Guide
Registered manager vs nominated individual: who does what in a CQC application
If you are setting up a care company, the CQC application asks about two key people: a registered manager and a nominated individual. The titles sound similar, but they are different roles with different legal footing.
This guide sets out what CQC and the regulations say about each role, when one person can hold both, and what each needs to have ready. Every point links to the CQC or government page it comes from.
The short version
- The registered manager runs the regulated activity day to day at a location. They apply to CQC in their own right and share legal responsibility with the provider.
- The nominated individual is a director, manager or secretary who supervises how the regulated activity is managed and is the main point of contact with CQC.
Only organisations need a nominated individual. Most providers need a registered manager.
Who needs a nominated individual?
CQC’s page What is registration? explains that if you apply for registration as an organisation, the regulations require you to nominate an individual “to act as the main point of contact with us”. If you register as an individual or a partnership, you do not need one. A limited company counts as an organisation.
The legal basis is Regulation 6 of the Health and Social Care Act 2008 (Regulated Activities) Regulations 2014. It says the body must tell CQC the name, address and position of an individual who is:
- employed as a director, manager or secretary of the body, and
- responsible for supervising the management of the carrying on of the regulated activity.
CQC’s guidance puts this more plainly: the nominated individual should be a senior person “with authority to speak on behalf of the organisation” about the way the regulated activity is provided. It is up to you who you nominate, as long as they meet those criteria.
You can nominate the same person for all your regulated activities, or a different person for each. But you can only nominate one person for each regulated activity.
Who needs a registered manager?
CQC says that in most cases a provider will need one or more registered managers. The regulations require CQC to put a registered manager condition on:
- a partnership
- an organisation
- an individual who is not personally in day-to-day charge of the regulated activities, or is not fit to be.
CQC’s page Register as a new manager says you need to register as a manager “if you are in charge of the day-to-day running of regulated activities at a location”. The point of the requirement, CQC explains, is to regulate the person managing the service day to day at the location, “rather than a more senior manager who is not in day to day charge at the location”.
The key differences side by side
| Registered manager | Nominated individual | |
|---|---|---|
| Who needs one | Most providers, including all organisations and partnerships | Organisations only |
| What they do | Runs the regulated activity day to day at a location | Supervises the management of the regulated activity; main contact with CQC |
| Who they are | The person in day-to-day charge | A director, manager or secretary of the organisation |
| How they get the role | Applies to CQC and is registered in their own right | Named by the organisation, which must check they are fit |
| Regulation | Regulation 7 | Regulation 6 |
| Legal responsibility | Shares legal responsibility with the provider for meeting the regulations | No statutory responsibilities beyond those of any other employee (per GOV.UK’s care workforce pathway) |
The last row comes from the government’s care workforce pathway page on the nominated individual role, which adds that the role is still “a major and important role in the leadership of your service”.
Can one person be both?
Yes, but CQC would rather you avoided it. Its guidance says that in very small organisations “it may be necessary for the same person to be both the registered manager and the nominated individual, but this should be avoided where possible” (What is registration?).
CQC’s reason is practical: when there are concerns about a service, it sometimes needs to speak to someone more senior than the manager.
If one director of a two-director company will be the manager, consider whether the other could be the nominated individual. That is your decision, based on who genuinely supervises the service.
What each person needs to show
Both regulations use very similar tests. Under Regulation 7, a registered manager must be:
- of good character
- have the necessary qualifications, competence, skills and experience to manage the regulated activity
- able, by reason of their health and after reasonable adjustments, to do the job
- able to supply the information listed in Schedule 3 of the regulations.
Regulation 6 sets the same tests for the nominated individual, but as a duty on the provider: it “must take all reasonable steps to ensure” the nominated individual meets them. CQC’s guidance on both says the provider must have processes to check qualifications, competence, skills and experience, and keep records. A long-term condition or disability does not in itself stop someone holding either role.
For both regulations, CQC says it “must refuse registration if providers cannot satisfy us that they can and will continue to comply”.
What the registered manager applies with
The registered manager makes their own application. According to Register as a new manager, they need to show they have management experience and can meet the needs of the people the service will support. They will also need:
- contact details for their GP and last employer
- a full work history from age 16, with any gaps of more than 4 weeks explained
- copies of qualifications and training (for a home care manager, CQC says a Level 5 Diploma in Leadership and Management or equivalent “would strengthen your application”)
- a DBS certificate issued in the past 12 months.
CQC’s DBS checks for CQC registration page explains that registered managers need an enhanced DBS check with the right barred list information. If you are not a registered healthcare professional, it must be a CQC countersigned check, and certificates older than 12 months are rejected. CQC says it can take up to 60 working days to receive the certificate, and you cannot submit your application until you have it. That alone is a good reason to start early.
CQC may interview the manager (Assessing your application), and they cannot manage regulated activities until CQC confirms their registration.
What the nominated individual needs
The nominated individual does not make a separate application. The provider’s application form asks for their details and the regulated activities they are nominated for (What is registration?). The organisation should be able to show how it checked their fitness under Regulation 6.
Keeping it up to date after registration
- Statement of purpose. CQC’s statement of purpose guidance asks for each registered manager’s name and contact details, the locations they manage, the percentage of time they spend at each, and any job share arrangements. If your managers change, your statement of purpose needs to change too.
- Changing your nominated individual. CQC’s notification page says you must notify CQC if you appoint a new nominated individual, or if a director, secretary or other officer joins or leaves your organisation. It provides a form to send by email.
A quick checklist before you apply
- If you apply as an organisation, is your nominated individual a director, manager or secretary?
- Who will be in day-to-day charge at each location? That is your proposed registered manager.
- If one person is doing both, could someone else take one of the roles?
- Will the manager’s enhanced DBS check still be under 12 months old when you submit?
- Have you recorded how you checked your nominated individual’s fitness?
- Do your statement of purpose and policies name the right people in the right roles?
Where OrCore fits
Your policies need to say who does what, and who the manager escalates to. When you build your policy pack with OrCore, the interview asks how your company is set up, including whether your registered manager is also your nominated individual and who sits above the manager, and the policies are written from those answers. You check and sign off every one. You can start the interview here.
About us. OrCore Compliance writes CQC policies from your own answers. We use AI to help draft them, and you check and sign off every one before you send anything to CQC. We are independent and not affiliated with or endorsed by the Care Quality Commission.
This article gives general information from CQC and UK government pages, with a link for each point. It isn’t advice about your own service: CQC makes every registration decision, and for advice on your situation speak to your own specialist. OrCore offers registration support only, with no guarantee of outcome.