Direct access - Updated 1 November 2025

Direct access works best in a team setting, partly because of legal restrictions such as those around prescribing and holding emergency medicines, which are not imposed by the GDC. Working in a team setting also allows for more immediate practical arrangements for records, referrals and second opinions. A team setting should give patients more routes of entry into treatment. However, there is no reason that direct access cannot work in many types of settings provided that appropriate safeguards are in place.

Overall responsibility for patient care depends upon who is treating the patient. If the patient is only seeing a dental care professional, then that individual would be responsible. If the patient is under the care of the dental team, including a dentist who is prescribing or directing the treatment, then the dentist would have overall responsibility.

When providing care via direct access, dental care professionals need to have clear arrangements in place to refer patients to dentists if those patients need treatment which only dentists can provide.

In a multi-disciplinary practice where the dental team works together on one site, this should be straightforward. In a multi-site set-up where members of the dental team work in separate locations, there should be formal arrangements such as standard operating procedures in place for the transfer and updating of records, referrals and communication between professionals.

Where dental care professionals choose to practise independently (i.e. in a situation where there is no dentist as part of the team), they should have clear referral arrangements in place in the event that they need to refer a patient for further advice or treatment. These arrangements should be made clear in their practice literature. If a patient requires a referral to a dentist with whom the dental care professional does not have an arrangement, the professional should set out for the patient, in writing, the treatment undertaken and the reasons why the patient should see their dentist.

In all cases, the need for referral should be explained to the patient and valid consent obtained. The reason for the referral and the fact that the patient has consented to it should be recorded in the patient’s notes. Relevant clinical information, including copies of radiographs, should be provided with the referral.

If a patient declines a referral to a dentist, the possible consequences of this should be explained to them and a note of the discussion made in the patient’s records.

There should also be referral arrangements in place to make sure a dentist is available to ‘report’ on aspects of a radiograph that are out of scope of the dental care professional. This is to ensure patients receive appropriate advice and subsequent care.

Dental professionals who set up in independent practice may need to register with the relevant healthcare systems regulator in the part of the UK in which they are practising. Please contact the relevant systems regulator for further information on registration requirements.

Dental care professionals seeing patients directly within an existing practice already registered with a systems regulator do not have to register with any other body.

There is no requirement for a dental professional to have been in practice for a certain amount of time before providing care directly to patients. However, dental professionals who wish to practise in this way should review their training, skills and continuing professional development to be sure that they are confident that they have the skill and competence required.

While it is not a requirement, a period after qualification spent practising on referral from a dentist will help to build confidence and experience before practising under direct access arrangements. This also applies to those who gained their primary qualification overseas, who will benefit from building their knowledge and experience of practising in the UK first.

Training to provide aspects of care directly to patients may be provided in different ways.  It could be delivered by an external and accredited provider, or it could be carried out in-house. If training is not externally accredited in some way, it is good practice for it to be recorded and verified as having taken place by the provider of the training, for example by annotating a logbook.

Consent must be obtained from the patient for all treatment undertaken and for any referral to other members of the dental team. Every dental professional is responsible for obtaining the patient’s consent when they are in their care.

Some emergency drugs are prescription-only medicines, controlled drugs, or pharmacy medicines. This means that they are subject to restrictions imposed by medicines legislation, which describes who can legally obtain, hold, and administer particular medicines.

Please read the content on this page for further information.

Every dental professional is responsible for keeping accurate patient records. If a patient needs to be referred then relevant clinical information, including copies of radiographs, should be provided with the referral. 

Dental care professionals who are setting up their own, independent practice could find that their status with regards to data protection law will change and they will have more responsibility. As with all laws and regulations that affect their work, dental care professionals should remember to check how data protection laws apply to them in their role. 

All dental professionals must be trained in medical emergencies, including resuscitation. Direct access does not alter this requirement. While every member of a dental team needs to be able to lead the response in the event of a medical emergency, their role may change depending on the setting and the team they are working within. 

You must follow the guidance on medical emergencies and training updates issued by the Resuscitation Council UK, so please visit their website for the latest training requirements.

