Our response to the PSA’s review of our performance for 2025-26
Every year the Professional Standards Authority (PSA), the independent body with oversight for health and social care regulators in the UK, reviews our performance against their regulatory standards. This means we work with the PSA to provide evidence for how we meet each of their standards.
This year in the PSA's review the General Osteopathic Council has been assessed as not meeting Outcome 3 of Standard 3 of the Equality, Diversity and Inclusion (EDI) Framework.
What does this mean?
Outcome 3 asks for evidence to show that: In terms of EDI, the regulator makes fair decisions across all regulatory functions.
This year the PSA decided that the GOsC did not provide enough data analysis to show that there is not unfairness in the way we regulate, and suggested that there are gaps in our EDI data and how we use it to make sure we can demonstrate we are making fair decisions across all our regulatory functions and fitness to practise outcomes. The exact wording of their assessment is shown in our detailed response.
We want to be clear that we know that demonstrating real change in this area requires meaningful consideration and time, and we are committed to working with and learning from our peers and experts in this field.
However we do not agree with the PSA’s assessment. While we will continue to work collaboratively with the PSA, we are seeking their assistance to help us understand what good looks like, and how we can better work together to achieve this.
Our response
We do not agree with the PSA assessment or with the suggestion that we ‘can and should do more’ to demonstrate fairness without clearer guidance from the PSA about what sufficient looks like. We need more information on what the standard is for smaller regulators who have much less data, and how the PSA assesses whether there has been enough progress made in this area.
For us, the PSA’s explanation (provided in our more detailed response) is unhelpful and lacking specific detail about where the gaps are in our evidence, which makes it hard for us to understand what more we could be doing.
So we are asking the PSA: What does good look like for small regulators when collecting and analysing data in this context? How can we work together in better ways to achieve this, while also making sure our efforts and resources are being used for meaningful change?
As the PSA acknowledges in its report, we are committed to promoting equity, valuing diversity, embracing inclusion and creating belonging, and embedding this in all that we do in our sector to make sure we are being fair and reducing the risk of bias.
The steps we have taken and the progress we have made so far demonstrates our commitment.
Our work on EDIB
In their assessment the PSA has recognised a lot of our work which we are really proud of and includes:
- The clear governance, structures and processes that we have in place to embed equality, diversity and inclusion. Including the progress we are making to deliver our 2024-30 Equity, Diversity, Inclusion and Belonging (EDIB) Framework, the equality impact assessments we publish and the review we carried out this year to improve the consistency in how we publish these assessments.
- The way we recruit for our non-executive roles. This process has been independently assessed as robust and equitable.
- Our standards, guidance and methods for checking and assuring the quality of osteopathic education and training to make sure students and osteopaths have appropriate EDI knowledge and skills, and are able to provide care to all patients and service users. The PSA recognises that expectations for equality, diversity and inclusion are clearly embedded within the Graduate Outcomes and Standards for Education and Training and within our professional guidance, for example our updated guidance on studying osteopathy with a disability and health condition. The PSA also recognises that because of our quality assurance processes, only students who meet the Osteopathic Practice Standards are awarded a Recognised Qualification (RQ) that allows them to apply for registration.
- We provide guidance and resources to support osteopaths in their ongoing development of EDI knowledge and skills. PSA also recognise our plans for further resources in this area related to our Continuing Professional Development (CPD) scheme.
- Our updated Fitness to Practise guidance includes clearer and stronger references to racist and other discriminatory behaviour.
- An independent audit we commissioned provided a sufficiently broad and representative evidential basis on the fairness of processes and decision-making in the initial stages of our Fitness to Practise processes.
- The EDI training we provide to members of staff, Council and Committee members (including Fitness to Practise) and decision-makers.
- Interactive training to Committee members on managing vulnerable witnesses, the use of special measures, and achieving best evidence. This included practical application of the Equal Treatment Bench Book, which supports decision-makers in understanding the diverse circumstances of individuals appearing before tribunals and hearings.
- The new CPD guidance and resources we have developed which were informed by focus groups, neurodiverse registrants and expert advice. This was done to make sure these resources are suitable for neurodivergent people.
- Our consistent and meaningful engagement with a range of audiences in ways that are relevant to EDI. Including patients, students and registrants and with others across the health and social care regulatory landscape.
- Our use of research and evidence to inform our work. Including the UrGEnT (Underrepresented Groups’ Experiences in Osteopathic Training) research and the National Council for Osteopathic Research (NCOR) reports. The three main recommendations from the UrGEnT research are that education providers prioritise actions to clarify institutional policies and processes to make sure they are accessible and effective in maintaining an inclusive educational environment; to review the adequacy of current student support services, particularly for underrepresented groups; and to provide EDI and communications skills training for staff to increase awareness about students’ learning needs and explore attitudinal barriers to change.
