Software and CQC, what is actually being assessed

No product is CQC compliant, and a vendor saying otherwise has told you something

The Care Quality Commission registers providers who carry on regulated activities in England. A clinic treating disease, disorder or injury registers. The software that clinic uses does not, because registration attaches to the activity and the person responsible for it rather than to a tool used while doing it.

This matters commercially rather than pedantically. A supplier who claims their product is CQC compliant, approved or certified is either describing a thing that does not exist or hoping you will not check, and the same looseness tends to show up in the answers that do matter. The question worth putting instead is narrower and answerable, which is what the product can evidence when somebody asks.

Records, and the word contemporaneous

Regulation 17 requires an accurate, complete and contemporaneous record in respect of each service user. Contemporaneous is the word that decides whether a system helps or hurts, because it means the record was made at the time rather than reconstructed at the end of a clinic, and a system that cannot distinguish the two cannot evidence it.

The practical test is whether the record carries its own history. When an entry was created, who created it, what it said before it was edited and who approved the change are four separate facts, and a system that overwrites rather than versions can produce none of them. Our page on monitoring an AI scribe once it is live covers the signals that tell you a documentation system has started drifting, which is the same evidence read a different way.

Staffing, and the gap between the rota and the day

Regulation 18 asks for sufficient numbers of suitably qualified, competent, skilled and experienced persons deployed. Deployed is doing the work in that sentence, because a rota describes an intention and an assessment is interested in what happened.

Most clinics can produce the planned rota instantly and the worked reality slowly, which is the wrong way round. The question an inspector reaches is usually about a specific date, and the answer needs to survive the follow up, which is who covered when somebody did not arrive and whether that person was qualified for what they covered.

Registration checks, which lapse quietly

Regulation 19 requires staff to be of good character and to have the qualifications, competence, skills and experience necessary, and the evidence for it is not a one off. A professional registration can lapse, be suspended or carry conditions, and none of those events sends your clinic a letter.

A system that recorded the check at onboarding and never again is evidence of a check on one day rather than evidence of a duty being met. What survives a follow up question is a date of last verification per person, held somewhere that somebody looks at rather than somewhere it was filed.

The framework is changing, and the evidence is not

CQC announced in March 2026 that it is moving away from one single assessment framework towards sector specific frameworks, with four drafts covering adult social care, mental health, primary care and community services, and hospitals. Key lines of enquiry replace the quality statements, each key question carrying between three and seven of them, and rating characteristics replace the scoring model. The consultation closed in June 2026 and the frameworks went to piloting over the summer.

The five key questions are unchanged. Safe, effective, caring, responsive and well led survive every version of this, and so does the underlying legislation, because the fundamental standards sit in regulations rather than in the assessment method. A clinic choosing systems on the current framework's vocabulary is buying against something that is being rewritten. A clinic choosing them on what the regulations require is not.

Where a given independent clinic lands across those four sector frameworks is not obvious from the outside, and anybody telling you with certainty which one applies to you is guessing. The regulations are the part worth building against.

What we are not claiming

This page describes what the regulations require and what systems can evidence. It is not legal advice, it is not a compliance assessment, and it does not substitute for your registered manager's own judgement or for the guidance CQC publishes itself. Where a decision turns on detail, the legislation linked below governs rather than this summary of it.

wai is not CQC registered, cannot be, and makes no claim to be. We are software used by registered providers. The registration and the duty stay with the clinic.

Where wai sits

wai is built so a clinician makes every clinical decision. It drafts the note, the letters and the coding for review, shows its working so a reviewer checks reasoning rather than trusting output, and holds every patient-affecting action for approval. Every read of a patient record is logged against a named role.

The reason that design helps here is incidental to why it exists. A system where a person approved each thing, and the approval is on the record next to the draft and the edits, answers the evidence questions above as a report rather than as a reconstruction. That is a side effect of building for a clinician rather than a feature built for an inspector.

Request our answers to every question on this page in writing before the demo. A supplier who will not put them in writing early, including us, has told you where they are. Clinicians still decide what enters the record.

Frequently asked questions