Regulatory Crisis at the Nursing and Midwifery Council: A Comprehensive Analysis and the Case for Modern Regulatory Management Systems

Abstract

The Professional Standards Authority's (PSA) 2023/24 performance review of the Nursing and Midwifery Council (NMC) revealed unprecedented regulatory failures, with the organization meeting only 11 of 18 Standards of Good Regulation—the worst performance since 2018/19. This analysis examines the systematic breakdowns in culture, governance, and operational functions that led to this crisis, explores the implications for public safety and professional regulation, and demonstrates how modern regulatory management platforms like GovCore could have provided early warning systems and preventive interventions. The findings highlight critical weaknesses in safeguarding, education quality assurance, fitness to practise processes, and equality, diversity, and inclusion (EDI) implementation, while illustrating how advanced regulatory technology can systematically identify and address sub-optimal performance before it becomes total failure.

Introduction

The Nursing and Midwifery Council, which regulates 850,707 healthcare professionals across the United Kingdom, experienced a significant regulatory crisis during 2023/24. The PSA's periodic review, published in June 2025, documented systematic failures across multiple regulatory functions, marking only the second time a regulator has failed to meet seven or more standards in a single year. This unprecedented breakdown occurred against a backdrop of whistleblowing disclosures that exposed deep-seated cultural and operational problems within the organization.

The crisis at the NMC is particularly significant given the vital role nurses and midwives play in healthcare delivery. Any regulatory failure potentially compromises patient safety and undermines public confidence in professional healthcare standards. This analysis provides a comprehensive examination of the failures identified, their root causes, and demonstrates how modern regulatory management systems could have provided early detection and prevention of these systematic breakdowns. The case study illustrates the critical need for advanced regulatory technology platforms that can identify performance deterioration before it reaches crisis levels.

Methodology

This research synthesizes findings from multiple sources:

The PSA's comprehensive 2023/24 performance review
The Independent Culture Review (ICR) conducted by Rise Associates
Internal NMC audit findings and strategic risk assessments
Stakeholder feedback and audit evidence
Comparative analysis with historical performance data

The analysis focuses on the seven unmet standards and their interconnected causes, examining both immediate operational failures and underlying systemic issues.

Key Findings

Systemic Cultural Breakdown

The ICR's findings revealed a profound organizational culture crisis that permeated all aspects of the NMC's regulatory functions. The review concluded that "the NMC had strayed from its central mission" and found evidence of "a culture that is seemingly not open to feedback and opportunities to improve when things go wrong." This cultural dysfunction manifested in several critical ways:

Loss of Regulatory Focus: Staff and stakeholders reported that "there had been a cultural shift in the last few years, away from the NMC's core business of Fitness to Practise and moving into trying to influence other areas such as policy."

Governance Failures: The ICR was critical of governance, noting it "led to mistrust, there is little faith in decision making and the duty of candour responsibility for healthcare professionals to be honest when things go wrong has become anathema at the NMC."

Resistance to Criticism: The review identified a pattern of hostility toward whistleblowers and a systematic failure to implement recommendations from previous reviews.

Critical Operational Failures

Safeguarding Deficiencies (Standard 17)

Perhaps most concerning were the failures in safeguarding—the NMC's ability to identify and prioritize cases posing serious risks to public safety. The ICR documented "multiple examples where safeguarding cases have been closed down by screening teams" and noted concerns about "a lack of a safeguarding lens in casework despite the availability of expert advice."

An internal audit revealed "there has been a failure to identify and act on safeguarding concerns," leading safeguarding to become the NMC's highest-rated strategic risk. The implications of these failures cannot be overstated—even small numbers of safeguarding failures can represent serious risks to vulnerable populations.

Education Quality Assurance Breakdown (Standard 9)

The NMC's ability to ensure the quality of nursing and midwifery education suffered severe compromises. A mandatory self-reporting exercise revealed that the NMC had failed to detect through routine monitoring that some education providers were not complying with basic standards, including "clear requirements about how to calculate the required practice hours."

