Fit and proper persons reference checks — FPPR evidence for directors and managers
The Fit and Proper Persons Requirement under Regulation 5 applies to directors and registered managers in every CQC-registered organisation. Employment references with written conduct evidence and a full audit trail form a core part of the FPPR documentation CQC expects. RefAssure generates this evidence automatically from 99p per reference.
The FPPR applies to every director and registered manager in a CQC-registered organisation — and references are a primary evidence source
Regulation 5 requires CQC-registered providers to have robust processes for assessing whether individuals in director and senior management roles are fit and proper. This is not a one-time exercise at appointment — providers must have ongoing processes and documented evidence. Employment references with written conduct evidence and a full audit trail are one of the core components of that documentation, alongside enhanced DBS checks and qualification verification.
What the Fit and Proper Persons Requirement covers
Six criteria must be met under Regulation 5. Employment references contribute evidence for several of them.
Good character
The individual must be of good character. Employment references covering conduct, professional behaviour and the circumstances of leaving previous roles contribute directly to evidencing this criterion.
Necessary qualifications and skills
The individual must have the qualifications, competence, skills and experience necessary for the role. References from previous employers in similar roles evidence this through professional assessment.
Physically and mentally fit
The individual must be physically and mentally fit for the role. Employment references that raise no concerns about fitness for work contribute to this assessment.
Not been responsible for misconduct
The FPPR explicitly excludes individuals who have been responsible for, privy to, or facilitated misconduct or mismanagement in a health or social care provider. References with explicit misconduct questions address this directly.
Not on any barred list
The individual must not be included on any barred list — confirmed through DBS check. References complement this by revealing professional concerns not captured in criminal records.
Documented assessment
The provider must have documented evidence of assessing the individual against each FPPR criterion. Written references with audit trail form part of this documentation.
What an FPPR-focused reference covers
Key questions for director and registered manager appointments — addressing FPPR criteria directly.
Director / Registered Manager Reference — FPPR Fields
Fit and proper persons reference checks — the complete guide
The Fit and Proper Persons Requirement is one of the most significant compliance obligations in the care sector — and one that is frequently misunderstood. Many care providers are aware that the FPPR exists and that it involves a DBS check, but do not fully appreciate the role that employment references play in the documented FPPR assessment, or the standard of reference evidence that CQC expects to see.
Who does the FPPR apply to?
The FPPR under Regulation 5 applies to directors of NHS trusts and foundation trusts, and to individuals in director, registered manager or equivalent senior leadership roles in other CQC-registered organisations. For most care providers this means the registered manager and any directors or owners involved in the management of the regulated activity. It does not apply to frontline care workers — though those individuals are covered by the separate safe recruitment requirements under Regulation 19.
Why employment references matter for FPPR
The FPPR requires care providers to assess whether individuals in leadership roles are of good character and have not been involved in misconduct or mismanagement in a health or social care setting. A DBS check addresses criminal history — it cannot reveal professional conduct. References from previous employers in health and social care are the primary mechanism for addressing the character and conduct criteria under Regulation 5. A reference that asks only about job performance and attendance, without addressing conduct, fitness for a regulated role and the specific FPPR exclusion criteria, does not generate the evidence CQC expects.
What happens during a CQC FPPR inspection
CQC inspectors may request to see the FPPR assessment documentation for directors and registered managers during inspection. They expect to find a documented process — not just a checklist tick — with evidence that each criterion has been assessed. For the reference component, this means written references with appropriate questions, obtained directly from referees, with a full audit trail. RefAssure's PDF report provides exactly this documentation, ready to be filed in the FPPR assessment record.
FPPR reference checks — questions answered
The FPPR under Regulation 5 requires CQC-registered providers to ensure directors and registered managers are of good character, have necessary qualifications and skills, are physically and mentally fit, and have not been responsible for misconduct or mismanagement in a health or social care provider.
Yes. Written employment references covering conduct, character and professional behaviour in previous roles — obtained directly with a documented audit trail — are a primary evidence source for demonstrating FPPR compliance for directors and registered managers.
The FPPR applies to directors of NHS trusts and foundation trusts, and to individuals in director, registered manager or equivalent senior leadership roles in other CQC-registered organisations.
FPPR compliance typically requires: enhanced DBS check, written employment references covering conduct and character, qualification and professional registration verification, and documentation of the provider's FPPR assessment against each Regulation 5 criterion.
RefAssure generates written references with candidate consent, structured conduct and character questions including FPPR-specific fields, and a full timestamped audit trail — all in a single PDF. The report can be filed directly in the FPPR assessment record and produced at CQC inspection.
More CQC compliance guides
FPPR reference evidence.
Written, documented, inspection-ready.
Role-specific templates for director and registered manager appointments, full conduct and character questions, timestamped audit trail — FPPR evidence generated automatically from 99p.
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