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Up until recently, the government had legislated that medical emergencies in a muddy festival field, sports arena, or any other large-scale temporary gathering required less oversight than in any other care setting.
Driven by the findings of the Manchester Arena Inquiry, the Health and Social Care Act (Amendment) Regulations 2026 now remove these exemptions.
Here is our breakdown of what you need to know before the 2027 deadline.
Treatment of Disease, Disorder or Injury (TDDI) vs. First Aid
The Care Quality Commission (CQC) is removing the exemptions for sports grounds and temporary events. If you provide TDDI, you need to be CQC registered. But what is the difference between TDDI and First Aid?
The CQC set out their definition of TDDI here, and it is summarised below:
- Regulated Activity (TDDI): If a registered health care professional, as stipulated by CQC, who uses their professional title to diagnose, monitor, or formulate a treatment plan, you MUST be CQC registered.
- Exempt First Aid: First aid covers immediate symptom relief and the use of basic diagnostic tools (such as ECGs or pulse oximeters) by non-healthcare professionals, solely to determine whether a 999 emergency referral is needed. Further details are in our FAQ.
The need to keep first aid exempt is primarily due to CQC capacity, but also the implications of including it would have far-reaching consequences as set out here.
Timelines for Compliance
The changes in regulation have two key dates all providers must be aware of
Sept 7, 2026: CQC Registration opens.
Dec 6, 2027: CQC Criminal enforcement begins.
That gives providers 15 months to become successfully registered. Current experience shows that applications are taking between 16 and 24 weeks, and the CQC are being ruthless in accepting applications. Missing details or incomplete fields will cause the application process to restart.
The CQC’s application process is not currently digital, so applicants must wait for a manual initial review of their forms before progressing to the registration phase. Providers who delay applying and wait until 2027 risk being unable to deliver their service model legally.
Those who read the play well will have their application ready to go for September 2026.
The Core Documentation
The CQC have tightened up their scrutiny of applications to clear backlogs. Incomplete or inaccurate applications are now rejected immediately, with no second chance to submit missing information.
To be successful, you need:
- A customised policy suite (Safeguarding, Medicines Management, IP&C).
- Verified vetting process including “Fit and Proper” persons with Enhanced DBS checks.
- A suitable Registered Location
- Appointed Registered Managers and Nominated Individuals.
- A financial viability statement
- Registration with the Information Commissioner’s Office
- Relevant Insurance
Importantly, all the documentation you provide must accurately reflect day-to-day operations.
Learning from the Past
We can learn from other areas of healthcare when regulations change or interpretations are clarified. The recent NHS England guidance on Ambient Voice Technologies (AVT) has sparked a significant shift in the AI scribe market, transforming regulatory compliance from a hurdle into a competitive advantage. By establishing a national Supplier Registry that mandates at least MHRA Class 1 registration, the NHS effectively “ordered” a stop to the use of unregistered tools, forcing manufacturers into a race for legitimacy. Likewise, the implementation of the National Data Opt alongside the GDPR in 2018 increased public awareness and trust in how data is used for planning and research in the NHS. This paved the way for more robust data governance frameworks and better quality research data.
If you are a sports club looking for medical cover for the 2027/28 season, you shouldn’t risk signing a provider who is still awaiting registration before this season starts.
As with other areas of private healthcare, CQC registration and then subsequent post-inspection ratings are seen as a certificate of competence. For event organisers, hiring an unregistered provider after Dec 2027 won’t just be a “risk”—it will be a criminal breach that invalidates your insurance and threatens your premises license.
What do you need to do?
Appoint the Registered Manager
Identify the person within your organisation who will be your Registered Manager. This individual must have an indepth knowledge of the regulations and how they apply to your business.
Demonstrate Regulatory Understanding from a “Can-Do” Stance
You’ll need to ensure you lean into the regulations and figure out how to apply them to your business model. Examples of questions to ask yourself include:
- How do you ensure privacy when using a tent as a temporary medical facility?
- How do you implement robust infection prevention and control measures?
- What is your business continuity plan? Does it include adverse weather conditions, and does it take into account any temporary buildings/ tents used?
- How do you transition a medical room from a non-event day to an event day?
- How are you assured of your team’s competence?
Monitor New Standards
Keep track of the soon-to-be-published Event Healthcare Standard, which will help clarify expectations for the sector.
We understand what good looks like, and we have been there. Whilst it might appear that the CQC and the industry are finding their feet with this “new sector”, in reality, the benchmarks already exist. The regulations are a constant. The CQC has already made it clear what governance arrangements it expects to see, and by drawing on the years of experience our team has in helping providers in the independent care sector, we can work with your team to demonstrate to the CQC how you have effectively applied the regulations to your delivery model.
Frequently Asked Questions
We’ve pulled together some FAQ’s for the most common environments that will feel the impact of this change in the regulation.
Does the club’s medical department need its own CQC registration?
If a professional team employs its own doctors, physiotherapists, or paramedics to treat players (Treatment of Disease, Disorder or Injury – TDDI), the club itself must register as a provider. If the club “outsources” this to a private clinic or hospital group, that external provider must be registered and list the stadium as a satellite location.
