Adding a New Site to Your Dental Practice: A Guide to CQC Registration Variations
A CQC registration variation is the legal step you must complete before you treat a single patient at a new dental site. I regularly speak to practice owners who have signed a lease, fitted out the surgeries and booked an opening date, only to find that the CQC side has not been started. As a former CQC inspector, I want to explain how the process works so it does not become the thing that delays your opening.
Why a new site needs a CQC registration variation
When you registered with CQC, your locations became conditions of your registration. CQC's guidance on making changes to your registration says you can decide at any time to carry on regulated activity from a different location, but first you must apply to vary that condition. You must have the application granted before you start.
The legal basis is section 19 of the Health and Social Care Act 2008, which lets a registered provider apply for the variation or removal of a condition. Failing to comply with a condition of registration without reasonable cause is an offence under section 33, which the application form itself warns about.
Is it a new location?
CQC's What is a location? guidance sets out 9 rules. For dental care, rule 4 applies: the location is the surgery where dental care is provided at or from. A second practice in another town is a new location.
Not every change is a new location, though:
Moving premises means applying to remove the old location and add the new one, for both the provider and the manager, with all the applications sent together.
Expanding into the unit next door, where the address changes from 1-2 High Street to 1-4 High Street, is not a new location. CQC asks you to apply to vary the condition instead, and may visit.
A building name change with no change to the service only needs a change of contact details notification.
Buying an existing practice involves the seller removing the location and you adding it at the same time, so liaise early.
What to send CQC
The current Provider application: Add a location page holds the forms. CQC says it has updated all its forms and will return applications made on old versions, so always download a fresh copy.
Your application normally includes:
The Add a location provider form. This asks for the location details, the regulated activities and service types at that site, and for dental services, the number of dental chairs.
An additional location section for each extra site if you are adding more than one.
An updated statement of purpose covering the new location. The form is clear that CQC will return your application without it.
Registered manager forms, where required.
A description of how the location will be safe, effective, caring, responsive and well-led. This free-text section is where weak applications fall down.
Everything goes in one email to HSCA_Applications@cqc.org.uk.
The registered manager question
Organisations and partnerships need a registered manager for the regulated activities at each location. The form says managers can sometimes manage more than one location, but CQC needs to be confident that the arrangement works in practice.
You have two main options:
an existing registered manager applies to add the new location using the Add a location manager application
a new manager submits a full registered manager application, even if they have been registered elsewhere
If your current manager will cover both sites, explain how. Who is in day-to-day charge at each site? How often will the manager be present? How will governance, audits and staff supervision work across both? My guide to dental registered manager responsibilities sets out what CQC expects of the role, and becoming a CQC registered manager covers the fit person interview.
Timing: not too early, not too late
The form says you must not begin regulated activity at a new location until it is in your conditions of registration, and that you should not submit if the location is not ready to be assessed. CQC also says it may return applications submitted too far ahead of the effective date.
In my experience, the sweet spot is when the premises are substantially complete, the equipment is commissioned and your key policies and risk assessments for that site are written. Before you submit, have ready:
your infection prevention and control arrangements and decontamination room set up
radiation protection documents for the new X-ray equipment
fire, legionella and electrical safety assessments
emergency medicines and equipment
staffing plans and safer recruitment files for new staff
If any of these are missing when CQC assesses the application, expect questions and delay. My guides to dental infection control and dental radiography compliance cover two of the areas I see most often.
Fees and your statement of purpose afterwards
Adding a site changes your annual fee. CQC's dental services fees page shows that a provider with one location pays by number of chairs, for example £747 for 2 chairs, while a provider with 2 locations pays £1,593 regardless of chairs. The BDA reports that these amounts are unchanged for 2026-27.
Once granted, CQC issues a new certificate of registration. Display it and check the conditions are correct. Keep your statement of purpose under review: the Care Quality Commission (Registration) Regulations 2009 require you to send CQC details of any revision within 28 days.
Common reasons applications are returned
From what I have seen, the most common are:
using an out-of-date form
no updated statement of purpose
missing registered manager applications
submitting before the site is ready, or far too early
a thin answer to the "how will this location be safe" question
I cover more of these in why CQC registration applications are rejected or refused.
How I can help
I prepare CQC registration variation applications for dental providers, from location forms and statements of purpose to manager applications and site readiness checks. I can also carry out a mock inspection of the new site before CQC assesses it. Find out more about my CQC registration application support.
If you'd like help with your registration or variation application, our dental CQC registration support can take you through it.
Sources
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