Between 2 June 2026 and 31 August 2026, the General Dental Council (GDC) consulted on a new Framework for Professionalism that would replace the current Standards for the Dental Team with a more modern, accessible and flexible approach.
Dental Protection welcomes the opportunity to respond to this GDC consultation and our complete submission response is outlined below.
Click here to view the GDC's consultation document on the proposed Framework for Professionalism
Consultation questions
The Principles of Professionalism
1. To what extent do you agree or disagree that the role of the Principles is clear?
Please explain your answer:
The Principles are clear and align with the previous Standards.
2. To what extent do you agree or disagree that the Principles capture the key areas of professionalism in dentistry?
Please explain your answer:
The proposed Principles are too heavily weighted toward defining minimum regulatory compliance rather than explaining the true nature of professional and ethical practice.
A professional healthcare framework should encourage registrants to excel, yet there is currently no explicit reference within the Principles that strive for the highest standards of clinical excellence or pursuing the best possible outcomes for patients.
Furthermore, true professionalism requires an absolute commitment to putting the interests of the patient above any other personal, financial or business interests. While patient interests are referenced in the lower-level Expectations, it must be elevated to a core, explicit element of the Principles themselves.
The proposed Principle to ‘Maintain trust in the profession’ should also more clearly reflect that professional standards apply to conduct both within and outside professional practice. While this concept appears elsewhere in the proposed Framework, it is not sufficiently evident at the level of the Principles themselves, despite being an area where registrants often seek greater clarity.
Similarly, the Principle to ‘Practise safely and effectively’ should explicitly emphasise the requirement to update and maintain professional knowledge and skills, rather than focusing primarily on keeping up to date with guidance and legislation.
It is also a significant omission that the word ‘ethical’ does not feature anywhere within the Principles. Professionalism in dentistry is fundamentally built upon an ethical framework and without this explicit language the proposed Principles lack a defining area of healthcare professionalism.
3. To what extent do you agree or disagree that the Principles, when applied by dental professionals, will help maintain public and patient safety?
Please explain your answer:
While the proposed Principles provide a baseline that will help maintain patient and public safety, their effectiveness is compromised by the lack of an explicit expectation of ethical conduct. For a regulatory framework to protect the public effectively, it must acknowledge that clinical safety and ethical conduct are inextricably linked.
As currently drafted, a registrant who is unfamiliar with the wider expectations of healthcare ethics and relies solely on the literal wording of the Principles may not appreciate that ethical duties are a fundamental component of professional practice.
By omitting ethical terminology and framing from this high-level part of the framework, it risks creating a regulatory blind spot in which technical compliance is prioritised over patient welfare.
Professional Guidance
4. To what extent do you agree or disagree that the criteria for Professional Guidance are clear?
Please explain your answer:
We do not consider that the proposed criteria for Professional Guidance are clear, as the structure is overly fragmented and creates potential ambiguity for registrants. The proposed Framework currently relies on a complex network of digital links branching off from the initial page, which complicates navigation and compromises clarity. Because each principle uses the phrasing that a dental professional is expected to act in a certain way, it fails to clearly distinguish between those instances where a registrant must follow guidance without exception as opposed to those where professional discretion applies.
To ensure absolute compliance and clarity, the precise obligations should be set out in detail within a single, easily accessible location rather than forcing users to navigate external documents and hyperlinks.
We also note that the various guidance documents referenced within the proposed Framework are not consistent in their layout and structure. Given the intention is to create a clear framework, we would encourage the General Dental Council to undertake a comprehensive review of supporting guidance rather than relying solely on light-touch amendments.
Finally, the supporting materials are not as helpful as they could be. The current use of various case study stories fails to sufficiently clarify the practical application of the guidance and requires thorough revision. The specific criteria used to justify issuing new Professional Guidance is also not clear, particularly the second point, which creates a circular rationale by stating the General Dental Council will provide guidance when it is the body responsible for doing so.
5. In addition to the areas listed above, are there any other aspects of professional practice or conduct that you think meet the criteria for the GDC to issue Professional Guidance?
