Consultation to implement the Consensual Disposal Process in UKCP’s Complaints and Conduct Process and strengthen the provisions around sanctions for sexual misconduct

About this consultation

UKCP is undertaking a consultation to introduce a Consensual Disposal Process in UKCP’s Complaints and Conducts Process (CCP) and to strengthen the provisions around sanctions for sexual misconduct so that the most likely sanction is removal from the register (rather than suspension). 

This consultation is running from 1 September 2026 to 30 October 2026.

After this consultation closes, our next steps will be to collate and analyse all responses. 

Purpose and justification for a Consensual Disposal Process

UKCP’s current Complaints and Conduct Process (CCP) does not currently make use of ‘consensual disposals’. Used by most other regulators, these provide a structured mechanism for managing cases in which a registrant accepts the material facts and acknowledges a breach of the Code of Ethics and Professional Practice, (code), removing the need for a fully contested hearing. Under the existing framework, such cases are still required to proceed to an adjudication panel for findings and sanction, even when the facts and breaches are not disputed.

This approach creates avoidable delays, generates unnecessary stress for both complainants and registrants and increases the overall regulatory burden. It also risks inefficient use of panel resources by allocating time to matters where the conduct has already been admitted, potentially diverting attention from contested, complex or higher risk cases.

Across the healthcare regulatory landscape, consensual disposal processes are now established practice. Right-touch regulation principles require regulatory intervention to be proportionate, consistent, transparent, targeted and agile. Consensual disposal meets these criteria without unnecessary adversarial hearings. The introduction of a structured Consensual Disposal Process aligns UKCP with these principles and signals continued regulatory maturity.

The Consensual Disposal Process would enable complaints to be resolved more quickly and efficiently, reducing the anxiety and inconvenience for both complainants and registrants by avoiding unnecessary hearings where:

1. the complaint does not relate to serious allegations that may give rise to termination of UKCP membership;
2. the registrant accepts the material facts and breaches of the Code of Ethics and Professional Practice;
3. it is in the public interest and appropriate to deal with the complaint this way; and
4. it would not be a ‘soft option’ but a pragmatic route to resolution that benefits all parties.

Purpose and justification for strengthening the provisions around sanctions for sexual misconduct 

UKCP proposes to amend its indicative sanctions guidance to make clear that removal from UKCP membership is the presumptive outcome in proven cases involving sexual misconduct. This reflects the seriousness of such behaviour, which constitutes a fundamental breach of professional boundaries, compromises safeguarding obligations and undermines the trust on which therapeutic practice depends. Panels will continue to retain discretion in genuinely exceptional circumstances; however, removal will be the expected regulatory response.

Providing for removal as the standard and most likely outcome strengthens public protection, provides clarity and consistency for decision makers and aligns UKCP with the expectations of the wider regulatory landscape, where sexual misconduct is recognised as conduct incompatible with continued registration. It promotes transparency by giving registrants clear notice of the likely consequences of such breaches. It supports public confidence in UKCP’s commitment to maintaining the highest standards of ethical and professional practice.

Scope and applicability of the Consensual Disposal Process

Consensual disposal would be available for all types of complaints covered by CCP (misconduct, professional incompetence, criminal convictions, health issues, and regulatory decisions), provided the registrant makes admissions as to the material facts underlying the complaint and breaches of the code and agrees to comply with the proposed sanction.

Consensual disposal is only available, where the complaint, if found proven, would not give rise to termination of UKCP membership. 

Consensual disposal key process steps

• The process may be initiated where the registrant makes admissions. It can be proposed by the registrant, the professional standards manager or the Professional Conduct Committee.
• The professional standards manager may seek the complainant's view of the complaint being dealt with by way of consensual disposal.
• The consensual disposal offer would be sent to the Professional Conduct Committee for their final review and approval, after which it would be sent to the registrant.
• The professional standards manager would draft a consensual disposal offer, including any proposed sanctions, in line with the indicative sanctions guidance.
• The registrant would have 21 days to accept or reject the consensual disposal offer. If rejected or not responded to, the matter would be referred to an adjudication panel.
• If the registrant agrees to deal with the complaint by consensual disposal, the consensual disposal agreement would be signed by the registrant and counter-signed by the PCC chair (or deputy chair). There would be no right of appeal for any party. The registrant will be strongly advised to take legal advice and inform their insurers before accepting the consensual disposal. 

Outcomes and enforcement

• The registrant, complainant, and the registrant’s organisational member or college if the registrant is a direct member, would be notified when the consensual disposal agreement has been signed, meaning the complaint is resolved.
• Complainants would not be able to challenge a consensual disposal once agreed.
• Sanctions, if imposed via consensual disposal, would be monitored by UKCP for compliance. Breach of the agreement may result in referral to an adjudication panel and potentially the imposition of more severe sanctions, including termination of membership.

Publication and transparency

• Consensual disposal decisions would be published on the UKCP website in accordance with the amended publication of decisions policy.
• The published decision would be a copy of the signed agreement, approved by the PCC, and would include an agreed statement of facts.
• The decision would be published until the registrant has complied with the terms of the agreement, ensuring openness and transparency.

Re-applying to the UKCP 

If a registrant chooses to resign after accepting the material facts and breaches identified in a complaint and a consensual disposal route would have been offered, then the complaint would remain on file and considered if the registrant re-applies to UKCP in the future. Any such re-application would be considered by the professional standards manager in consultation with the Professional Conduct Committee who may review any material facts and breaches on file when determining whether to admit the individual to UKCP membership.

The professional standards manager would decide whether to: 

1. re-admit the former registrant;
2. draft a consensual disposal offer imposing sanctions in relation to the accepted material facts and breaches on file before re-admitting the individual; or
3. refuse to re-admit that individual to UKCP membership. 

UKCP may share details of the accepted material facts and breaches in relation to the complaint to a relevant body, regulator or future employer of the registrant if UKCP receives a request for information about the registrant that necessitates such disclosure.

Documentation changes 

Proposed redline changes to the CCP, publication of decisions policy, and the indicative sanctions guidance can be seen below:

Our questions

We welcome your views on the above and when responding to this consultation we would like you to answer the following questions: 

1. Do you have any comments or concerns about the proposed Consensual Disposal Process?
2. Are there any risks, safeguards or practical implications we should consider?

Please submit your response to this consultation to: complaints@ukcp.org.uk by 4pm on Friday, 30 October 2026.

We will publish and attribute your response unless you request otherwise.