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DEXA Scan Regulation in England: What Providers Must Know

Writer: Liam
Liam
2 days ago
4 min read
Navy and teal graphic with the title "DEXA Scan Regulation in England" beside a stylised skeleton on a scanner panel, labelled justify, optimise and register.
DEXA scan regulation in England: what IR(ME)R and CQC registration mean for providers in 2026.

DEXA scan regulation is one of the most misunderstood areas I deal with, particularly among private body composition and sports clinics. I see plenty of enthusiasm for DEXA and a fair amount of confusion about what is lawful. Here is where things stand in October 2026.


Why DEXA is regulated


DEXA (dual-energy X-ray absorptiometry) uses low-dose ionising radiation. That brings it within the Ionising Radiation (Medical Exposure) Regulations 2017, known as IR(ME)R, as amended in 2024. In England, the Care Quality Commission is the enforcing authority for IR(ME)R, and the regulations apply equally to the NHS and the independent sector.


Separately, CQC's scope of registration guidance confirms that procedures using any form of radiation, including X-ray, fall within the regulated activity of diagnostic and screening procedures. That activity also covers the analysis and reporting of the examinations you carry out.


The legal position on sports and wellness DEXA


On 30 March 2026, the government confirmed that DEXA is permitted for medical purposes, such as diagnosing osteoporosis, assessing fracture risk, monitoring treatment and medical research. It also stated that non-medical DEXA for sports and wellness purposes is not justified under the Justification of Practices Involving Ionising Radiation Regulations 2004 (JoPIIRR). In the government's words, providing it is prohibited, and providers doing so are operating outside the JoPIIRR framework. The consultation document notes that DEXA for insurance or legal purposes, with no medical indication, is permissible.


The Department of Health and Social Care consulted on changing this between March and June 2026. Its response, published on 7 October 2026, reports 397 responses. Most supported justification, especially for elite athletes, while medical and healthcare professionals were more cautious. No final decision has been made. Until it is, a body composition scan sold direct to the public for fitness is not something I would advise any client to offer.


What IR(ME)R requires


Whether your service is medical or a future justified non-medical service, the core framework is the same.


Duty holders. The employer must have written procedures and ensure they are followed. The referrer must be a registered healthcare professional entitled under those procedures, and must give the practitioner enough medical data to decide whether there is a sufficient net benefit. The practitioner, also a registered healthcare professional, is responsible for justification. Operators carry out practical aspects and are responsible for each one they perform.


Justification. Under regulation 11, no exposure can take place unless the practitioner has justified it as showing a sufficient net benefit and it has been authorised. The practitioner must weigh the objectives, the potential benefits, the individual detriment and alternatives involving less or no radiation. For asymptomatic individuals, the practitioner must have regard to relevant guidelines, and some procedures require specific documented justification by the practitioner in consultation with the referrer.


Employer's procedures. Schedule 2 lists what your written procedures must cover, including identifying the individual, entitlement of duty holders, pregnancy and breastfeeding enquiries, giving people information about the benefits and risks of the dose before exposure, clinical evaluation of each exposure and specific procedures for non-medical imaging exposures.


Optimisation. Regulation 12 requires doses to be kept as low as reasonably practicable for the intended purpose.


Non-medical imaging


IR(ME)R defines a non-medical imaging exposure as a deliberate exposure for imaging using medical radiological equipment where the primary intention is not to bring a health benefit to the individual. Regulation 3 brings these exposures within scope, and regulation 11 requires them to comply with the employer's procedures for such exposures. The Society of Radiographers' DXA guidance gives total body scans for body composition in limited, justified cases, such as sports science, as an example. Being covered by IR(ME)R is not the same as being permitted, however. The practice itself still has to be justified under JoPIIRR.


Self-referral


Because IR(ME)R defines a referrer as a registered healthcare professional entitled under the employer's procedures, a client booking themselves in online cannot be their own referrer. If your model relies on self-referral, your referral pathway needs rethinking.


Consultation, consent and safeguards


The government consultation summarises the 2019 advice of COMARE (the Committee on Medical Aspects of Radiation in the Environment). COMARE advised that sports DEXA could be justified but should only be considered as part of a recognised training programme, with limits on scan frequency, particular caution for children and no knowing use in pregnancy. It also said consent procedures would need to set out how incidental findings are handled, including referral of images and results to a medical doctor. The consultation asked whether children, young people and pregnant individuals should be excluded and whether scans should be limited. These are proposals, not rules, but they show where safeguards are heading.


What CQC is finding


CQC's IR(ME)R annual report 2025/26, published on 13 October 2026, records 996 statutory notifications and 83 inspections. Recurring inspection themes included employer's procedures, training and entitlement records, justification and authorisation, referral management and governance. In my experience, these are exactly the areas where new DEXA services fall short.


My advice


If you want to offer DEXA in England, build a genuine clinical pathway with entitled referrers and practitioners, put robust employer's procedures in place, register for diagnostic and screening procedures (my registration application support at https://www.cqcconsultancy.net/registration-application-support covers this) and watch closely for the government's decision on non-medical DEXA. Do not launch a sports or wellness service on the assumption that it will be approved.


How I can help you register


As a former CQC inspector, I know what CQC looks for in a DEXA application. I advise on the correct regulated activity, which for DEXA is diagnostic and screening procedures, and complete your provider and Registered Manager applications with you. I write your IR(ME)R employer's procedures and governance policies, and I prepare your Registered Manager for their interview. Find out more about my registration application support at https://www.cqcconsultancy.net/registration-application-support


Sources


Care Quality Commission, Ionising Radiation (Medical Exposure) Regulations (IR(ME)R): https://www.cqc.org.uk/guidance-providers/ionising-radiation/ionising-radiation-medical-exposure-regulations-irmer


Care Quality Commission, IR(ME)R annual report 2025/26: https://www.cqc.org.uk/publications/irmer-annual-report/2025-2026



The Ionising Radiation (Medical Exposure) Regulations 2017: https://www.legislation.gov.uk/uksi/2017/1322/contents



IR(ME)R Schedule 2, employer's procedures: https://www.legislation.gov.uk/uksi/2017/1322/schedule/2





 
 
 

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