What the NMC Actually Checks at Revalidation

Most revalidation submissions are reviewed automatically. The NMC’s system reads the eight checkboxes (practice hours, CPD hours, feedback count, reflective accounts, reflective discussion, health and character, indemnity, confirmation) and if all eight are recorded as complete, the submission is approved and your registration is updated.

A minority (historically around 2.5%) are pulled for full audit. That’s where the underlying evidence is read in detail. This chapter walks through both review paths, and what trips submissions up.

The automatic screening

Every submission passes through the automatic screening first. The system is checking presence, not substance:

• Has 450 (or 900/1,350) practice hours been declared?
• Has 35 CPD hours, 20 of them participatory, been declared?
• Have 5 pieces of feedback been logged?
• Have 5 reflective accounts been entered on the Form 6 fields?
• Has 1 reflective discussion been recorded?
• Has the health and character self-declaration been signed?
• Has an indemnity arrangement been confirmed?
• Has the confirmation form been submitted by a named confirmer?

If all eight boxes are present, you pass the automatic screening. You’ll get an approval email and your registration status moves from “pending revalidation” back to “Active”.

The screening doesn’t read the content of your reflective accounts. It doesn’t check that your CPD hours are reasonable. It doesn’t verify that your feedback is genuine. Those checks only happen in audit.

Selection for audit

The NMC audits a sample. The exact percentage shifts year on year but has historically run around 2.5% of all submissions, meaning roughly one in 40 revalidating nurses gets picked.

Selection is partly random and partly risk-based. The factors that increase audit likelihood:

• Late submission (close to the deadline rather than the early end of the 60-day window). The NMC interprets this as a risk flag.
• Pattern anomalies: for example, reflective accounts all dated within the last two weeks before submission, or CPD certificates concentrated in a single month.
• Confirmation from someone outside the normal pattern: a confirmer the NMC doesn’t already recognise as a senior registrant.
• Recent fitness-to-practise activity: registrants with current or recent FtP concerns are more likely to be sampled.
• Random selection for the base rate.

You can’t game the system to reduce audit likelihood. The way to make audit a non-event is to have the underlying evidence ready, whether or not you’re picked.

What happens in an audit

If you’re selected for audit, the NMC sends an email shortly after your submission asking you to provide the underlying evidence. You have 28 days to respond.

What’s requested:

• CPD evidence: certificates, agendas, reflective notes on courses attended, lists of participants for participatory CPD.
• Feedback summaries: anonymised written versions of the five pieces of feedback.
• Reflective accounts on Form 6: the actual signed/dated forms (which you’ve already submitted, but the auditor reads the content carefully now).
• Reflective discussion record: the form signed by the registrant you discussed with.
• Confirmer evidence: confirmation that your confirmer is who they say they are (in practice, NMC PIN of the confirmer, employment verification of the role they claim).
• Indemnity arrangement: a copy of the policy document or letter from your employer confirming cover.
• Practice hours: a record of hours, which may need supplementing with employment confirmation.

The audit team reads everything. They check for plausibility, internal consistency, and alignment with the eight requirements.

What fails an audit

Audit failures fall into three categories:

Missing evidence. The most common failure. A CPD hour claimed but no certificate. A reflective account dated in the submission but not actually written until the day of the audit request. A confirmer who turns out to be on the NMC register but not in a role that meets the confirmation criteria. Missing evidence is recoverable if the registrant can produce it within the 28-day window. If they can’t, the submission is rejected.

Substantive deficiency. The evidence exists but doesn’t meet the standard. A reflective account that names a Code section but doesn’t actually link to it. CPD that isn’t relevant to the registrant’s scope of practice. Feedback that’s actually from a previous cycle, not the current one. Substantive deficiencies usually lead to follow-up questions and sometimes additional evidence requests, rather than outright rejection.

Concerning content. Less common. A reflective account that describes a serious incident in a way that suggests the registrant didn’t recognise or report it. CPD that includes content the registrant has visibly failed to apply. These can lead to fitness-to-practise referrals rather than just audit rejections.

What an audit actually feels like

Most audits resolve in 4–6 weeks with “no further action required”. The registrant sends the evidence, the auditor reads it, confirms it matches the submission, and closes the case. Your registration status remains “Active” throughout. Audit is not a suspension of registration.

The minority of audits that find issues usually result in supplementary requests rather than outcomes. The auditor asks for missing certificates, asks for a confirmer’s NMC PIN, asks for a clarification of a reflective account. The registrant provides the additional material, the audit closes.

Audits that lead to rejection or referral are rare: well under 1% of the 2.5% sampled, which is well under 0.025% of all submissions. The conditions for that level of escalation are usually serious: fabricated evidence, fundamental misrepresentation, or content that raises a separate fitness-to-practise concern.

Audit-proofing your submission

The path to a non-eventful audit is being able to produce the evidence in 28 days. Three practical habits:

1. Save evidence as you go. CPD certificate into a folder labelled “Revalidation [year]” the day you receive it. Reflective account written and dated within a week of the event. Feedback in a Word document with date, source, and content.
2. Date everything consistently. Audit auditors notice when 17 reflective accounts are dated within a 10-day window.
3. Know your confirmer’s NMC PIN before you submit. If they’re a registered nurse or midwife, get the PIN. If they’re a senior allied health professional, get their professional registration number. You need it for the form and you’ll need it again if you’re audited.

The next chapter covers how NMC revalidation has changed since it was first introduced in 2016: the small adjustments that have happened, and what’s currently being consulted on.