The subsequent analysis identified "a number of issues concerning non-compliance with standards which the NMC had not detected through its routine monitoring," indicating fundamental failures in the regulatory oversight of education. This breakdown directly compromised the integrity of professional preparation.

Registry Integrity Issues (Standard 10)

Over 350 individuals joined the NMC register without completing required practice hours, while additional registrants may have gained entry fraudulently through compromised testing centers in Nigeria and India. These failures strike at the heart of professional regulation—ensuring only qualified individuals can practice.

Fitness to Practise Delays (Standard 15)

The NMC continues to fail in processing fitness to practise cases in a timely manner, with cases taking too long to process and a significant backlog persisting. The organization "has not met this Standard since 2018/19," indicating a long-standing systemic problem.

Equality, Diversity, and Inclusion Failures

Despite having processes in place to promote EDI, the PSA "could not be assured that these processes were working effectively" due to ICR findings about discrimination and organizational culture. This failure is particularly significant given the diverse workforce the NMC regulates and the populations they serve.

How Modern Regulatory Management Systems Could Have Prevented the Crisis

The Power of Predictive Analytics and Early Warning Systems

The NMC crisis exemplifies what happens when regulatory bodies lack sophisticated monitoring and early warning capabilities. Modern regulatory management platforms like GovCore demonstrate how advanced technology can systematically identify and address sub-optimal performance before it escalates into total failure.

Real-Time Performance Monitoring: A platform like GovCore would have provided continuous monitoring of key performance indicators across all regulatory functions. Instead of the NMC's delayed recognition of problems, automated systems would have flagged declining performance in:

Fitness to practise case processing times
Education quality assurance gaps
Registry integrity issues
Safeguarding case handling

Predictive Risk Assessment: Advanced AI algorithms can analyze patterns in regulatory data to predict where failures are likely to occur. The NMC's "strategic risks all rated Red or Amber" situation could have been anticipated months or years earlier through predictive modeling of performance trends.

Integrated Data Analytics: The NMC's acknowledged "limited data capability" represents exactly the type of infrastructure gap that modern platforms address. GovCore's integrated approach to data management would have provided:

Single source of truth for all regulatory activities
Cross-functional visibility into performance patterns
Automated identification of anomalies and trends
Real-time dashboards for executive decision-making

Automated Compliance and Quality Assurance

Education Provider Monitoring: The NMC's failure to detect non-compliance with practice hour requirements through "routine monitoring" demonstrates the limitations of manual oversight systems. Modern platforms provide:

Automated compliance tracking for all education providers
Real-time verification of student progress and requirements
Immediate alerts when standards are not met
Comprehensive audit trails for all educational activities

Registry Integrity Protection: The entry of over 350 unqualified individuals onto the NMC register could have been prevented through:

Automated verification of qualification requirements
Real-time cross-referencing of educational records
AI-powered fraud detection for application anomalies
Blockchain-based credential verification systems

Continuous Compliance Monitoring: Rather than discovering problems through whistleblowing or external review, modern systems provide:

Continuous monitoring of all regulatory processes
Automated detection of policy deviations
Real-time compliance scoring and reporting
Proactive alerts for emerging risks

Cultural and Organizational Health Monitoring

Digital Culture Assessment: Modern regulatory platforms can track organizational health indicators that predict cultural problems:

Response times to citizen complaints
Internal escalation patterns
Staff turnover in critical functions
Training completion rates and effectiveness

Stakeholder Sentiment Analysis: Advanced platforms can monitor external stakeholder feedback to identify emerging cultural issues:

Automated analysis of public consultations
Social media sentiment monitoring
Professional body feedback aggregation
Citizen complaint pattern analysis

Transparency and Accountability Mechanisms: Technology platforms can enforce cultural change through:

Mandatory reporting and escalation protocols
Public-facing performance dashboards
Automated stakeholder communication
Built-in whistleblower protection systems

Case Study: How GovCore Would Have Addressed Each Failed Standard

Standard 2: Purpose and Policy Application

The Problem: The ICR found the NMC had "strayed from its central mission" with performance issues across multiple functions.