Are "Match Day" medical services for fans now in scope?
Yes. Previously, medical care for spectators at sports grounds was exempt. Now, any fan-facing medical service that goes beyond basic first aid (e.g., a stadium doctor assessing a suspected heart attack or a paramedic administering meds) must be provided by a CQC-registered entity.
Does this apply to the treatment of professional athletes during training?
Yes, the CQC does not distinguish between a “patient” and an “athlete.” If a club doctor or physio provides clinical assessment or treatment for an injury at a training ground, they are performing a regulated activity. The club must ensure this falls under a formal clinical governance framework registered with the CQC.
Does an ice bath or a recovery suite count as "treatment"?
Standard sports science and recovery (massages, ice baths, nutritional support) usually stay out of scope. However, if the facility is used for clinical interventions, such as ultrasound-guided injections or the management of chronic conditions by a doctor, it likely requires registration under Treatment of Disease, Disorder or Injury (TDDI).
Do we need a "Registered Manager" for the stadium’s medical room?
Yes. Every registered provider must appoint a Registered Manager—often the Head of Medical or a Senior Physician—who is legally accountable for the quality and safety of care provided on-site. They must pass a CQC “fit and proper person” interview.
How does this affect our stadium’s Green Guide (SGSA) compliance?
The Sports Grounds Safety Authority (SGSA) is aligning its “Green Guide” with these CQC changes. Your match-day medical plan will now be considered incomplete or non-compliant by local authorities if your provider cannot demonstrate a valid CQC registration.
What is classed as First Aid under the new regulations?
Under CQC guidelines, the legal exemption for “first aid” covers the immediate alleviation of symptoms and simple, non-invasive procedures designed to prevent a patient’s condition from worsening. If an activity is strictly classed as first aid, it does not require CQC registration.
Crucially, the legal definition of first aid is broader than many realise. It officially permits the use of certain non-invasive diagnostic and monitoring tools—such as electrocardiograms (ECGs), pulse oximeters, blood pressure monitors (sphygmomanometers), ophthalmoscopes, and thermometers.
However, these tools are exempt only when used strictly to determine whether a patient requires an onward emergency referral (such as calling 999). If this equipment is used for continuous patient monitoring, formal clinical diagnosis, or to guide ongoing treatment plans, the activity crosses the threshold into regulated clinical care (Treatment of Disease, Disorder, or Injury – TDDI) and requires CQC registration.
Finally, while first aid is typically associated with trained lay responders, the exemption also applies to qualified healthcare professionals, provided they deliver care solely in an unexpected emergency “Good Samaritan” capacity rather than as part of a structured, rostered clinical service. For events, this means you can not arrange to have a doctor on site just in case, but if one is in attendance, say as a visitor, they can help.
FAQs - Greenfield Events
Does a temporary medical centre on a greenfield site count as a "location" for CQC registration?
While the site is temporary, the activity (TDDI) is what triggers the need for registration. The medical provider must be registered to provide these services. Since there is no physical location, the administrative hub will likely serve as the registered location.
If we provide "sobering-up" tents or welfare areas, are these now under CQC scope?
If these areas only provide hydration, warmth, and monitoring by non-clinicians, they generally remain “Welfare” and out of scope. However, if a clinician in that tent provides medical treatment (like IV fluids for dehydration or clinical observations for drug toxicity), or If non-clinicians are delivering care or monitoring patients under treatment protocols or Patient Group Directions (PGDs) established by a listed healthcare professional (such as an event doctor acting as clinical lead), the activity is legally classed as being “under the supervision of” that professional.it becomes a regulated activity.
How do these regulations affect our temporary hospitals or clinics?
These clinics are the primary target of the regulatory change because they often perform advanced procedures (such as stitching, X-rays, or administering prescription-only medications). Under the new rules, these facilities must meet the same fundamental standards of safety and governance as a permanent urgent care centre.
Can we still use local volunteer first aid groups?
You can, but their role must be strictly limited to basic first aid (e.g., bandages and minor cuts). If you expect them to handle the complex medical needs typical of a multi-day greenfield event, you must ensure they have transitioned to a CQC-registered status or are working under the governance of a registered lead provider
Does the presence of a "Registered Manager" apply to our temporary event?
The CQC requires every registered provider to have a designated Registered Manager who is legally responsible for the quality of care. For a greenfield event, you should confirm who this individual is for your medical contractor and that they have oversight of the specific clinical team on your site.
If I am already registered for "Transport" and "Triage," do I still need to apply for "Treatment of Disease, Disorder or Injury" (TDDI)?
Yes, because your current registration only covers moving patients or assessing their priority, not the actual clinical care provided on-site. Without the TDDI activity on your certificate, you are not legally authorised to perform medical interventions like wound care, administering meds, or definitive clinical assessments at an event.
Need help registering with the CQC?
Our team of ex-CQC Inspectors and Healthcare Governance professionals can help you prepare and maintain your registration with the CQC. Book a free consultation with our team today.
