One of your physiotherapists starts maternity leave next month, the waiting list is already at five weeks, and you need cover. Hiring a locum physiotherapist is the obvious answer, and most of the time it goes smoothly. When it goes wrong, it is usually because a check that takes five minutes was skipped in the rush. This guide is for the owner or practice manager of a private physiotherapy or MSK clinic, and it covers the checks that matter as the rules stand in October 2026.
Check the HCPC register yourself, on the day
Physiotherapist is a protected title. Anyone who calls themselves one in the UK must be registered with the Health and Care Professions Council. The register is free to search on the HCPC website by name or registration number, and physiotherapist numbers start with PH.
Look at three things. The status should say registered. The entry should show no conditions of practice or caution, and if it does, ask about it before you go any further. And if you want the locum to prescribe, the entry should carry a supplementary or independent prescribing annotation. Without it, they cannot.
Physiotherapists renewed between 1 February and 30 April 2026, so the next renewal is in 2028. Anyone who did not renew has dropped off the register and cannot practise. Check on the day you confirm the booking, not from a CV or a certificate they emailed last year.
Indemnity is a condition of their registration
The HCPC requires every registrant to have a professional indemnity arrangement that suits the work they do. Employed staff are usually covered by their employer. A self employed locum must arrange their own, often through their professional body.
Ask for the certificate and read what it covers. If your clinic offers acupuncture, injection therapy or clinical Pilates, the locum’s cover needs to include it. If they are coming through an agency, call your own insurer and ask whether your policy covers agency clinicians working under your name. It is a short call and it settles the question before anything happens.
What a DBS check needs to cover
Healthcare given by a regulated health professional is regulated activity with adults in England and Wales. That means an enhanced DBS check with a check of the adults’ barred list. If the locum will treat children, ask for the children’s barred list as well. In Scotland the equivalent is PVG scheme membership, and in Northern Ireland an Enhanced AccessNI Disclosure.
If the physio is on the DBS Update Service you can check their certificate online in minutes, with their consent. Our guide to DBS Update Service checks walks through how.
Agency, umbrella or limited company: who carries the tax risk
How the locum is paid decides who is on the hook if the tax goes wrong. A physio on an agency’s own payroll is the simplest arrangement. The agency employs them for pay purposes and you pay one invoice.
Umbrella companies changed on 6 April 2026. The agency that supplies a worker paid through an umbrella is now jointly and severally liable for that umbrella’s PAYE and National Insurance. If there is no agency and you contract with the umbrella yourself, that liability can land on you. Most clinics are better off letting the agency carry it.
If you book a physio’s limited company directly, the off payroll working rules apply. A small company client leaves the employment status decision to the contractor. A medium or large one must decide status itself and give the contractor a status determination statement. If you are unsure which you are, ask your accountant before the first invoice, not after.
The 12 week rule for agency locums
Under the Agency Workers Regulations 2010, an agency worker who has spent 12 weeks in the same role with you is entitled to the same basic pay, holiday and working time terms as if you had hired them directly. Access to your staff facilities and to your job vacancies applies from day one.
Maternity cover nearly always runs past 12 weeks, so budget for it from the start. If your own physios get a pay rise during the booking, the locum’s rate may need to follow. Our guide to the Agency Workers Regulations 12 weeks rule covers the detail.
Brief them properly before the first patient
Most locum problems in a clinic are not about compliance. They come from a good physio who was never told how your clinic works. Set up their login to your notes system before day one. Tell them which outcome measures you record, how long a new assessment and a follow up are booked for, and who they go to when a patient needs onward referral or imaging.
Agree their scope in writing. If you do not want a locum running injection clinics or taking on your sports contracts, say so at the start. Book a short catch up at the end of the first week to read a sample of their notes. It costs half an hour and tells you most of what you need to know.
Where we come in
Flamingo Workforce supplies physiotherapists and other allied health professionals to clinics, NHS services and private providers across the UK. Every locum we send has been checked against the HCPC register, the DBS level the role needs and the right to work, and you get their compliance file before they start. If you have a gap coming up, get in touch and tell us the dates.