The GovCore Solution:

Mission Alignment Monitoring: Automated tracking of resource allocation against core regulatory functions
Performance Integration: Cross-functional dashboards showing how activities align with public protection mandate
Strategic Risk Management: AI-powered early warning systems for mission drift
Executive Reporting: Real-time visibility into organizational focus and performance

Standard 9: Education Quality Assurance

The Problem: Mandatory self-reporting revealed the NMC failed to detect education provider non-compliance through routine monitoring.

The GovCore Solution:

Continuous Provider Monitoring: Real-time tracking of all education providers against compliance requirements
Automated Verification: Digital verification of student practice hours and educational requirements
Risk-Based Inspections: AI algorithms determining inspection priorities based on risk factors
Integrated Reporting: Centralized platform for all education quality assurance activities

Standard 10: Registry Integrity

The Problem: Over 350 individuals joined the register without meeting requirements, plus fraudulent entries from compromised testing centers.

The GovCore Solution:

Automated Eligibility Verification: Real-time checking of all qualification requirements before registration
Fraud Detection Systems: AI-powered analysis of application patterns to identify anomalies
Blockchain Verification: Immutable credential verification systems
Continuous Registry Auditing: Ongoing verification of registrant qualifications

Standard 15: Fitness to Practise Timeliness

The Problem: Cases taking too long to process with significant backlogs, failing this standard since 2018/19.

The GovCore Solution:

Workflow Automation: Automated case progression through standardized processes
Resource Optimization: AI-powered resource allocation based on case complexity and urgency
Predictive Analytics: Forecasting case volumes and identifying bottlenecks before they occur
Performance Management: Real-time tracking of case processing times and outcomes

Standard 17: Safeguarding and Risk Identification

The Problem: Internal audit showed failure to identify and act on safeguarding concerns, making this the highest strategic risk.

The GovCore Solution:

Risk Scoring Algorithms: Automated assessment of case risk levels based on multiple factors
Priority Escalation: Immediate flagging and escalation of high-risk cases
Cross-Case Analysis: Pattern recognition across multiple cases to identify systemic risks
Continuous Monitoring: Real-time tracking of all safeguarding-related activities

The Economic Case for Modern Regulatory Management

Cost of Regulatory Failure

The NMC crisis demonstrates the enormous costs of regulatory failure:

Direct Costs: £30 million invested in fitness to practise improvements alone
Opportunity Costs: Senior leadership time diverted to crisis management
Reputational Costs: Damage to public and professional confidence
Compliance Costs: Resources required for multiple independent reviews and oversight

Return on Investment for Modern Platforms

Modern regulatory management platforms like GovCore deliver measurable returns through:

Prevention vs. Remediation: Early detection prevents expensive crisis management
Operational Efficiency: Automation reduces manual processing costs
Resource Optimization: Better allocation of inspection and oversight resources
Risk Reduction: Proactive identification reduces public safety incidents

Scalability and Adaptability

Unlike traditional systems that require extensive customization, modern platforms offer:

Rapid Deployment: Cloud-based systems can be implemented quickly
Configurable Workflows: Adaptable to specific regulatory requirements
Integration Capabilities: Seamless connection with existing systems
Continuous Updates: Regular enhancement of AI algorithms and capabilities

Implementation Roadmap for Regulatory Transformation

Phase 1: Assessment and Foundation (Months 1-6)

Comprehensive audit of current systems and processes
Stakeholder requirements gathering
Platform selection and customization
Initial data integration and migration

Phase 2: Core System Deployment (Months 7-12)

Implementation of core regulatory management functions
Staff training and change management
Pilot programs with selected regulatory areas
Initial performance monitoring and optimization

Phase 3: Advanced Analytics and AI (Months 13-18)