We believe the General Dental Council should consider developing guidance on the professional expectations associated with the use of artificial intelligence in dentistry.
The proposed Expectation that dental professionals should understand their responsibilities when using technology to support practice is welcome, but it remains broad. As AI becomes increasingly used to support clinical practice, communication, administration and practice promotion, registrants would benefit from greater clarity about how the existing Principles and Expectations apply when using it.
In particular, the General Dental Council should consider clarifying expectations concerning professional accountability, the continued exercise of independent professional judgement, appropriate scrutiny of AI-generated information and the need for registrants to understand the limitations of the systems they use. This would help registrants use emerging technology appropriately while maintaining patient safety and public confidence.
We recognise that AI is developing rapidly and that overly detailed guidance could quickly become outdated. Any guidance should therefore focus on enduring professional expectations and could be supplemented by supporting material that is updated as the technology develops.
The Expectations
6. To what extent do you agree or disagree that the purpose of the Expectations is clear?
Please explain your answer:
We have concerns in relation to the clarity and application of the Expectations, specifically the statement indicating that “it is important to recognise that this is not a complete list”. While we understand that the General Dental Council intends to develop a fluid and adaptable framework that can evolve alongside changing professional landscapes, leaving the Expectations open-ended introduces regulatory risk.
Our previous experience indicates that while a framework may be designed to support flexible professional judgement, the actual application of these standards becomes far more rigid when a registrant faces a fitness to practise investigation. In a contested regulatory hearing, an open-ended framework can easily be used as a tool to allege misconduct.
By stating the list is incomplete, the proposed Framework introduces unnecessary ambiguity for dental professionals. To ensure fairness and a transparent regulatory environment, the proposed Framework should be more prescriptive.
7. To what extent do you agree or disagree that the Expectations themselves are clear?
Please explain your answer:
The Expectations are clear on their own, but the proposed Framework does not explain the practical difference between what a registrant ‘must’ do versus what is simply an ‘expectation’. This distinction is vital for registrants to understand their exact regulatory duties, especially since the document states this is not a full list.
Additionally, the text needs to be much more concise. Many of the points are verbose and could be expressed more simply to make them easier to read and understand.
Some Expectations could also be more clearly expressed. For example, the Expectation to ‘treat patients as individuals and not make assumptions about them based on how they look or their background’ seems narrower than the broader professional obligation to ensure patients are not discriminated against and that a registrant’s personal beliefs do not impact upon the professional relationship or care provided. Similarly, terminology such as ‘personal and professional scope of practice’ lacks clarity and risks creating confusion where simpler wording would suffice. The cumulative effect of this unnecessary complexity may undermine understanding, particularly within a profession comprising diverse backgrounds.
8. To what extent do you agree or disagree that the Expectations cover the areas in which the regulator should set expectations for registrants?
- Neither agree or disagree
Please explain your answer:
The current draft of the Expectations contains ambiguities that require clarification before implementation.
In particular, the Expectation regarding a registrant's ‘life both inside and outside work’ is unclear. As currently worded, it implies the General Dental Council will only regulate personal conduct that directly impacts clinical trust or a patient's willingness to seek oral healthcare. However, the General Dental Council’s past behaviour demonstrates that its investigations have routinely related to personal misconduct that is unrelated to clinical delivery or healthcare access.
If the regulator intends to maintain an interest in all aspects of personal conduct, this must be explicitly articulated to avoid doubt. Conversely, if the scope is restricted to clinical trust, that should also be made clear.
Further, because the General Dental Council states these Expectations will be used during panels to determine where a professional has ‘fallen short of the Principles’, leaving them as an open-ended and illustrative list creates regulatory uncertainty for registrants. For the sake of fairness and transparency, the proposed Framework must provide a complete list of expectations rather than leaving the parameters open to subjective interpretation.
