Registered Manager or Nominated Individual: Who CQC Needs and What They Will Be Asked

Registered Manager or Nominated Individual: Who CQC Needs and What They Will Be Asked

The Care Quality Commission requires two distinct statutory roles for most provider registrations: a registered manager who oversees day-to-day service delivery at a specific location, and a nominated individual who acts as the accountable person for the entire organisation. Both must satisfy fit and proper persons requirements before registration, and both face separate assessments during which the CQC will test not just compliance knowledge but also their understanding of governance, safeguarding escalation and how they will evidence continuous improvement.

Different roles, different accountability

The registered manager is location-specific. If you operate three care homes, each needs its own registered manager unless you apply for and are granted an exception. That manager must be present at the location, leading the staff, handling incidents, liaising with commissioners and families, and holding direct operational responsibility for care standards.

The nominated individual sits above this. One NI can be named across all your registered locations. Their role is strategic accountability: they are the person the CQC will contact when systemic issues arise, the signatory on notifications, and the individual who ensures adequate resources, competent management and compliant governance across the whole provider entity. The NI is not the day-to-day manager. They are the board-level or executive-level point of accountability.

Most providers structure this as the registered manager being the home manager or service lead, and the NI being the managing director or operations director. That works if the NI has sufficient oversight, authority and time. Where it breaks down is when the NI is a non-executive who visits once a quarter, or when the company secretary is named as NI because someone read that it is a corporate filing role. It is not. The CQC expects the NI to know the operation intimately and to intervene when risk emerges.

Fit and proper persons requirements

Both the registered manager and the nominated individual must meet fit and proper persons requirements set out in Schedule 3 of the earlier Health and Social Care Act 2008 (Regulated Activities) Regulations 2014. The CQC will check whether the person is of good character, has the qualifications, competence, skills and experience necessary for the role, has the physical and mental health to do the job, and has not been responsible for, privy to, or contributed to serious misconduct or mismanagement in a care setting.

In practice, this means a full employment history with gaps explained, a Disclosure and Barring Service check, two references covering regulated activity roles, and a self-declaration on health, conduct and solvency. The CQC will look at County Court judgments, director disqualifications and any history of regulatory enforcement at previous employers. If the person was a manager or director at another provider rated inadequate or placed into special measures, expect detailed questions about what went wrong and what they learned.

The nominated individual interview will also probe business structure. If the applicant is an employee but not a director or shareholder, the CQC will ask who owns the company, how decisions are made, who controls the budget, and whether the NI has real authority or is a post box. If the operating company is a subsidiary, the CQC will want to know the holding company structure and whether the parent exercises operational control. If the property is held in a separate entity and leased back, the assessor will ask about lease terms, whether the property company can remove access, and how conflicts of interest are managed. These are not theoretical questions. Poor corporate structure is one of the most common reasons for delayed or refused registration.

The interview and what it probes

Both the registered manager and the nominated individual will be interviewed, usually separately. As of 2026-10-31, most of these interviews take place by video call, though some inspectors still prefer a site visit for the registered manager interview so they can walk the premises and observe the environment.

The CQC assessor is not testing rote knowledge of regulations. They are testing judgment, insight and honesty. A common opening question is to describe a serious safeguarding incident you managed and what you would do differently. If the candidate has no example or says they have never had one, that is a red flag. Experienced managers have incidents. What the CQC wants to hear is escalation decisions, how you involved the local authority, what immediate actions you took, how you communicated with the family, and how you reviewed your systems afterwards.

Another standard area is staffing and safe deployment. The assessor will ask how you calculate dependency, what you do when agency staff do not turn up, how you ensure competence before someone works unsupervised, and what you do if you suspect a staff member is under the influence or behaving inappropriately. There is no single right answer to these scenarios, but there are plenty of wrong ones. Saying you would handle it informally or wait to see if it happens again will end the interview poorly.