Deployment of predictive analytics capabilities
Implementation of automated risk assessment
Advanced reporting and dashboard configuration
Integration with external data sources

Phase 4: Optimization and Expansion (Months 19-24)

System optimization based on performance data
Expansion to additional regulatory functions
Advanced AI features and machine learning
Continuous improvement processes

Lessons for Other Regulatory Bodies

Universal Principles

The NMC crisis offers several lessons applicable to all regulatory bodies:

Technology is Not Optional: Modern regulatory challenges require modern solutions
Early Warning Systems Save Lives: Proactive monitoring prevents public safety incidents
Integration Prevents Silos: Connected systems provide holistic oversight
Transparency Builds Trust: Real-time reporting enhances public confidence

Underlying Systemic Issues and Technology Gaps

Data and Technology Deficiencies

A recurring theme across multiple failures was the NMC's inadequate data capabilities. The organization acknowledged it "does not currently have the capacity in terms of data, processes, or resource within the team" to effectively manage education quality assurance risks. This technological weakness undermined multiple regulatory functions.

Resource and Capacity Constraints

The NMC noted it "underestimated how long it would take to implement productivity improvements" and acknowledged that "due to its historic underinvestment in its people and building its capabilities, it is harder to deliver sustained improvements."

Leadership Instability

The organization continued to have "a number of vacancies at Executive Director level, for which there are currently numerous Interim Directors," contributing to organizational instability during a critical period.

Comparative Analysis and Historical Context

The 2023/24 performance represents a dramatic decline from previous years. The NMC had consistently met 17 out of 18 standards in 2020/21, 2021/22, and 2022/23, making the drop to 11 out of 18 standards particularly stark. This performance was "notable in that it is only the second time, after the Pharmaceutical Society of Northern Ireland in 2023/24, that a regulator has not met this many Standards in a single year."

Implications for Public Safety and Professional Regulation

Immediate Public Safety Concerns

The convergence of safeguarding failures, education quality assurance breakdowns, and registry integrity issues creates a perfect storm of public safety risks. When regulatory systems fail to:

Identify high-risk practitioners
Ensure proper professional preparation
Maintain accurate professional registers
Process fitness to practise cases efficiently

The cumulative effect significantly compromises public protection.

Broader Regulatory Implications

The NMC crisis raises fundamental questions about regulatory resilience and the adequacy of oversight mechanisms. The systematic nature of the failures suggests that existing governance structures were insufficient to prevent or detect the breakdown before it reached crisis proportions.

Professional Confidence and Workforce Implications

The ICR noted that some panel members expressed concerns about discrimination awareness and support for vulnerable people in hearings, while stakeholders reported that "drawn out investigations had been a contributory factor to six nurses taking their lives in the prior year." These impacts extend beyond regulatory compliance to affect the wellbeing of the regulated workforce.

Reform Efforts and Prospects for Recovery

Immediate Response Measures

The NMC has undertaken several immediate reforms:

Accepting all 36 ICR recommendations
Establishing transformation plans for culture, fitness to practise, and EDI
Creating a safeguarding hub and board
Investing £30 million in fitness to practise improvements

Oversight Mechanisms

The PSA established an Independent Oversight Group (IOG) including "senior representatives from all four UK governments, professional bodies, and relevant experts" to monitor the NMC's improvement efforts.

Challenges to Reform

Several factors complicate the reform process:

The scale and interconnected nature of the problems
Historical failures to sustain improvements from previous reform efforts
Resource constraints and capacity limitations
The need to maintain regulatory functions while implementing changes

Conclusions and Recommendations: The Imperative for Modern Regulatory Technology

The NMC crisis represents a regulatory failure that was both predictable and preventable. The systematic breakdown across multiple functions—from safeguarding to education quality assurance—demonstrates how organizational culture problems can cascade into operational failures with serious public safety implications. More importantly, it illustrates the critical gap between traditional regulatory oversight methods and the sophisticated monitoring capabilities available through modern regulatory management platforms.

