Exception reporting reform for resident doctors

Today (31 March 2025), the British Medical Association UK Resident Doctors Committee (BMA RDC) has announced it has accepted the framework agreement for exception reporting. The acceptance of the framework agreement has formally ended the BMA RDC’s current dispute with the government and the document has been ratified by DHSC ministers.
The framework agreement is a document outlining the upcoming exception reporting reforms for the 2016 Terms and Conditions of Service (TCS) in England.
12 September 2025, is the implementation date for employers to have in place the agreed reforms.
It has been created in partnership with the Department of Health and Social Care (DHSC), NHS England, NHS Employers, the BMA and employer representatives, during a series of talks since the acceptance of the July 2024 pay deal.
The content of the framework agreement was based on the twelve principles agreed between the BMA and government, outlined below.
Access the framework agreement
Read the framework agreement (PDF) for the new exception reporting reform.
Key points of the deal include:
- All educational exception reports will go to the directors of medical education (DME) for approval.
- All other exception reports to go to HR or medical workforce HR for approval.
- The guardian of safe working hours (GoSWH) will retain oversight of all exception reports.
- A three-tier system will be used to determine if hours were indeed worked.
- Doctors will have their choice of time off in lieu (TOIL) or pay - except when a breach of safe working hours mandates the award of TOIL.
- Additional fines: fines will be introduced to ensure that doctors have timely access to systems and are not prevented from exception reporting. Employers will face additional fines to ensure that doctors are not adversely affected by the unnecessary sharing of exception reporting information.
NHS Employers and the BMA RDC will be agreeing the necessary changes to the 2016 TCS contract, amending existing resources and producing new guidance to help employers apply the reforms.
Webinars
NHS Employers will host webinars to outline the upcoming exception reporting reforms for resident doctors on the 2016 TCS in England.
This event is targeted to employers in medical HR, medical workforce lead and guardian of safe working hours roles.
8 April 2025 10-11:30am
Details of additional webinars will be promoted in due course.
Next Steps
- Guidance and Resources - updated guidance and resources will be made available to support employers with the implementation of the exception reporting reforms.
- Monitoring - the Resident Deal Implementation Group (RDI) will continue to oversee all monitoring and publications produced until the initial phase is concluded.
- Evaluation - this reform will be evaluated by the DHSC, the BMA RDC, NHS Employers (and employer representatives) and NHS England from August 2027.
- Rotational Placements - the separate work steam on rotational placements will continue. The DHSC is leading work in partnership with key stakeholders to review the current system of training and rotational placements.