 weeks from late September to December 2026 and is listed on the NMC's consultations page. A response describing how confirmation actually works when your hours came from six different organisations is worth more than a general comment.
• Say what a workable confirmer rule looks like for you. If the answer is a lead nurse at the organisation where you worked most hours, or an agency clinical lead, write that.
• Name your next confirmer now rather than in the 60-day window, and tell them before you need the signature.
• Log hours by organisation as you work, with dates and scope of practice, so a random verification is a retrieval job rather than an investigation.
• Ask for feedback at the end of each placement, while the people who worked with you still remember the shift.

Sector-specific detail on how these requirements sit alongside self-employed record keeping is on the pages for locum nurses and locum midwives. For anything about your own fitness to practise or an individual case, the regulator's guidance and your defence organisation come first.

Sources

• NMC to launch landmark consultation on new Code and Revalidation process (Nursing and Midwifery Council, 22 July 2026)
• Green light for 'landmark' consultation on new Code and revalidation (Nursing Times, 22 July 2026)
• Revalidation: practice hours requirement (Nursing and Midwifery Council, accessed September 2026)
• Consultations (Nursing and Midwifery Council, accessed September 2026)
• News and updates (Nursing and Midwifery Council, accessed September 2026)
• NMC sets out programme of work to support nursing and midwifery practice (Nursing and Midwifery Council, 18 February 2025)