The Technology Imperative

From Reactive to Predictive: The NMC's crisis was characterized by reactive responses to problems that had been developing for years. Modern platforms like GovCore transform regulatory oversight from reactive crisis management to predictive risk prevention. The technology exists today to:

Identify performance degradation before it becomes failure
Predict where regulatory breakdowns are likely to occur
Automate compliance monitoring to prevent registry integrity issues
Provide real-time visibility into organizational health and culture

The Cost of Delay: Every day that regulatory bodies continue to rely on outdated systems and manual processes represents increasing risk to public safety and organizational sustainability. The NMC's £30 million crisis remediation cost could have funded a comprehensive regulatory management platform with advanced AI capabilities for multiple years.

Strategic Recommendations for Regulatory Bodies

Immediate Technology Assessment: All regulatory bodies should conduct immediate assessments of their technology infrastructure against modern standards. Organizations still relying on manual processes, disconnected systems, or reactive monitoring are at high risk for NMC-style failures.
Adopt Integrated Platforms: Regulatory bodies should prioritize integrated regulatory management platforms that provide:
- Real-time performance monitoring across all functions
- Predictive analytics for early warning of problems
- Automated compliance tracking and verification
- Centralized data management and reporting
Invest in Preventive Technology: The return on investment for modern regulatory platforms is measured not just in operational efficiency, but in prevented crises. Regulatory bodies should view advanced technology as essential infrastructure, not optional enhancement.
Continuous Monitoring Culture: Technology alone is insufficient; organizations must develop cultures of continuous monitoring and improvement. Modern platforms provide the tools, but success requires commitment to data-driven decision making and proactive risk management.

Industry-Specific Applications

Different regulatory sectors can benefit from tailored approaches:

Healthcare: Focus on patient safety monitoring, professional competence tracking, and education quality assurance
Financial Services: Emphasis on fraud detection, compliance monitoring, and risk assessment
Environmental: Real-time monitoring of environmental impacts and compliance with regulations
Safety: Continuous monitoring of workplace and public safety standards

The Path Forward

For the NMC: While the organization has committed to transformation, success requires more than cultural change—it demands technological transformation. The NMC should consider modern regulatory management platforms as core infrastructure for its recovery and future success.

For Other Regulatory Bodies: The NMC crisis serves as a warning and an opportunity. Organizations can learn from the NMC's failures and proactively implement systems that prevent similar breakdowns. The technology exists; the question is whether regulatory bodies will embrace it before or after their own crisis.

For Policymakers: Government oversight bodies should consider requiring regulatory bodies to demonstrate adequate technology infrastructure and early warning capabilities. The public deserves regulatory protection that leverages the best available technology.

Final Thoughts: Prevention vs. Remediation

The NMC crisis illustrates a fundamental truth about regulatory oversight: prevention is always more effective and less costly than remediation. Modern regulatory management platforms like GovCore represent the evolution from traditional compliance-checking to intelligent regulatory management. They offer the possibility of regulatory bodies that are:

Proactive rather than reactive
Predictive rather than responsive
Efficient rather than bureaucratic
Transparent rather than opaque
Effective rather than symbolic

The technology exists today to prevent regulatory crises like the one experienced by the NMC. The question facing every regulatory body is not whether they can afford to implement modern regulatory management systems, but whether they can afford not to. The cost of inaction, measured in public safety, professional confidence, and organizational survival, is simply too high.

As the healthcare landscape continues to evolve and regulatory challenges become more complex, the regulatory bodies that thrive will be those that embrace technological transformation as a fundamental requirement for protecting the public interest. The NMC crisis should serve as the catalyst for this transformation across the entire regulatory sector.

Appendix A: Standards Not Met

Standard 2: Purpose and Policy Application

The regulator is clear about its purpose and ensures that its policies are applied appropriately across all its functions and that relevant learning from one area is applied to others.

