Most regulators investigate, decide, then prosecute through a single track. The GMC’s process splits these stages across distinct decision-makers: case examiners, the Investigation Committee, and the Medical Practitioners Tribunal Service. Each stage has its own rules of procedure, its own threshold, and its own strategic considerations.
A response that works at the case examiner stage can look different from the approach needed at the MPTS. Jake spent years working inside the GMC, drafting fitness-to-practise decisions and advising case examiners. That insider understanding shapes how we approach every stage of your defence.
When a complaint reaches the GMC, it is triaged to assess whether it meets the threshold for a formal investigation. Many complaints are closed at this stage. We can make representations to the triage team and provide supporting information that helps prevent a complaint from progressing.
If the GMC decides to investigate, it sends a Rule 7 letter setting out the allegation and inviting your response. This is one of the most important documents in the entire process. A well-constructed Rule 7 response can close a case at the investigation stage. A poor response — or no response — can result in a referral to the MPTS that could otherwise have been avoided.
We draft Rule 7 responses that are evidence-led, address each allegation directly, and present your case in the strongest possible terms. We have helped doctors close cases at the Rule 7 stage that their previous advisers thought would go to a hearing.
After the investigation, a case examiner reviews the evidence and decides whether there is a real prospect of finding impairment. They can close the case, issue a warning, agree undertakings with the doctor, or refer to the MPTS. We make detailed representations to case examiners and, where appropriate, challenge decisions by way of review.
The IOT can impose conditions on or suspend your registration during an investigation, before any findings of fact are made. IOT hearings can be called at short notice and move quickly. They are often the most urgent and most stressful part of the process. We prepare detailed written submissions and attend to make oral representations on your behalf.
If the case is referred to the MPTS, a panel of three hears the evidence and makes findings of fact. If impairment is found, the same panel then determines the appropriate sanction. Sanctions range from a warning through to conditions, suspension, or erasure. We represent doctors at every stage of MPTS proceedings, including contested hearings, sanctions hearings, and review hearings.
If you disagree with an MPTS decision, you have the right to appeal to the High Court under Section 40 of the Medical Act 1983. The GMC can also appeal decisions it considers too lenient. Section 40 appeals are complex and time-limited. We advise on the merits and, where appropriate, represent doctors in the Administrative Court.
The MPTS can impose a range of sanctions at the conclusion of a fitness-to-practise hearing:
The appropriate sanction depends on the nature and severity of the findings, the doctor’s insight and remediation, and any aggravating or mitigating factors. We make detailed submissions on sanction, drawing on Yusuff v GMC, Bawa-Garba v GMC, and the MPTS sanctions guidance to argue for the most proportionate outcome.
The single most important piece of advice we give to every doctor who contacts us is this: instruct a solicitor as early as possible. The earlier you get specialist advice, the more options you have.
Doctors who wait until they receive a hearing notice have often lost the opportunity to close a case at the Rule 7 stage. Doctors who respond to a Rule 7 letter without specialist advice sometimes make admissions, volunteer information, or take a tone that makes a later defence harder to run.
If you have received any correspondence from the GMC — a triage letter, a Rule 7 letter, a case examiner decision, or a notice of an IOT hearing — call us. The initial consultation is free. We will tell you honestly where you stand and what we recommend.
The GMC triages every complaint and decides whether it passes the threshold for a formal investigation. Many complaints are closed at triage without the doctor even being notified. If the GMC decides to investigate, it sends a Rule 7 letter setting out the allegation and giving the doctor 28 days to respond. The case is then allocated to a case examiner, who reviews the evidence and decides whether to close the case, issue a warning, agree undertakings, or refer to the MPTS.
Early specialist advice significantly increases the chances of closing a case before it reaches the MPTS.
A Rule 7 letter is the formal notification that the GMC is investigating allegations against you. It sets out the concerns and invites your response, usually within 28 days. This is one of the most consequential documents in the whole GMC process.
A strong Rule 7 response can close a case at the investigation stage without a referral to the MPTS. A weak response, or one that makes unnecessary admissions, can make a later defence significantly harder. You should not respond without specialist legal advice. We draft Rule 7 responses that are evidence-based, address each allegation directly, and present your case in the strongest possible terms.
Timescales vary significantly depending on complexity. Straightforward cases — where the evidence is clear and no expert report is required — can close at the case examiner stage within four to six months. Cases involving clinical allegations, parallel proceedings (police investigation, NHS Trust disciplinary, coroner inquiry), or multiple complainants typically take twelve to twenty-four months to reach a hearing.
The GMC has published targets for case progression but does not always meet them. We are direct with our clients about realistic timescales at the outset.
Yes. The GMC can apply to the Interim Orders Tribunal (IOT) to impose conditions on or suspend your registration during an investigation, before any findings of fact are made. The IOT can act if it considers there is a real risk to patients or to public confidence in the profession.
IOT hearings can be called at short notice — sometimes with fewer than seven days’ warning. They are often the most urgent and stressful part of the process, because the consequences are immediate: if the IOT imposes a suspension, you cannot practise. We prepare detailed written submissions for IOT hearings and attend to make oral representations.
Case examiners are GMC-employed decision-makers who review the evidence at the investigation stage and decide whether a case should be referred to a fitness-to-practise panel. They are not a tribunal — there is no oral hearing at the case examiner stage, and decisions are made on the papers.
The Medical Practitioners Tribunal Service (MPTS) is an independent tribunal that hears cases referred to it by the GMC. MPTS hearings are formal proceedings: witnesses give evidence, documents are produced, and both parties make oral submissions. The panel makes findings of fact and, if impairment is found, determines the appropriate sanction.
At the case examiner stage, the options are: no further action, a warning, agreed undertakings, or referral to the MPTS.
At the MPTS, the full range of outcomes runs from no further action through warnings, undertakings, conditions, suspension (up to twelve months at a time), or erasure from the register. Erasure is the most serious sanction and means you can no longer practise as a doctor in the UK. You may apply for restoration after five years.
The appropriate sanction depends on the nature and severity of the findings, the doctor’s insight and remediation, and any aggravating or mitigating features. We make detailed sanctions submissions at every stage.
Medical defence organisations (MDOs) such as MDU, MPS, and MDDUS provide support for many types of GMC matter and can be a useful first port of call. However, MDO representation is not always available for all types of case, and there are circumstances where independent specialist legal advice offers significant advantages.
MDOs handle very high volumes of cases. A specialist regulatory defence firm can dedicate more focused attention to your case and take a more bespoke approach to your defence strategy. Jake’s background as a former in-house GMC lawyer means we understand how the GMC thinks — and how to construct a response that addresses exactly what case examiners are looking for.
Many clients come to us after receiving an MDO-assisted Rule 7 response that has not closed their case. We work alongside MDO indemnity and are often instructed on a self-funding basis for cases where the client wants specialist input.
Our initial one-hour consultation is free. After that, we agree a fixed fee or an hourly rate cap before any work begins. For defined stages of work — a Rule 7 response, an IOT hearing, a case examiner representation — we can usually quote a fixed fee. For longer-running matters such as contested MPTS hearings, we work to an estimated total with regular updates.
Our hourly rate is £300 per hour. Fixed fees are agreed in writing before work begins. Payment plans are available. Full details are on our pricing page.