CQC Requirement Notice (Now Called an Action Plan Request): What It Means and How to Respond

CQC Requirement Notice (Now Called an Action Plan Request): What It Means and How to Respond

What CQC’s action plan request is, why it was a requirement notice until 2026, how it differs from a warning notice, how long you have to respond and how to write the report CQC will accept.

A CQC requirement notice, now called an action plan request, tells you CQC considers you in breach of a regulation but that people are not at immediate risk. You must send CQC a written report showing how and by when you will comply. CQC’s policy says it is not itself enforcement action. Ignoring it is an offence. Where it is made under Regulation 17(3) you have 28 days from the day after you receive it, and CQC can prosecute that failure directly without first serving a warning notice. If the plan is not satisfactory CQC can refuse it, and a repeat of the breach can lead to a warning notice or action on your registration.

This guide is for registered managers, nominated individuals and directors of care homes, home care agencies and other CQC-regulated services in England. CQC’s enforcement policy now calls what many people still search for as a “requirement notice” an action plan request, and its decision tree says it was “previously called a Requirement Notice”. Some CQC pages and many provider articles still use the old name, so this page uses both.

The wider picture, including warning notices and urgent powers, is in our guide to CQC enforcement action. For how to write the plan itself, see how to write a CQC improvement plan and the action plan template.

What is a CQC requirement notice (action plan request)?

CQC’s policy says that where a registered person is in breach of a regulation but people using the service are not at immediate risk of harm, CQC may use its power to request a report from the provider. This is the action plan request. Making the request notifies you that CQC considers you in breach of your legal obligations. The report must show how you will comply and what action you are taking or propose to take. The planned action must be within a timeframe CQC judges reasonable (CQC: Protecting people by requiring improvement).

It sits at the bottom of the enforcement ladder. In CQC’s decision tree, a low seriousness breach points to an action plan request, a medium one to a warning notice or conditions, and higher scores to suspension, cancellation or urgent action. See the seriousness matrix in our enforcement guide.

When does CQC issue an action plan request?

CQC says it will consider one where:

• the provider is acting in breach of the regulations;
• the impact on people using the service is not immediately significant;
• it assesses that the provider should be able to improve its standards within a reasonable timeframe; and
• the provider has no history of poor performance that gives rise to wider concerns.

CQC’s own worked example in its decision tree shows the line. A GP practice recruited office staff without DBS checks and without a risk assessment explaining why a check was not needed. When this was raised, the practice immediately amended its procedures, required DBS checks for all staff and required previously recruited staff to apply for one. Its history showed it had consistently met the regulations. CQC says an action plan request, not a warning notice or conditions, was the appropriate response.

The two things that kept that case at the lowest level were immediate action and a clean track record. In adult social care, CQC’s 2025 enforcement page, which it marks as under review and which still uses the old name, also says that where a service is repeatedly rated Requires Improvement it will use its power to require an improvement action plan setting out what the provider will do to achieve a better overall rating.

How long do you have to respond?

CQC’s policy says the report must be sent within a set timescale. The legal source is usually Regulation 17(3) of the Health and Social Care Act 2008 (Regulated Activities) Regulations 2014: the registered person must send CQC, when requested and by no later than 28 days beginning on the day after receipt of the request, a written report setting out how, and the extent to which, the governance requirements are being complied with, and any plans for improving the standard of services (Regulation 17). A request for a summary of complaints under Regulation 16(3) runs to the same 28 day rule.

Two practical points:

• Check your letter. It may cite a different regulation or give an earlier date. Work to the earlier date.
• Count from the day after it reaches you. A request received on 1 March has day 1 on 2 March and day 28 on 29 March. Keep the email or envelope showing when it arrived.

What happens if you ignore it or send it late?

Failing to send the requested report within the timescale is an offence. Under Regulation 22(1)(c) it is an offence for a registered person to fail to comply with Regulation 17(3). CQC’s offences page lists Regulations 16(3) and 17(3) among the offences it can prosecute directly, without first issuing a warning notice. A defence is available where the registered person took all reasonable steps and acted with all due diligence.

Separately, an unresolved or repeated breach can lead CQC to choose a stronger response next time. CQC’s decision tree tells staff to consider failures to act on previous requirements and a history of repeated breaches, and both can raise the seriousness of the next action. Fixed penalties and fines are covered in CQC fines and penalties.

Action plan request vs warning notice vs notice of proposal

How to write an action plan CQC will accept

CQC can refuse a plan that does not satisfactorily address the issues, and the actions must be within a timeframe CQC judges reasonable. Promise too much and you miss your own dates. Promise too little, too slowly, and the plan can be rejected. A plan that answers every finding, names an owner and a date for every action, and says how you will check it worked is the safest.

The table shows the layout we recommend. The example row is illustrative, not from a real service:

Five habits make the difference:

1. Answer every finding. List each breach with the regulation, what CQC found and the evidence CQC relied on.
2. Fix the cause, not the symptom. A missing record gets filled in, but whatever made it go missing stays for the next inspection to find.
3. Be specific on dates. Your report tells CQC how and by when you will comply, so the dates you give are the dates CQC will read.
4. Get the provider behind it. A Regulation 17(3) report is about governance. A plan the manager wrote alone, which the owner or board never saw, can look like the governance gap CQC is asking about.
5. Tell CQC when you have finished. CQC’s guidance says providers should inform it in writing when the actions are completed.

Our action plan template and improvement plan guide go further, and Regulation 17 explains the governance duty behind most of these requests.

What to do in the first 48 hours

1. Record the day it arrived and keep the evidence.
2. Read the letter for its own terms: the regulation it cites, what it asks for and the date it gives. If anything is unclear, ask CQC in writing straight away.
3. List every breach with the regulation and the evidence.
4. Deal with any risk today. CQC judged that people are not at immediate risk. If you find something that is, act and record what you did and when.
5. Diarise the deadline and the sign-off. Plan backwards from day 28 (or the earlier date) with time for the provider to review.
6. Allocate owners for each finding.

Can you challenge an action plan request?

CQC’s policy sets out representations for warning notices and notices of proposal, and a tribunal appeal for notices of decision and urgent action. It sets out no route for an action plan request, which sits outside those processes. If you think a finding is wrong, still send the report on time and set out your evidence in it. For wider options on a rating, see our guides to the factual accuracy check and rating review. This guide is general information, not legal advice.

Sources and how this was checked

• CQC: Enforcement policy, protecting people by requiring improvement (updated 25 June 2026).
• CQC: Enforcement decision tree, stage 3 (seriousness matrix and worked examples).
• CQC: Offences (Regulations 16(3) and 17(3) prosecutable directly).
• Regulation 17 and Regulation 22 of the Health and Social Care Act 2008 (Regulated Activities) Regulations 2014, on legislation.gov.uk.
• CQC: Enforcement, adult social care services (updated 15 May 2025; under review), for the improvement action plan where a service is repeatedly rated Requires Improvement.

Read on 23 October 2026. CQC’s older pages still say “requirement notice”, so your letter may use either name.