Key Issues:

The ICR concluded that "the NMC had strayed from its central mission"
Performance issues across multiple regulatory functions
All key strategic risks rated Red or Amber
Leadership instability with numerous interim directors

Standard 3: Equality, Diversity and Inclusion

The regulator understands the diversity of its registrants and their patients and service users and of others who interact with the regulator and ensures that its processes do not impose inappropriate barriers or otherwise disadvantage people with protected characteristics.

Key Issues:

Limited evidence about the impact of EDI work undertaken
ICR made numerous critical findings about EDI embedding
Concerns about discrimination and organizational culture
Failed to meet Outcome 1 under this Standard

Standard 4: Performance Reporting and Learning

The regulator reports on its performance and addresses concerns identified about it and considers the implications for it of findings of public inquiries and other relevant reports about healthcare regulatory issues.

Key Issues:

Inconsistencies in fitness to practise reporting
Significant gaps in education quality assurance reporting
Failed to implement recommendations from previous reviews
Culture resistant to feedback and criticism

Standard 9: Education Quality Assurance

The regulator has a proportionate and transparent mechanism for assuring itself that the educational providers and programmes it oversees are delivering students and trainees that meet the regulator's requirements for registration, and takes action where its assurance activities identify concerns either about training or wider patient safety concerns.

Key Issues:

Mandatory self-reporting exercise revealed failures in routine monitoring
Issues with non-compliance not detected through normal processes
Limited data capability and system failures
Education quality assurance improvement plan not finalized

Standard 10: Accurate Register

The regulator maintains and publishes an accurate register of those who meet its requirements including any restrictions on their practice.

Key Issues:

Over 350 registrants joined without completing required practice hours
Multiple instances of fraudulent applications (CBT, OET, PNC cases)
Large number of people added to register without meeting requirements
Registry integrity compromised

Standard 15: Fitness to Practise Timeliness

The regulator's process for examining and investigating cases is fair, proportionate, deals with cases as quickly as is consistent with a fair resolution of the case and ensures that appropriate evidence is available to support decision-makers to reach a fair decision that protects the public at each stage of the process.

Key Issues:

Cases still taking too long to process
Significant backlog persists
Has not met this Standard since 2018/19
Limited progress despite £30 million investment

Standard 17: Risk Identification and Interim Orders

The regulator identifies and prioritises all cases which suggest a serious risk to the safety of patients or service users and seeks interim orders where appropriate.

Key Issues:

Failure to identify and act on safeguarding concerns
Internal audit showed safeguarding failures
Safeguarding rated as highest strategic risk
Multiple examples of inappropriate case closures

Appendix B: Timeline of Crisis Events

October 2023: Whistleblowing disclosures received by NMC

Autumn 2023: NMC commissions three independent reviews

March 2024: NMC approves latest fitness to practise improvement plan (£30 million investment)

July 2024: Independent Culture Review published with 36 recommendations

September 2024: PSA originally due to publish performance review (delayed)

2024: PSA establishes Independent Oversight Group to monitor NMC improvements

June 2025: PSA publishes 2023/24 performance review

Future: Pending publication of two Omambala KC reviews

Appendix C: Key Stakeholder Responses

PSA Chair Caroline Corby

"The NMC's performance during the review period has caused us considerable concern... Our assessment of the NMC's performance in 2023/24 is notable in that it is only the second time, after the Pharmaceutical Society of Northern Ireland in 2023/24, that a regulator has not met this many Standards in a single year."

NMC Response

The NMC accepted all 36 ICR recommendations and acknowledged that it "needs to tackle issues urgently" while recognizing that "eliminating the problems and transforming our culture successfully will take time."

Government Oversight

The PSA wrote to both the Secretary of State for Health and Social Care (Wes Streeting MP) and the Vice-Chair of The Health and Social Care Select Committee under its escalation policy, requesting meetings to discuss the NMC's performance and support for improvement.

This analysis is based on the Professional Standards Authority's 2023/24 performance review of the Nursing and Midwifery Council, published June 2025, and associated documentation including the Independent Culture Review conducted by Rise Associates.