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Response to General Dental Council's consultation on 'Trusted and effective: a strategy for dental regulation 2026-2028'

Post date: 19/08/2025 | Time to read article: 8 mins

The information within this article was correct at the time of publishing. Last updated 19/08/2025

Overview of the consultation

Between July and August 2025, the General Dental Council sought views on their new proposed corporate strategy, 'Trusted and effective: a strategy for dental regulation 2026-2028'. More information can be found on the dedicated consultation page

Consultation 

About our proposed objectives and activities

To what extent do you agree that our strategic objectives are the right focus for the GDC, given the context in which we are operating?

  1. Strongly agree
  2. Somewhat agree
  3. Neither agree nor disagree
  4. Somewhat disagree
  5. Strongly disagree
  6. Don’t know

Please provide reasons for your answer:

Dental Protection welcomes the overall direction of the strategy and the GDC’s recognition of persistent issues that adversely impact upon the timely progression of cases around the Fitness to Practise processes and the climate of fear within the profession. The commitment to proportionality, collaboration, and support for registrants is encouraging.

However, many of the proposals remain high level and we believe that it would be beneficial for a clearer and a more detailed strategy to be provided on implementation, timelines, and measurable outcomes. One example we would like to draw out, is how the GDC proposes to implement its commitment to use the discretion which it already holds, in the absence of legislative change. If the GDC is to strengthen trust with the profession, it should clearly demonstrate how the tone and ambition of the strategy will be reflected in regulatory practice.

For each of the proposed strategic objectives, please tell us to what extent do you agree that the priorities we have outlined to support delivery will help us achieve the objective

Objective 1: Support dental professionals to provide the right care for their patients − to what extent do you agree that the priorities we have outlined to support delivery will help us achieve this objective?

  1. Strongly agree
  2. Somewhat agree
  3. Neither agree nor disagree
  4. Somewhat disagree
  5. Strongly disagree
  6. Don’t know

Please provide reasons for your answer:

We support the strategic objectives to adopt a more supportive and proportionate approach to regulation in order to enable dental professionals to provide the right care for patients. The experience of many professionals is heavily impacted by disproportionate delays in investigations, inconsistent communication, and unclear lengthy processes. Changing this experience, by providing consistent and clear messaging, would go a long way to build confidence in the regulatory process which in turn would improve understanding and trust and would minimise the perception of regulatory risk.

We consider that the strategy makes limited reference to key developments in dental practice which impact the delivery of safe care. The integration of digital technologies and the growth of cosmetic procedures are not referenced explicitly; these areas of practice are creating both new challenges and expectations for the profession and patients. Addressing these areas through clearer guidance and greater engagement with the sector would better support registrants to navigate fast paced developments.

We also note that the level of investment proposed for supporting professionals appears modest in comparison to other areas of the strategy and we would encourage the GDC to reflect on whether this might raise challenges in delivering on this objective.

Objective 2: Get the right people on the registers at the right time − to what extent do you agree that the priorities we have outlined to support delivery will help us achieve this objective?

  1. Strongly agree
  2. Somewhat agree
  3. Neither agree nor disagree
  4. Somewhat disagree
  5. Strongly disagree
  6. Don’t know

Please provide reasons for your answer:

We appreciate the recognition of delays and challenges in the registration process in the strategy, particularly for international applicants. We would ask for further clarity on how improvements will be delivered, what timelines are envisaged and how the outcomes will be measured.

Given the profession’s ongoing workforce pressures, and our organisation’s experience in supporting dental professionals from overseas, we would encourage the GDC to ensure that future processes are fair, transparent and well-communicated. We would also urge the GDC to focus on improved engagement with those who regularly advise registrants, to help ensure that changes to registration processes are both workable and proportionate.

Objective 3: Improve fitness to practise, maximising patient safety and reducing unintended impacts − to what extent do you agree that the priorities we have outlined to support delivery will help us achieve this objective?