Direct access may not extend to certain areas of practice which are governed by other legislation which the Council does not have the power to change. One such area is tooth whitening:

Under the Cosmetic Products Enforcement Regulations 2013 (including amendments from Regulation 1223/2009, Regulation 344/2013 and Regulation 1197/2013), products containing or releasing between 0.1% and 6% hydrogen peroxide can only be sold to dental practitioners (dentists). These products can only be made available to patients following a clinical examination. The first cycle of use must be provided by a dentist or by a dental hygienist, dental therapist, or clinical dental technician under the direct supervision of a dentist (i.e. within the same dental setting). The products may then be provided to the patient to complete the cycle of use. This means that dental hygienists, dental therapists and clinical dental technicians can only carry out tooth whitening with a prescription (patient specific direction) from a dentist, and with a dentist on the premises and supervising the procedure when the first treatment is carried out.

There are tasks that some dental professionals may carry out that are not the practice of dentistry and are not regulated by the GDC. These may, however, be subject to regulation by other bodies, or specific legislation may apply. Two such areas are described below: 

Botulinum Toxin (Botox®)

The administration of Botox for cosmetic purposes is not the practice of dentistry. Botox cannot be advertised to the public as it is a prescription-only medicine (POM). It needs to be prescribed by a registered doctor or dentist who has completed a full assessment of the patient. 

Injectable dermal fillers

Injectable dermal fillers are classed as medical devices and so do not require a prescription.

Dental professionals who choose to provide these treatments to patients must be sure that they are trained, competent, and indemnified or insured to do so.

While these non-dental tasks are not currently regulated, this status may be subject to change. All dental professionals need to ensure that they are acting both safely and within the law at all times.

Dental hygienists and dental therapists can carry out their full scope of practice (except tooth whitening) without referral from a dentist. They should not be pressured to work in this way as providing direct care to patients is an option. Those who prefer to provide treatment under referral from a dentist may do so.  

Dental hygienists and therapists must be confident that they have the skill and competence to treat patients under direct access. A period of practice working to the referral of a dentist is a good way to assess this.

Hygienists and therapists who qualified after 2002 in the UK should have covered the full scope of practice in their training, while those who trained before 2002 or overseas may not have covered everything. However, many will have addressed this via top-up training, CPD and experience. Dental professionals who are unsure whether there are any gaps in their training should check with their indemnity or insurance provider before undertaking any new duties.

Dental hygienists and dental therapists practising under direct access should only diagnose and provide care within their scope of practice. They should refer to a dentist (or other relevant healthcare practitioner) when they identify areas of concern, or when the treatment required is out of their scope of practice such as when an opinion is needed about whether permanent tooth requires treatment that is out of scope. 

Medicines

Dental hygienists and dental therapists can legally supply and administer specific prescription-only medicines under exemptions without the need for a prescription. Details of these medicines can be found here. All dental hygienists and therapists who choose to work within this mechanism must ensure they have undertaken appropriate training and are competent, and indemnified or insured, to do so. Please see our statement relating to this matter. If the dental hygienist/dental therapist is not working with the exemptions mechanism, a prescription (patient specific direction or patient group direction*) is required for all prescription only medicines.

*please note that patient group directions will be phased out for dental hygienists and therapists

Dental nurses can participate in structured programmes which provide dental public health interventions without the patient having to see a dentist first. If the intervention includes the application of fluoride varnish a prescription (patient specific direction) must be in place. 

Dental nurses who wish to practise in this way should be sure that they are trained, competent, and indemnified or insured to do so. 

Dental nurses should undertake the rest of their work under prescription from, or the direction or delegation of, of a dentist or other registered dental or healthcare professional.

Orthodontic therapists work under prescription of a dentist, however, those who are trained, competent, and indemnified or insured, can carry out Index of Orthodontic Treatment Need (IOTN) screening direct to patients, or as part of a structured public health programme led by a specialist in orthodontics, a consultant in Dental Public Health, a specialist in Dental Public Health or a general dental practitioner. 

Orthodontic therapists should undertake the rest of their work under referral or direction of a dentist.

Clinical dental technicians can provide direct care for patients who have no teeth and no implants for the provision and maintenance of full dentures. Otherwise, they work under prescription from a dentist or oral and maxillofacial surgeon for dentate patients.

Any treatment provided for patients with teeth or implants is done on prescription from a dentist. 

The work of a dental technician (other than denture repairs and shade-taking) should continue to be carried out on the prescription of a dentist or clinical dental technician.

Dentists are the only member of the dental team who can carry out the full range of dental treatments and prescribe a full range of prescription only medicines. Dentists must be trained, competent, and indemnified or insured to provide this care.