The Supporting Material
9. To what extent do you agree or disagree that the purpose of Supporting Material is clear?
- Neither agree or disagree
Please explain your answer:
We support the principle of using supporting material to guide registrants, however, the content itself needs to be clearer, more comprehensive and consistent to achieve its stated purpose. While the overall intent behind these resources may be clear to some, specific elements such as the provided ‘Stories’ are ambiguous and fail to adequately clarify the underlying guidance.
In addition, we have reservations regarding how the supporting material will function in practice. To allay these concerns, it is important that the General Dental Council adheres to its stated aim that the supporting materials will not be used in any disciplinary or regulatory enforcement proceedings.
10. Are there any topics in particular that you believe the GDC should prioritise to support registrants in using the Framework?
We believe there could be benefit in developing supporting material that addresses managing professional responsibilities with personal and commercial interests. This could include practical examples of how registrants are required to put patient interests above their own personal and/or business interests. Clear guidance in this area is important to help professionals manage daily operational and commercial pressures while remaining fully compliant with their regulatory obligations.
Framework for Professionalism
11. To what extent do you agree or disagree that the proposed Framework for Professionalism will prioritise patient safety and public confidence?
- Neither agree or disagree
Please explain your answer:
We do not believe that the proposed Framework itself will have any direct influence over patient safety and public confidence. Its impact will instead be determined by the extent to which it is implemented by the profession. This will be assisted by making the final version of the Framework as concise, consistent and easy to use as possible.
Currently, there is a risk that the proposed Framework is too disparate to be clear to busy professionals who need expectations set out transparently so they know where they stand. This is also particularly important given the diversity of the dental workforce.
Given this, ensuring the final Framework is easy to navigate will be crucial to its practical implementation.
12. To what extent do you agree or disagree that the proposed Framework for Professionalism encourages and supports the use of professional judgement?
- Neither agree or disagree
Please explain your answer:
While the proposed Framework does encourage and support the use of professional judgement, many registrants are apprehensive about how their decisions will be viewed by the General Dental Council.
As such, registrants may be hesitant to fully exercise their professional judgement if they feel their decisions could be easily challenged by the regulator at a later date. Because of these concerns, the proposed Framework needs to be completely clear and unambiguous.
13. To what extent do you agree or disagree that the proposed Framework for Professionalism supports dental professionals to make the appropriate decision for each situation?
- Neither agree or disagree
Please explain your answer:
The proposed Framework relies upon judgment, so it allows for some flexibility in decision-making. However, whether this will always result in the appropriate decision being made depends entirely on how closely a registrant’s interpretation matches the regulator's own view of what is considered appropriate. The current supporting information is not comprehensive enough to guide these decisions effectively.
In areas where the proposed Framework lacks sufficient clarity, registrants may increasingly look to peers, professional forums and informal networks for reassurance regarding appropriate conduct. This creates a risk of ‘group think’, whereby interpretations become widely accepted despite not necessarily reflecting the regulator's intended position. More comprehensive supporting material and clearer drafting would help reduce this risk.
14. To what extent do you agree or disagree that the proposed Framework for Professionalism provides a useful way to organise guidance for registrants?
- Neither agree or disagree
Please explain your answer:
The proposed Framework provides a useful way to organise guidance, but it is essential that those elements which are mandatory are made explicit. This is necessary to minimise any risk of inappropriate interpretation regarding where personal judgment can be exercised and what the General Dental Council actually expects.
The information also needs to be clearer and more accessible within the proposed Framework itself, rather than requiring registrants to navigate external links and multiple documents.
The relationship between the Framework for Professionalism and Fitness to Practise
15. Please specify which groups you think would be impacted and how. Please let us know if you have any suggestions for how these issues could be addressed.
The move to a more principles-based framework may disproportionately affect registrants whose first language is not English, including some registrants from minority ethnic backgrounds and those who qualified in other jurisdictions. Ambiguous or highly nuanced wording may make it difficult to understand what constitutes reasonable professional judgement in practice. Therefore, the General Dental Council should use clear and accessible language, provide practical examples for all registrant groups and test the proposed Framework with registrants from a range of cultural and linguistic backgrounds.