  1. Strongly agree
  2. Somewhat agree
  3. Neither agree nor disagree
  4. Somewhat disagree
  5. Strongly disagree
  6. Don’t know

Please provide reasons for your answer:

We strongly agree that reforming the Fitness to Practise processes should be a priority and support the aim to reduce adversarial elements and perception with a focus on proportionality.

Currently, the proposed strategy does not provide enough detail on how these reforms will be implemented. From our perspective, delays in processes and investigations as well as a lack of clear triage mechanisms, remain a significant concern. Although outcomes themselves can be proportionate, the process itself can be unnecessarily long and stressful.

In 2023, our survey of members who had experienced a GDC investigation in the last 5 years, found that 82% said that they felt that it was the length of the investigation which impacted their mental health most during the course of the investigation. In addition, 75% said that if the process was completed more quickly it would have made it less stressful. Worryingly, over a quarter (28%) said they experienced suicidal thoughts during the investigation. More must be done to acknowledge, and address, these impacts.

The early stages of an investigation are particularly critical. From our experience, we would suggest enhanced training for those assessing concerns and drafting allegations. This would support the reduction in investigations continuing based on vexatious or spurious complaints and serious probity allegations being made without substance. It would also enable increased transparency in complaints handling and avoid vague allegations being pleaded in the absence of direct evidence. We also believe it would be beneficial to consider the introduction of structured, specialised support for registrants under investigation, including peer or wellbeing-focused resources.

Objective 4: Work collaboratively to speak up on, influence, and address issues that affect patients and the public − to what extent do you agree that the priorities we have outlined to support delivery will help us achieve this objective?

  1. Strongly agree
  2. Somewhat agree
  3. Neither agree nor disagree
  4. Somewhat disagree
  5. Strongly disagree
  6. Don’t know

Please provide reasons for your answer:

We support the GDC’s ambition to take a more outward-looking and collaborative approach and would be happy to continue working with colleagues to help achieve this.

It is our view that there are key areas where a more action is needed. One such area, as previously mentioned, is cosmetic dentistry; this area of clinical practice continues to present regulatory challenges due to confusion around scope of practice, risks from non-dental providers, and the potential for patient dissatisfaction through expectations not being met. This could be improved through clearer guidance for registrants, improved public awareness, and a more consistent regulatory position.

We would also encourage the GDC to give further consideration to the implications of digital technologies and AI tools in dentistry. As these tools become increasingly integrated into clinical practice, the GDC has an important role to play in setting expectations, updating standards, and engaging with the wider sector to ensure ethical and safe implementation.

Objective 5: Maximise the effectiveness of our people, our culture and our systems − to what extent do you agree that the priorities we have outlined to support delivery will help us achieve this objective?

  1. Strongly agree
  2. Somewhat agree
  3. Neither agree nor disagree
  4. Somewhat disagree
  5. Strongly disagree
  6. Don’t know

Please provide reasons for your answer:

We support the strategic aim to improve the internal culture and systems at the GDC.

To deliver on this objective, we believe the GDC should prioritise the training of staff involved in assessments and decision-making, ensuring that decisions are based upon robust investigation and evidence together with proportionate judgment. This would help mitigate delays and inconsistency in processes.

Do you have any other comments you would like to make on our high-level objectives or the activity designed to support their achievement that are not covered by your answer to the previous questions?

The GDC’s strategic direction and objectives are welcome, and their success will depend upon meaningful, transparent implementation. A delivery plan with clear milestones, timelines, and indicators of progress would be appreciated, in order to support the wider dental workforce’s understanding of how this activity will be achieved.

The GDC rightly acknowledges the climate of fear within the profession and the need for a less adversarial approach, to Fitness to Practise investigations. However, we consider that there is currently insufficient detail on how the proposed objectives will translate into tangible improvements in registrants’ day-to-day experience. It is particularly important that the GDC sets out how it will reduce unnecessary delays, improve transparency in case handling, and demonstrate proportionality.

