What does CQC Regulation 18 require on staffing levels?
Regulation 18(1) of the 2014 Regulations is short and direct. You must deploy "sufficient numbers of suitably qualified, competent, skilled and experienced persons" to meet the needs of the people using your service and the other fundamental standards in Part 3.
There is no national staffing ratio in the regulation. CQC's guidance is explicit that you should have a systematic approach to working out how many staff and what mix of skills you need, and that approach must reflect current legislation and any available guidance for your type of service. A nursing home with high-dependency residents and a small supported-living service will land in very different places, and that is the point. The duty is outcome-based, not a fixed headcount.
Regulation 18(2) adds the development side. You must give staff the support, training, professional development, supervision and appraisal necessary to do their jobs, enable them to gain further qualifications relevant to their role, and, where staff are registered professionals such as nurses or social workers, enable them to give their regulator evidence of continued fitness to practise.
Because there is no magic ratio, inspectors look at your evidence. A documented dependency assessment, rotas that match it, and training records you can produce on the day are what demonstrate compliance, not a number you assert.
What does Regulation 19 require for fit and proper recruitment?
Regulation 19 governs who you employ. Under paragraph (1), each person must be of good character, have the qualifications, competence, skills and experience necessary for the work, and be capable of the role's intrinsic tasks after reasonable adjustments.
Paragraph (2) requires recruitment procedures that make sure those conditions are met. Paragraph (3) is the documentary core: for each person you employ, you must hold the information specified in Schedule 3 to the Regulations. That schedule lists proof of identity with a recent photograph, a criminal record certificate or enhanced criminal record certificate where the role qualifies, satisfactory evidence of conduct in previous health or care employment, a full employment history with written explanation of any gaps, evidence of relevant qualifications where reasonably practicable, and information about any physical or mental health condition relevant to the role.
The enhanced criminal record certificate referenced in Schedule 3 is the enhanced DBS check, issued under section 113B of the Police Act 1997, with a check of the children's or adults' barred list where the work is regulated activity with vulnerable adults or children. Most front-line care roles qualify.
Regulation 19 also keeps running after hiring. Paragraph (5) requires you to take proportionate action when an employee no longer meets the paragraph (1) conditions, and to inform the relevant regulator if that person is a healthcare professional or social worker.
Which Schedule 3 documents must you hold for each member of staff?
Schedule 3 to the 2014 Regulations is the checklist CQC inspectors work from when they review personnel files. Hold each item for every employee, and be able to show it.
The table below lists the Schedule 3 requirements as the legislation sets them out. The criminal record certificate items only bite where the individual is eligible for that level of check, which for regulated activity with adults or children means the enhanced certificate with barred-list information.
| Schedule 3 item | What it means in practice |
|---|---|
| Proof of identity | Identity documents including a recent photograph |
| Criminal record certificate (s.113A Police Act 1997) | Standard DBS certificate, plus barring information where applicable |
| Enhanced criminal record certificate (s.113B Police Act 1997) | Enhanced DBS with children's or adults' barred-list check where the role is eligible |
| Conduct in previous employment | Satisfactory evidence of conduct in prior health, social care or vulnerable-groups work |
| Reason previous employment ended | Where prior work involved children or vulnerable adults, verification of why it ended |
| Qualifications | Documentary evidence of relevant qualifications, where reasonably practicable |
| Full employment history | Complete history with written explanation of any gaps |
| Health information | Any physical or mental health condition relevant to capability for the role |
Is the Care Certificate a legal qualification with an expiry date?
No. The Care Certificate is an induction standard, not a qualification that expires. CQC's position is that it expects providers to show staff have, or are working towards, the skills set out in the Care Certificate, which CQC treats as the benchmark for induction of the non-regulated workforce.
It is made up of 16 standards covering what a new health or social care worker should know and be able to do, from understanding their role and duty of care through to safeguarding, infection prevention and basic life support. The standards were updated in March 2025, when a new standard on awareness of learning disability and autism was added, taking the total from 15 to 16. Skills for Care, NHS England and Skills for Health developed it, and CQC references it in its guidance under both Regulation 18 and Regulation 19.
The practical consequence is twofold. There is no "renewal date" on a Care Certificate the way there is on a first-aid certificate or an SIA licence. Once a worker has completed it, it does not lapse. What you do track is the underlying ongoing training and competence that Regulation 18 demands. The Care Certificate is also not strictly mandatory in name. If you do not use it, CQC expects you to use something in its place that covers the same standards.
The honest caveat is that "no expiry" does not mean "set and forget". A worker who completed the Care Certificate in 2019 still needs current safeguarding, moving-and-handling and other refresher training. Those refreshers do have review cycles, and that is where most providers actually slip.
How does the DBS Update Service help care providers stay compliant?
The enhanced DBS certificate you obtain under Schedule 3 is a snapshot from the day it was issued. It has no statutory expiry, but a certificate from several years ago tells you nothing about what has happened since. That gap is where the DBS Update Service comes in.
The Update Service is a subscription that keeps a standard or enhanced DBS certificate up to date and lets employers check online whether anything has changed. It costs £16 per year, paid by the individual by debit or credit card, and is free for volunteers. With the worker's permission, you can run an online status check rather than starting a fresh application each time, which makes a certificate portable across roles where the same type and level of check is required.
For a care provider, the value is operational. Instead of re-applying for a brand-new enhanced check when staff move between your services, or doing periodic re-checks to satisfy your own recruitment policy, you can verify status online in minutes. That keeps you on the right side of Regulation 19's standing requirement to act when someone is no longer fit for the role.
One point to be clear about: the Update Service is optional, and the worker has to register within the relevant window after their certificate is issued. CQC does not mandate it. But for a service running dozens of enhanced checks, it is a cheap way to keep them current.