This equality impact assessment (EIA) relates to the implementation of amendments to the regulated activity of Treatment of Disease, Disorder or Injury (TDDI) within the Health and Social Care Act 2008 (Regulated Activities) Regulations 2014. Two exceptions that previously excluded healthcare provision at sporting and cultural events from CQC regulation have now been removed.
This change will bring medical providers that deliver care at events such as sports fixtures, concerts and festivals into CQC’s regulatory scope. The statutory instrument was laid in Parliament on 26 February 2026.
CQC is now required to consult on aspects of how this change is implemented, including guidance and regulatory expectations, ahead of implementation in September 2026.
This EIA considers the equality and human rights implications of the consultation, engagement activity and subsequent implementation approach.
The consultation is primarily aimed at providers of the regulated activity of Treatment of Disease, Disorder or Injury (TDDI), rather than people who use services. This is because it focuses on the guidance for the technical process of registration that providers use. Equality impacts are therefore considered in relation to providers and individuals responding in a professional capacity to the consultation.
However, this regulatory change will also have an impact on people who may receive care at events – by reducing the risks associated with unregulated activity. We acknowledge that these risks affect different groups of people in different ways and that risks for some people will be greater than for others. This EIA highlights some of the key equality and human rights-related risks for people who may receive care at events and for the events workforce, which will be important for CQC, providers and partners to consider, as we develop our implementation approach.
There may also be other potential impacts on people employed in the sector, on CQC’s workforce or partner organisations. During the consultation, we will ask about equality impacts to explore this. We will use the consultation findings to inform our implementation approach.
Evidence and engagement log
Who have you engaged and consulted with as part of your assessment?
This equality impact assessment has been informed by:
- Evidence of harm and safeguarding concerns reported to CQC relating to unregulated medical provision at sporting and cultural events
- The state of care in independent ambulance services - Care Quality Commission (2019)
- The findings and recommendations of the Manchester Arena Inquiry (final report, November 2022)
- DHSC’s public consultation on removing the TDDI events exemptions (summer 2024)
- Internal policy development with DHSC on implementing the statutory change
- Development of a provider focused consultation on CQC guidance and registration requirements
- Evidence of issues affecting equality and human rights in the wider sector, including sexual safety, for people receiving care and for the workforce, for example:
- State of care in independent ambulance services – CQC (2019) identified ongoing issues with poor recruitment practices, training and safeguarding practices, with evidence of serious harm to people from staff that had not been properly recruited and vetted. It also highlighted particular risks to children and adults with complex needs and mental health needs. Poor workplace culture and subcontracting in the sector can increase risk.
- Reducing misogyny and sexual safety: What we know - Association of Ambulance Chief Executives (2024), Sexual Safety – HSSIB (2024), CQC and EHRC joint enforcement on sexual safety for ambulance workers.
- Monitoring the Mental Health Act – CQC (2024/25) notes the number of urgent and very urgent referrals to crisis services has continued to rise over the last 2 years, people are more unwell when they reach crisis.
- Still Ignored: The Fight for Accessible Healthcare – RNID and Sign Health (2025) notes barriers for disabled and d/Deaf people and challenges in accessing emergency or unplanned care.
- Listening to Workers Speak Up Review of Ambulance Trusts - National Guardian, (2023) highlights culture and workforce issues in sector.
Engagement activity during this consultation will focus primarily on providers and organisations delivering TDDI at events, including those currently registered and those who may be required to register for the first time.
The consultation includes a specific question to identify potential equality impacts on different groups, as well as optional equality monitoring questions to support analysis of who is responding and whether some groups are under-represented.
Impact on protected groups
Age
People of different ages, including children
Potential impact(s) to consider:
- The consultation is aimed at providers rather than the general public. However, sole traders or small providers operated by older individuals may experience additional administrative burden. Younger professionals or newly established providers may have less familiarity with regulation.
- Children and young people face specific risks at events, including safeguarding failures, adult‑oriented care models and sexual exploitation (especially for girls). These risks require explicit consideration in regulatory approach and guidance.
Mitigation
- For consultation:
- Clear, plain English guidance
- Reasonable consultation timescales
- Supporting guidance that explains expectations clearly
- For implementation:
- There is an opportunity to improve sexual safety in the sector, by setting regulatory expectations for existing and new providers registering for events provision and developing clear guidance for providers to support equality issues (e.g. sexual safety and providing services for children) ahead of regulatory assessments starting in December 2027.
Disability
Disabled people, including people with mental health needs
Potential impact(s) to consider:
- Disabled providers or staff involved in responding to the consultation may face barriers to engagement (for example digital accessibility or cognitive load or inaccessible formats)
- Disabled and neurodivergent people as well as people experiencing mental health conditions or in crisis may experience sensory overload at events, with communication barriers and misinterpretation of distress as non-compliance or aggression. There is an opportunity to improve response from providers to better meet people’s needs.
- Providers delivering services to disabled people at events may benefit from clearer expectations on reasonable adjustments and accessible communication e.g. for deaf people using British Sign Language.
- Providers delivering services to people experiencing mental health crisis at events, may benefit from clearer regulatory expectations.
Mitigation:
- Accessible consultation formats and routes, provide Easy Read version on request.
- Clear guidance on regulatory expectations, not overly complex or burdensome
- There is an opportunity to improve disability equality, by setting regulatory expectations and developing clear guidance for providers.
Gender reassignment
Trans people and non-binary people
Potential impact(s) to consider:
- No direct or disproportionate impacts identified in relation to provider engagement in consultation.
- Indirect positive impact through clearer regulatory expectations around dignity and respectful care.
Pregnancy and maternity
People who use health and care services who have additional needs because of pregnancy or maternity.
