Strong NHS board governance begins with the right people. Decisions made at board level shape the quality of care delivered across entire organisations, communities, and patient populations. That is why the NHS Fit and Proper Persons Test (FPPT) exists and why it matters more than ever.
Whether you are a chair, a non-executive director, or a governance professional, understanding the FPPT and what it requires of your board is essential. This article walks you through what the framework involves, who it applies to, and how your organisation can stay on top of its obligations with confidence.
What is the NHS Fit and Proper Persons Test (FPPT)?
The FPPT is a legal requirement that ensures every board-level leader in the NHS meets a clear standard of fitness for their role. It covers character, competence, qualifications, and professional conduct.
NHS England published a revised FPPT Framework. The Framework became effective from 30 September 2023 and NHS organisations are expected to use it for all new board-level appointments or promotions, and for annual assessments for all board members going forward.
The strengthened FPPT prioritises patient safety and good leadership in NHS organisations, while ensuring that unfit board members are prevented from moving between NHS organisations. Better boards lead to better care.
Which NHS Organisations Does the FPPT Apply To?
The FPPT applies to all board members in NHS trusts, foundation trusts, integrated care boards, and arm’s-length bodies, including the Care Quality Commission and NHS England itself. It covers both executive and non-executive directors, including interim and non-voting appointments.
Trusts can also extend the framework to cover other senior positions, such as individuals who regularly attend board meetings or have significant influence on board decisions. The annual submission requirement, however, is limited to board members only.
If your role involves shaping decisions at board level, the FPPT is relevant to you.
NHS FPPT Compliance is an Ongoing Commitment
The FPPT is a continuous governance responsibility and one that requires consistent attention throughout the year.
Existing board members are required to undertake an annual self-attestation process, confirming each year that they continue to meet the requirements of the FPPT. This sits alongside the annual appraisal cycle and must be formally recorded.
The chair holds ultimate responsibility for ensuring the organisation can evidence that appropriate systems and processes are in place. Those systems include recruitment, induction, training, development, appraisal, governance committees, and disciplinary and dismissal processes.
For chairs, the Senior Independent Director or Deputy Chair reviews the chair’s FPPT compliance annually, with the completed assessment signed off within the Electronic Staff Record.
Getting this right consistently, year on year, is where having the right tools in place makes a big difference.
How the NHS Leadership Competency Framework Shapes FPPT Assessments
The updated Framework assesses whether board members have the skills and experience their role genuinely demands.
From 30 September 2023, the NHS Leadership Competency Framework must be used as part of the assessment process when recruiting to all board roles, and incorporated into annual appraisals of all board directors. It provides guidance for the competence categories against which a board member should be appointed, developed, and appraised.
This turns the FPPT into something more meaningful than a background check. It becomes a structured, values-based review of whether your board has the leadership it needs to perform.
NHS Board Member References Under the New FPPT Framework
One of the most practically significant changes introduced by the Framework is how board member references are handled.
A new standard reference template has been introduced to ensure greater transparency, robustness, and consistency when appointing NHS board members. The annual appraisals of the past three years inform the board member’s reference, with ESR data used to populate it whenever a director leaves their role, even where no reference has been formally requested.
NHS organisations must maintain complete and accurate board member references at the point of departure, irrespective of whether a prospective employer has asked for one. ESR records should be maintained on a career-long basis.
This closes a gap that previously allowed unsuitable individuals to move between organisations without scrutiny. It is a meaningful step forward for accountability across the NHS.
How the FPPT Affects Your CQC Well-Led Assessment
FPPT compliance does not sit in isolation from wider regulatory oversight. It connects directly to how the CQC views your organisation’s leadership.
The CQC is likely to consider compliance with the Framework as a measure of whether an organisation is Well-Led, even where that compliance goes beyond the strict requirements of the Regulations. Maintaining sufficient evidence of the checks carried out is therefore essential.
The CQC shifted to the Single Assessment Framework in April 2024, introducing a more data-driven, continuous inspection approach with quality statements replacing previous key lines of enquiry. In that environment, well-organised, readily accessible governance documentation is not just good practice — it is what inspectors expect to see.
Making Compliance Manageable in 2026
With full implementation of the FPPT Framework expected across all NHS organisations since March 2024, you must demonstrate that clearly and consistently.
The Framework is designed to be the start of an ongoing dialogue between board members about probity and values, forming a core element of a broader programme of board development, effective appraisals, and competency-based appointments.
That means the governance infrastructure behind your board needs to keep pace. Annual assessment cycles, ESR records, reference documentation, appraisal evidence, and audit trails all need to be managed reliably and be accessible when a regulator comes calling.
A board portal like Convene helps NHS organisations bring all of that together in one secure, intuitive platform. From organising board papers and tracking appraisal cycles to maintaining the kind of clear, auditable records that Well-Led reviews demand, Convene gives your governance team the tools to stay on top of every obligation. When your processes are running smoothly, your board is free to focus on accountable leadership for patients and communities across the NHS.
Book a demo with the Convene today and see what a board portal can do for your healthcare organisation.
Frequently Asked Questions
What happens if an NHS board member fails the Fit and Proper Persons Test?
The organisation must address the concern through its disciplinary or dismissal processes. The outcome is recorded in the Electronic Staff Record (ESR), making it visible to future NHS employers. This prevents unsuitable individuals from moving between organisations undetected.
Does the FPPT apply to interim NHS board members?
Yes. The Framework applies to all board members regardless of appointment type, including interim, non-voting, and seconded directors. If someone is performing the functions of a board director, they are within scope.
How does the FPPT link to the CQC’s Well-Led framework in 2026?
The CQC treats FPPT compliance as evidence of a Well-Led organisation. Under the Single Assessment Framework introduced in April 2024, inspectors take a continuous, evidence-based approach to leadership. Boards with well-documented FPPT records are better placed during inspections.
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