PA and AA mandatory GMC registration: 13 December 2026

Will Stocker, founder8 May 20268 min read

If you work as a Physician Associate (PA) or Anaesthesia Associate (AA) in the UK, or if you book one for locum shifts, the long talked-about regulatory cliff edge now has a real date on it. From 13 December 2026, practising as a PA or AA without GMC registration becomes a criminal offence under the Anaesthesia Associates and Physician Associates Order 2024.

Below: the exact rules, the bits that have not yet started, and what the change means for locum bookings.

What changes on 13 December 2026

Statutory regulation of PAs and AAs by the General Medical Council started on 13 December 2024, and the GMC opened its register for applications on 16 December 2024. The legislation built in a two-year transition window during which registration is optional, so existing PAs and AAs can keep working while they get on the register.

That window closes at the end of 13 December 2026. After that date, Article 19(1)(b) of the Order takes effect, making it an offence to use the title "physician associate" or "anaesthesia associate", or to practise in those roles, without being on the GMC register.

The first 250 PAs and AAs joined the register in early 2025, and the GMC has been writing to all PAs and AAs on the previous voluntary registers throughout 2025 and 2026 inviting them to apply.

Who is affected

Two professions, one regulator, one framework:

Physician Associates (PAs) work across primary and secondary care under doctor supervision.
Anaesthesia Associates (AAs) work under anaesthetist supervision in theatres and critical care.

Both fall under the same statutory regulation, the same Order, and the same GMC register. The deadline is identical for both groups.

The old Physician Associate Managed Voluntary Register (PAMVR) at the Faculty of Physician Associates (RCP) closed to new entrants on 16 December 2024 when GMC regulation began, and the FPA itself closed on 31 December 2024. Final PAMVR membership stood at 5,092 PAs and 178 AAs. The PAMVR remained searchable until 31 March 2025; after that, the GMC register is the single source of truth.

Being on the old PAMVR does not automatically transfer you across. Every PA and AA must apply to the GMC themselves.

How to register now

To register as a PA, the GMC requires you to evidence:

A pass in both parts of the Physician Associate Registration Assessment (PARA) or its predecessor the Physician Associate National Examination (PANE), within the last 24 months. The PANE was renamed PARA in September 2025; the RCP runs the assessment on behalf of the GMC. Both parts must be passed within 18 months of each other.
Completion of an approved UK PA programme based on the Competence and Curriculum Framework for the Physician Assistant (2012) or the Physician Associate Curriculum (2023). International applicants need their qualification assessed and accepted by the GMC first.
A Disclosure and Barring Service (DBS) check and the standard fitness to practise declarations.

Anaesthesia Associates have an equivalent registration route via approved AA training programmes.

If you trained outside the UK, you go through the international PA registration route at the GMC, which assesses your qualification before you sit PARA.

Fees

The GMC application and first-year registration fee for PAs and AAs is £325, set under the General Medical Council Registration Fees Regulations 2025 (effective 1 April 2025). This is not the same as the doctor ARF; it is a separate, lower fee for associate registration. PAs and AAs pay this annually on the anniversary of their registration date.

The PARA exam itself is paid separately to the RCP.

Reference numbers and ID

PAs and AAs receive a seven-digit GMC reference number prefixed with the letter "A" (for "associate"), for example A1234567. This is deliberately different from doctors' purely numeric reference numbers, so patients, employers and insurers can tell at a glance who they are dealing with.

GMC registered PAs and AAs are required to use their full registered name and reference number when introducing themselves in clinical contexts, in line with GMC guidance on identification.

For locum agencies and bookers, the A-prefix number is the new compliance anchor: it goes on shift bookings, pay schedules, indemnity certificates and patient records, the same way a doctor's GMC number does today.

What hasn't started yet (revalidation)

Revalidation for PAs and AAs is not yet live. The GMC has been consulting on the rules, the supporting information requirements, and the role of recommenders throughout 2025, with implementation expected to follow.

Three things to know:

No exam at revalidation. The GMC has confirmed that the model will not routinely require PAs or AAs to sit an exam.
Annual appraisals matter now. Even before revalidation formally starts, registered PAs and AAs are expected to begin annual appraisals and to collect supporting information (CPD, reflective practice, quality improvement, significant events, feedback).
At least 12 months' notice. The GMC has committed to giving registrants at least 12 months' notice of their first revalidation submission date once dates are set.

