The October Rule Change That Nobody Properly Explained (But Everyone Is Now Paying For)
Let’s clear something up.
From 6 October, the Care Quality Commission quietly changed how it treats locations for homecare providers. There was no headline announcement. No bold warning on the application portal. Just a new expectation applied during reviews.
From that point onwards, homecare providers have been expected to submit proof of a physical office location, and not just any proof.
CQC now wants:
Evidence of an office space, and
A letter from the landlord or mortgage lender
Explicitly confirming the premises can be used to operate a CQC-registered service
Not “office use”.
Not “business activities”.
Very specifically: CQC-regulated activity.
If that wording is missing, vague, or implied rather than stated, the application is very likely to be rejected.
Home Office? That Ship Has Sailed
During Covid, home offices were accepted. Flexibility was necessary. Everyone adapted.
That era is now well and truly over.
If you attempt to register a homecare service using a home address as your base, expect intense scrutiny. Even if you are not rejected immediately, you are likely to face repeated requests for clarification, additional evidence, and follow-up questions.
In plain terms:
👉 A home office is no longer a “simple” option — it’s a risk.
Virtual Offices: A Clear “No”
Virtual offices may look neat on paper, but they do not stand up to regulatory reality.
They fail to demonstrate:
Secure storage of records
Day-to-day management of staff
Governance and oversight
Operational control
Submitting a virtual office as your registered location is one of the fastest ways to invite refusal.
This is not a grey area. CQC’s position on this is now very clear.
The Quiet Workaround: “Location Will Be Ready By…”
Here’s something many providers miss.
On the new provider application form, there is a specific section asking when the location will be ready.
Given that CQC applications routinely take 4 to 6 months (and sometimes longer) to be processed, it is entirely reasonable to state that:
The location will be ready in 4–5 months’ time
Used properly, this approach can:
Save months of unnecessary rent
Align costs with realistic timelines
Avoid paying for an empty office while waiting for approval
This is not cutting corners. It is working within the framework CQC itself provides — timing and wording just need to be right.
Not Applying for Homecare? Breathe (Slightly)
If you are not registering a domiciliary care service, the pressure is lower.
For many other service types, proof of office premises is not required at the point of application. It will still be assessed later, but it does not usually block submission in the same way.
This difference alone has caused confusion, particularly for providers running multiple services.
The Uncomfortable Truth: Retrospective Enforcement
Here’s where frustration really kicks in.
Many homecare providers submitted applications earlier in 2025, before this requirement was clearly enforced. Their applications sat in the queue for months.
When those applications were eventually reviewed after 6 October, the new standard was applied anyway.
Was this unfair?
Arguably, yes.
Was it unexpected from a regulatory body?
Less so.
CQC assesses applications against the requirements in place at the time of review, not at the time of submission. That has caught many good providers off guard.
Faster Checks, Less Forgiveness
There is good news.
CQC has recruited a large number of administrative staff whose sole job is to screen applications.
The result:
Initial checks can now happen within two weeks
The downside:
Applications are scrutinised line by line
One missing document or unclear sentence can trigger rejection
Applications are often rejected multiple times, each time for a different issue, rather than being reviewed properly in one go
In short: things are moving faster, but tolerance for error has dropped sharply.
What This Means in Real Life
If you are applying for homecare now:
Your office arrangements matter more than ever
Your paperwork must be precise
Your wording must match CQC expectations exactly
This is no longer an area where assumptions are forgiven.
What to Do Now (A Practical Checklist)
If you are planning to apply, or you have already been rejected, work through this calmly:
Confirm whether your service actually requires proof of an office at application stage
Secure a physical office (not home-based, not virtual)
Obtain a landlord or lender letter that explicitly allows CQC-registered activity
Check the wording — vague language is a common reason for refusal
Use the “location ready by” section wisely if timing allows
Review your application holistically before submission, not section by section
How Cura Compliance Helps
At Cura Compliance, this is now one of the first things we review.
We support providers to:
Decide what must be registered — and when
Avoid unnecessary rent and premature commitments
Get landlord and lender letters right the first time
Reduce repeat rejections caused by technical errors
You can learn more about our CQC registration support here:
👉 https://curacompliance.co.uk
Or speak to us before submitting or resubmitting your application:
👉 https://curacompliance.co.uk/contact-us/