- Our work to improve the clarity and transparency of our fitness to practise process for osteopaths, employers and the public. This was done to help reduce barriers to raising concerns and included making changes to our website and to our annual fitness to practise report, and publishing our podcast on this topic.
However, we know that demonstrating real change requires meaningful consideration and time. In line with the recommendations outlined in the recently published Mann Review we are committed to working with and learning from our colleague regulators and organisations with expertise to make meaningful change. This is a journey and we strive to keep learning from our peers and experts in this important field.
As part of this, in May 2026 we joined the Care Quality Commission, General Medical Council, Nursing and Midwifery Council and other regulators to sign a commitment to nine shared anti-racism principles aimed at tackling racism in the workplace at every level of the health and social care system.
The problem with data
The PSA assessment suggests that more complete data sets are needed to demonstrate fairness or unfairness in our procedures year to year. We disagree with this.
As well as the usual data and evidence that the PSA asks for, we also provided the following data analysis during March and April 2026:
- Information on the number of students that enrolled and progressed through osteopathy education from 2023 to 2026
- Diversity data for osteopaths who had concerns raised about them considered as part of our fitness to practise process, and who were then involved in hearings about these concerns during 2025 to 2026
- An explanation of numbers for data related to those who raised concerns and complaints – even though we had just under 10% response overall, because some categories of information were very small which meant we could not share the numbers because individuals in those categories would be able to be identified.
- The scope of an independent audit (carried out over 12 months) that we commissioned to assess unfairness in our fitness to practise procedures which was carried out in 2025.
The issue with our data is that we struggle to have enough of it. We have:
- 5,597 osteopaths
- currently, fewer than 900 students across up to 6 year groups
- fitness to practise concerns in the region of 95 during the reporting period (higher than our usual 65 to 70)
- referrals from the independent screeners in the region of 50
- and during the reporting period, in the region of 25 Professional Conduct Committee hearings
This means getting enough EDI data that supports statistically robust trend analysis and clear conclusions naturally takes longer than it would for larger regulators.
As well as this we have 10 Council members, 18 fitness to practise panellists and 4 external Education Committee members (numbers are restricted in legislation) who make up our non-executive senior decision makers. The numbers are again small which means that publishing their EDI data is difficult – because the smaller the number, the more likely it is that a person can be identified.
Trying to draw meaning from smaller numbers can also be much more difficult, unless the information is considered over a period of much longer than a year. Regardless of this we continue to hold this data internally and it is considered annually, and we collect EDI data through our recruitment campaigns from the people why apply to work at the GOsC. Collecting this information has shown us that, as a result of our recruitment strategy, we have been able to attract more diverse candidates for the roles we advertise.
The challenge is the same when it comes to our 30 or so staff members, of which 25 are whole time equivalent roles and just 8 are part of our fitness to practise team.
In smaller datasets, even minor changes in responses can lead to proportionally larger statistical changes, which means patterns become inconsistent and do not have meaning year to year, but only over longer periods of time. We take this into account when interpreting results, assessing emerging trends and deciding where our resources go to have the most impact.
Our approach to both the collection of EDI information and how we analyse this information has therefore been proportionate and pragmatic. We aim to gather meaningful insight while ensuring that the data is reliable and used in a responsible way.
A lot of our EDI data falls into categories with fewer than ten individuals. In these cases, we cannot publish or share the information due to the risk of inadvertently identifying specific individuals. Protecting confidentiality and maintaining trust in our data processes remain our core priorities.
Conclusion
As it stands, we have significant concerns that the PSA report appears to have failed to consider the context affecting how we regulate, and both the evidence that we have submitted and its own guidance, which says:
“We take into account specific circumstances facing individual regulators, for example those caused by differences in legislation, size or source of referrals. We encourage individual regulators to discuss these challenges with us so that we maintain a comprehensive view of the circumstances in which they operate.”
For Outcome 3, we disagree with PSA’s conclusion that we did not provide robust EDI analysis and that we have not provided enough assurance about how we make fair decisions across all of our regulatory functions. We think this fails to take account of the work we have done and the information we gave to the PSA, which we have outlined in our more detailed response.
We know that demonstrating real change does not happen quickly and requires meaningful consideration and collaboration with other regulators and experts. We also recognise that this is a journey, but our view is that the current report – which says that there are ‘significant gaps in our data’ – is misleading to anyone in our sector who is interested in our work. It is also misleading for the wider public who read the report, and fails to recognise the commitment we have shown to improving our work in this area already. This has the potential to damage trust.
We are asking for the PSA to support us to understand what good looks like in the collection and analysis of data for small regulators in our context and how we can better work together to achieve this, while also making sure that our efforts and resources are being used for meaningful change.