On the designated body and responsible officer side: doctors revalidate through their designated body and a responsible officer (RO). For PAs and AAs, the equivalents are still being finalised. PA and AA "recommenders" are likely to sit outside the existing RO Regulations, with a similar but separately specified role. Practically, most NHS-employed PAs will align with their employing trust's revalidation infrastructure, and primary care PAs with a primary care designated body.

Indemnity for PAs and AAs

GMC registration carries the same indemnity expectation as for doctors: you must have adequate and appropriate insurance or indemnity cover for the full scope of your practice.

What that looks like in practice:

NHS-employed PAs and AAs: covered by NHS Resolution schemes. Trust-employed staff fall under the Clinical Negligence Scheme for Trusts (CNST). PAs working in NHS general practice are covered by the Clinical Negligence Scheme for General Practice (CNSGP) for clinical negligence liabilities arising from incidents on or after 1 April 2019. Supervising GPs are also indemnified under CNSGP for supervision-related claims involving PAs.
Locum, agency, or non-NHS work: CNSGP and CNST do not cover non-NHS clinical negligence, regulatory matters, GMC defence, complaints handling, or "Good Samaritan" acts. Personal cover is needed. The MDU, MPS and MDDUS now offer PA-specific membership products that wrap occurrence-based or claims-made cover with regulatory and inquest support.

If you are a locum PA, treat indemnity the same way locum doctors do: state-backed cover for NHS clinical work, personal medico-legal membership for everything around it.

Scope of practice: what PAs still cannot do

Two limits matter for booking decisions in 2026:

No prescribing. PAs and AAs cannot prescribe. The Order regulating the professions did not include prescribing rights, and additional legislation would be required to change that.
No ionising radiation requests. PAs cannot request ionising radiation (for example X-rays, CT). The RCP and the Royal College of Radiologists are working on best-practice guidance for how PAs request imaging via a supervising clinician.

The Leng Review, published 16 July 2025 and accepted in full by Government, sets out 18 recommendations that will further shape scope. Headline points relevant to bookings:

The role title is to be renamed from "physician associate" to "physician assistant".
Newly qualified physician assistants should gain at least two years' secondary care experience before moving to primary care.
Physician assistants should not see undifferentiated patients except within clearly defined national clinical protocols.
A formal certification and credentialling pathway will be developed, which could in future unlock prescribing of certain medicines and ordering of non-ionising radiation, but only after further legislation and training standards are in place.

Impact on locum work

If you book or work locum PA or AA shifts, the practical changes from 13 December 2026 are:

GMC registration is non-negotiable. No A-prefix GMC number, no shift. Agencies and direct bookers must check the GMC register the same way they check it for locum doctors today.
Title use becomes a criminal offence without registration. This is not just a contractual or NHS-employer rule; it sits in primary legislation.
Compliance pack expands. Expect agencies to require: GMC registration certificate, PARA / PANE evidence, DBS (with update service), occupational health and immunisation records, two clinical references, and proof of personal indemnity for non-NHS work.
Supervision must be documented. The Leng Review and BMA scope guidance both pull supervising doctors deeper into the audit trail. Bookings should record who the named supervisor is for each shift.
Annual appraisals start now, even before revalidation. Locum PAs without a single fixed employer should be lining up an appraiser through their primary contracting body or a recognised appraisal service so that, when revalidation goes live, the supporting information is already there.

If you are a PA or AA still on the fence about applying, the GMC's repeated guidance has been: apply now.

FAQ

I was on the PAMVR. Do I still need to apply to the GMC? Yes. PAMVR membership did not transfer automatically. The GMC has invited former PAMVR registrants but the application is still on you.

Will I have to sit PARA again to register if I qualified years ago? You need to evidence a pass in PARA or its predecessor PANE within the last 24 months, with both parts passed within 18 months of each other. Older qualifying routes are handled case by case under GMC international and transitional guidance.

Can I prescribe once I'm GMC registered? No. Registration alone does not grant prescribing rights. Prescribing for PAs and AAs would require further legislation, which is not in place.

What's the difference between the GMC ARF for doctors and for PAs? The PA / AA fee is set separately under the 2025 Fees Regulations and is currently £325 for first year and annual retention. Doctors pay a different (higher) ARF.

What if I work only occasional locum shifts after December 2026? You still need GMC registration. There is no "low volume" exemption. You also still need adequate indemnity covering every shift.

Sources

physician-associateanaesthesia-associategmcregulationlocum-compliance

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