For the nominated individual, expect questions about financial sustainability, business continuity and how you know what is happening across your locations. If you operate four homes, how often do you visit? What reports do you review? How do you know staffing is safe? What would you do if one location was consistently over budget? If a registered manager resigned, how quickly could you replace them and what would you do in the interim? The CQC is assessing whether you are genuinely accountable or simply a name on a form.

Common structural errors

The most frequent mistake is confusing the company that holds the CQC registration with the company that owns the property or the parent company that holds the shares. The CQC registers a legal entity. That entity must employ the staff, hold the contracts, invoice for care, and carry the liability insurance. If the operating company is a shell and all the substance sits elsewhere, registration will stall.

A worked example: a developer sets up PropCo to buy the building and OpCo to run the service. OpCo applies for CQC registration and names the development director as nominated individual. The CQC interviews the director and discovers that OpCo has no staff, no bank account, and no assets. All contracts are signed by PropCo, staff are employed by a management services company owned by the same parent, and the director spends most of his time on property deals. The application is refused. The CQC does not register theoretical structures. It registers functioning, accountable providers.

Another example: a franchise model where the franchisor wants to be the registered provider and install a franchisee as registered manager. The CQC will want to know who is genuinely in control. If the franchisor sets all the policies, controls the budget, hires the staff and takes the revenue, they are the provider. If the franchisee is genuinely independent, employs their own staff, holds their own insurance and keeps the income, they are the provider. Hybrid models where accountability is blurred will be challenged.

Holding company oversight is acceptable, but it must be clearly documented. If the parent company appoints the NI, that is fine. If the parent company second assigns staff to the operating company, that can work if there is a formal agreement, the operating company has a right of direction, and employment liability is clear. If the parent company simply instructs the operating company what to do without any formal governance, the CQC may conclude the operating company is not a genuine provider and ask the parent to apply instead.

Where health and social care commissioning intersects

Providers bidding for NHS contracts or local authority block placements will often face questions about CQC registration status during the selection stage. The NHS Provider Selection Regime, operational for direct awards and competitive processes since the original regulations introduced in 2023, allows commissioners to exclude providers who are not registered or who hold an inadequate rating. That makes timing critical. You cannot wait until you win the contract to start your registration. The application process typically takes three to four months from submission to decision, longer if the CQC raises queries about structure, finances or fit and proper persons.

If you are writing a tender response and your registration is pending, be explicit about the stage you are at, when you expect the decision, and what contingency you have if it is delayed. Evaluators marking NHS tender submissions will often score providers with established good or outstanding ratings higher than newly registered or pending applicants, particularly for complex or high-risk services. That is not unlawful. It is a proportionate response to the risk of contract failure.

Some frameworks, including several available through the Provider Selection Regime routes, allow registration to be a condition precedent rather than a pass/fail criterion at selection. That means you can bid, be appointed to the framework, and then complete registration before any call-off contract is signed. That sequencing only works if you are confident the registration will succeed. If there are structural issues with your corporate setup or concerns about the nominated individual's track record, resolve them before you bid, not after.

Frequently asked questions

Who can be both the registered manager and the nominated individual?

The same person can hold both roles if they have day-to-day operational control and board-level accountability. This is common in single-location providers where the owner-manager runs the service directly. The CQC will expect that person to demonstrate they have enough time to fulfil both roles and that there is a clear plan for separation or succession if the business grows or if they are incapacitated.

What happens if the nominated individual leaves and we do not replace them immediately?

You must notify the CQC within 28 days and submit an application for a new NI as soon as possible. The organisation can continue to operate during this period, but if the gap extends beyond a few months without good reason, the CQC may consider it a breach of your conditions of registration and take enforcement action. Have a deputy or succession plan in place before the departure, not after.

Can a non-executive director be the nominated individual if they do not work in the business day to day?

Legally yes, but practically it is high risk. The CQC expects the NI to have detailed operational knowledge, to be contactable at short notice, and to intervene when necessary. A non-executive who attends four board meetings a year will struggle to demonstrate that level of engagement during the interview. If your NI will not be full-time in the business, document how they maintain oversight, how often they visit, what reports they review, and who deputises when they are unavailable.

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