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 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 the table further below.

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 the table further below) 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:

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:

The issue with our data is that we struggle to have enough of it. We have:

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 the table further below.

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.