Information for service providers: Independent medical agency

Who needs to register

The regulation of independent medical agencies (IMAs) came into force in 2025.

Independent medical agencies (IMAs) can take account of many types of service. This includes services provided by healthcare professionals that are not directly related to healthcare.

Online services (such as an online GP) are IMA. If your service meets the statutory definition, and is not excluded, you should contact us to start the registration process. If you are not an online service provider, but you think that you may an IMA please email us. We will get in touch if you need to be registered.

Check if you need to register

The law defines an IMA as an undertaking that is not a hospital or an independent clinic. It includes:

  • medical practitioner
  • dental practitioner
  • dental care professional
  • registered nurse
  • registered midwife
  • registered pharmacist
  • registered pharmacy technician

You are not required to register as an IMA if your service:

  • is a service that is part of the NHS
  • is a pharmacy that is registered with the GPhC
  • is a nurse agency that is registered with the Care Inspectorate
  • is an occupational health service provided only for employees by an employer
  • only provides first aid
  • only provides talking therapies

Scenario’s

In the following scenarios, insert the relevant type of healthcare professional from the list above for your circumstances.

Please ensure you read the list of exemptions above with each example. The following are examples only, based on our current understanding of the definition of an IMA, and do not cover every scenario and as our understanding develops we may add additional scenarios here to assist providers in deciding if they are an IMA or not.

Non-urgent advice: Scenario 1

I am a clinician providing a private online primary healthcare service to a range of patients across the UK. The legal entity that is the provider of the service is based in Scotland. None of my patients will visit my office, even if they live nearby.

This is an independent medical agency. As you are a clinician included in the definition and you do not have premises for patients to visit.

Non-urgent advice: Scenario 2

I am a clinician who is qualified to prescribe medication. I have a website/social media app, which sets out a range of conditions that I am competent to prescribe for, based on either patient questionnaires or video consultations or both. I am based in Scotland.

This is an independent medical agency. As you are a clinician included in the definition and you do not have premises for patients to visit

Non-urgent advice: Scenario 3

My practice runs an NHS GP practice. Since the pandemic, we have offered a range of services for our private patients using online forms and video calling services, via a separate company that is registered in Scotland. Private patients do not visit the NHS GP practice premises, even if they live nearby.

This is an independent medical agency. As you are a clinician included in the definition, your patients do not visit any premis(s)e and the service is provided by a separate company which provides the NHS services.

Non-urgent advice: Scenario 4

My practice runs an NHS GP practice. Since the pandemic, we have offered a range of services for our NHS patients using online forms and video calling services.

This is not an independent medical agency. You do not have to register with HIS as the as the services provided are part of the provision of NHS primary care.

Non-urgent advice: Scenario 5

I am a prescribing clinician, I have a website/social media app which sets out a range of conditions that I am competent to prescribe for, based on patient either questionnaires or video consultations or both. The legal entity that is the provider of the service is based in England.

This is not an independent medical agency. You do not have to register with HIS as he provider is based out with Scotland

Non-urgent advice: Scenario 6

I am a clinician, based in Scotland, and I provide first aid cover for my son’s rugby team. I cover matches at the home ground and some away matches.

This is not an independent medical agency. You do not have to register with HIS as the provision of first aid is excluded from regulation.

Non-urgent advice: Scenario 7

I am a dentist, and I have also recently studied to become a counsellor. While my dental practice is based in premises, I run my counselling service wholly online through video calls and asynchronous messaging. I do not prescribe medication. I have a separate company to provide my counselling services, which has the legal entity registered in Scotland.

This is not an independent medical agency. You do not have to register with HIS as talking therapies (where the treatment is provided only through speech between the service provider and the patient) are excluded from regulation.

Next steps

If you still have questions on your registration, email the independent health care team.

If need to register your service, visit our website.

Our current registration timescales are approximately three months. These timescales are based on applications being entirely complete at the time of submission. An application is considered complete where all parts of the application have been submitted. This includes:

  • application form
  • supporting documents
  • policies and procedures

Applications that are incomplete may be refused. Registration fees are non-refundable.

We cannot provide support to service providers to assist with making an application to register