The policy direction is clear, the targets are set, and NHS estates teams are already working through which buildings will be repurposed first. But alongside the excitement about co-location and integrated care, a practical question keeps surfacing, one that doesn’t get nearly enough airtime: what does CQC registration actually look like when several providers are operating under the same roof?
The NHS is moving decisively toward a neighbourhood model of care.
The government has committed to delivering 250 Neighbourhood Health Centres (NHCs) by 2035, with 120 by 2030. The first wave (2026–27) will largely focus on repurposing existing NHS estate in areas of highest deprivation.
These centres are designed as shared clinical environments, where multiple services and providers operate side-by-side, often sharing infrastructure, but not governance.
This raises a recurring and important question:
“How does CQC registration work when multiple providers operate from the same place?”
To answer that properly, you need to understand two things:
- What the NHS is trying to achieve
- How the CQC defines a location
This blog was written in partnership with the THC Primary Care.
The direction of travel: the neighbourhood model
At the heart of the NHS 10-Year Plan is a fundamental shift in how care is organised:
1. From hospital → community
Care is moving closer to where people live, with diagnostics, outpatient activity, and prevention delivered locally.
2. From fragmentation → integration
Neighbourhood models bring together:
- primary care
- community services
- mental health
- social care
- voluntary sector
3. From single organisations → multi-provider ecosystems
The model explicitly promotes:
- co-location of services
- multidisciplinary teams
- flexible use of the estate
- multiple providers operating in one place
4. From treatment → prevention
Services are increasingly designed around population health, not episodic care.
Where regulation anchors: what is a “location”?
Despite this operational shift, the regulatory framework remains clear and unchanged.
A CQC location is:
The place where regulated activities are delivered.
And critically:
- Registration sits with the provider, not the building
- Multiple providers can operate from the same physical space
- Each provider must register the locations where they deliver regulated activity
The tension: flexibility vs accountability
This is where providers often get caught out.
The NHS is moving toward:
- flexible, shared estate
- rotating / pop-up services
- co-located delivery
But the CQC still requires:
- clearly defined locations
- identifiable lines of accountability
- demonstrable governance at each place where care is delivered
Co-location does not mean shared registration
Even in a fully integrated neighbourhood hub, the reality is:
- One building
- Multiple providers
- Multiple registered locations
- Shared infrastructure, but separate accountability
What this means in practice
If you are operating (or planning to operate) within a Neighbourhood Health Centre:
1. Map your activity to delivery
Ask: Where is care actually being delivered?
That determines whether a location needs to be declared.
2. Don’t assume shared space removes registration requirements
Even if you:
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- Rent rooms
- Use space intermittently
- Operate clinics within a wider hub
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You may still need to register that location.
3. Separate estate from regulation
Be clear on the distinction:
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- Lease/licence agreement → who owns or manages the space
- CQC registration → who is responsible for care delivered within it
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They are not the same thing.
4. Be explicit about governance
This is what inspectors will focus on:
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- Who is responsible for patient safety in that space?
- How is emergency equipment accessed?
- How is infection prevention and control managed?
- How do patient pathways operate within a shared environment?
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The question is never “Who owns the building?”, it is always “Who is accountable for care delivered here?”
The bottom line
The system is becoming more integrated operationally, but remains provider-specific regulatorily. The building can be shared, but in CQC's eyes, the responsibility cannot.
That is the core tension every provider operating in a Neighbourhood Health Centre must navigate.
Get in touch with BAXCQC today
Please email Kelsey Price at kelsey.price@baxendale.co.uk, or book a call, to get expert guidance on CQC registration for shared neighbourhood health centre models, including responsibilities, registration pathways and timelines.