We encourage the GDC to maintain regular, ongoing engagement with stakeholders – not just at the consultation stage, but throughout the delivery of its strategy. We also urge the GDC to ensure that feedback from registrants directly informs the implementation of its objectives.

Dental Protection is pleased to see the ambitions and objectives outlined in this proposed strategy; they are promising, and it is clear to see the GDC is moving in the right direction. We would be happy to support with further development, and implementation, wherever possible.

Our expenditure plans

Thinking about our expenditure plans, please tell us to what extent do you agree that you understand our explanations?

  1. Strongly agree
  2. Somewhat agree
  3. Neither agree nor disagree
  4. Somewhat disagree
  5. Strongly disagree
  6. Don’t know

Thinking about our expenditure plans, please tell us to what extent do you agree that the assumptions underpinning our plan make sense?

  1. Strongly agree
  2. Somewhat agree
  3. Neither agree nor disagree
  4. Somewhat disagree
  5. Strongly disagree
  6. Don’t know

Please provide reasons for your answers:

We recognise the GDC’s efforts to improve financial transparency and welcome the visibility of projected spending.

We note the budget for professional support is relatively small compared to other departments and we believe greater clarity could be provided on how financial decisions will support the delivery of strategic priorities and ensure registrants are adequately considered and supported.

Do you have any other comments you would like to make on our expenditure plans that are not covered by your answers to the previous questions?

None

Equality, diversity and inclusion

One of our aims when developing this strategy was to deliver on our commitment to ensure that equality, diversity and inclusion are central to our corporate purpose and strategy. We are seeking views on whether our commitment to equality, diversity and inclusion is clearly and appropriately expressed in this strategy.

We are also seeking to understand the extent to which our proposed strategy has the potential to positively or negatively impact on people with protected characteristics.

To what extent do our objectives clearly describe our commitment to equality, diversity and inclusion?

  1. Very clearly described
  2. Clearly described
  3. Somewhat clearly described
  4. Not very clearly described
  5. Not at all clearly described
  6. Don’t know

We would like you to consider whether our proposals have the potential to impact people based on their protected characteristics. Please note, you do not need to provide us with any information regarding your protected characteristics to answer this question. The protected characteristics identified by the Equality Act 2010 are:

  • Age
  • Disability
  • Gender reassignment
  • Marriage and civil partnership
  • Pregnancy and maternity
  • Race
  • Religion or belief
  • Sex
  • Sexual orientation

Please tell us about any impacts you think our proposals could have on people based on their protected characteristics:

We would encourage the GDC to develop and publish clear performance indicators to monitor disproportionality in referrals and outcomes based on protected characteristics, and to commit to independent audit or review of decision-making processes. This would build clear accountability structures into operational delivery.

About Dental Protection

Dental Protection is part of the Medical Protection Society (MPS), the world’s leading protection organisation for doctors, dentists, and healthcare professionals. MPS protects and supports the professional interests of more than 300,000 members around the world and is proud to have supported over 30,000 dentists and dental care professionals in the UK for many years.

Membership provides access to expert advice and support together with the right to request indemnity for complaints, investigations or claims arising from professional practice.

We are a mutual non-for-profit organisation and the benefits of membership of MPS are discretionary as set out in the Memorandum of Articles of Association. MPS is not an insurance company. 

About MPS

MPS is the world’s leading protection organisation for doctors, dentists and healthcare professionals with almost 300,000 members around the world.

Our in-house experts assist with the wide range of legal and ethical problems that arise from professional practice. This can include clinical negligence claims, complaints, medical and dental council inquiries, legal and ethical dilemmas, disciplinary procedures, inquests and fatal accident inquiries.

MPS is not an insurance company. We are a mutual non-for-profit organisation and the benefits of membership of MPS are discretionary as set out in the Memorandum of Articles of Association.

Contact

Should you require further information about any aspects of our response to this consultation, please do not hesitate to contact us.

Megan Bennett
Policy and Public Affairs Manager
[email protected]

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