Potential impact(s) to consider:
- Providers employing pregnant staff or delivering care to pregnant people at events may benefit from clearer regulatory expectations
- Risk of impact limited and indirect
- Mitigation through proportionate regulation and guidance.
Race
People from minority ethnic backgrounds, people of different nationalities.
Potential impact(s) to consider:
- Providers from ethnic minority backgrounds, or those for whom English is not a first language, may face barriers engaging with complex regulatory guidance.
- Evidence of racial disproportionality in mental health diagnosis, restrictive practices, restraint and escalation to police – particularly affecting Black people – may be amplified in event settings.
- There is an opportunity to improve race equality in the sector, by setting regulatory expectations and developing clear guidance for providers ahead of regulatory assessments beginning in December 2027.
Mitigation:
- Clear accessible language
- Opportunity to feedback through free text questions
- Ongoing engagement alongside the formal consultation survey.
- Consider how to advance race equality during implementation.
- There is an opportunity to improve race equality, by setting regulatory expectations and developing clear guidance for providers ahead of regulatory assessments beginning in December 2027.
Religion or belief
People with different religions and/or beliefs or no belief
Potential impact(s) to consider:
- No direct impacts identified in relation to provider registration or engagement.
- Indirect positive impact through improved quality and sensitivity of care delivered at events.
Sex
Either male or female, or a group such as women or girls, men or boys
Potential impact(s) to consider:
- Some providers may be small, female led organisations or sole traders; proportionality in regulatory expectations is important
- Event healthcare settings present predictable risks of sexual violence, harassment, exploitation and boundary violations.
- Risks arising from poor workforce practices e.g. recruitment and DBS checks and wider culture, present risks to women receiving care and to employees.
- Women and girls face specific sexual safety risks at events.
- There is an opportunity to improve sexual safety in the sector, by setting regulatory expectations and developing clear guidance for providers ahead of regulatory assessments beginning in December 2027.
Sexual orientation
People who are heterosexual, gay, lesbian or bisexual
- No specific impacts identified for consultation
- Improved regulation may support inclusive and respectful practice.
Carers
People with caring responsibilities
Potential impact(s) to consider:
- Providers or professionals with caring responsibilities may have limited capacity to engage if consultation processes are time intensive
Mitigation:
- 6-week consultation window
- Online response options
Socio-economic
People from lower socio-economic backgrounds
Potential impact(s) to consider:
- Many affected providers are small or micro organisations
- Risk that registration requirements could be perceived as disproportionate or financially burdensome
Mitigation:
- Clear explanation of who is in scope
- Supporting guidance focused on proportionality
- Phased timelines for registration
Intersectionality
Include any other relevant information relating to the intersection of any of these protected groups and any other cross-cutting issues
Potential impact(s) to consider:
- Providers may experience overlapping disadvantages (for example disability, ethnicity and socio-economic status)
- Without clear guidance, there is a risk of uneven impact on smaller or less well resourced providers
- Risks are compounded for people with multiple protected characteristics attending events, for example Black women and children, disabled women, and young women. Event medical support is complex and providers may benefit from clearer regulatory expectations on equality.
Wider issues of inequalities
Consider health inequalities, inclusion health groups, cross-cutting issues
Potential impact(s) to consider:
- Although the consultation is provider-focused the policy has indirect implications for health inequalities. Regulation of event healthcare supports safer care for people who may rely on such services
- Providers may benefit from clearer regulatory expectations on supporting people using drugs or alcohol at events
Human rights
(Consider where there is a human rights implication)
No adverse human rights impacts from the consultation process itself have been identified. The wider regulatory change supports:
- Article 2 (Right to life) through safer regulated event medical care
- Article 3 (Freedom from inhuman or degrading treatment) through strengthening safeguards and regulatory expectations
- Article 8 (Respect for private and family life) through clearer standards on dignity, consent and communication
These issues will be further considered as we develop our implementation approach, including opportunities to prevent abuse of people’s rights, in line with our Human Rights Approach.
We need to ensure our implementation approach supports our commitment to promoting human rights and preventing human rights breaches, including our duties as a National Preventive Mechanism (NPM) body. Our NPM duties occur whenever we inspect or visit a service where people are deprived of their liberty – including under the Mental Health Act or those who have Deprivation of Liberty safeguards applied to them.
Any proposed changes also need to ensure that we can identify and assess:
- risks to the human rights of people who use health and care services or employees in a service
- good practice within a service in protecting and promoting human rights.
Action plan
Action 1
Issue identified: Risk that some provider groups may be less able to engage with consultation.
Planned action
- Ensure technical guidance and consultation materials are accessible, clear and proportionate.
- Make an Easy Read version of the guidance available on request to support accessibility
- Ongoing engagement alongside the formal consultation.
- Use equality monitoring to understand responses of people with different protected characteristics and whether those responding are people who may receive care or providers, to the consultation.
- Proactive engagement with smaller providers through targeted engagement
Actions to be completed by
Policy and Engagement teams - during the consultation period.
Action 2
Issue identified: Potential equality impacts not yet identified.
Planned action
- Use the dedicated equality impact consultation question and monitoring data to identify any new impacts or themes, disproportionate effects and monitor participation of different stakeholders. Use analysis to inform implementation approach.
- Consider how to develop equality monitoring during implementation.
- Review and update this EIA following consultation and engagement
Actions to be completed by
Data & Insight, Policy and Engagement teams – post consultation analysis.
Action 3
Issue identified: Risk of disproportionate impact on small providers
Planned action
- Use monitoring data to identify impacts, themes for small providers and use analysis to inform implementation approach.
Actions to be completed by
Data & Insight and Policy teams
Action 4
Issue identified: Opportunity to advance equality through implementation of regulatory assessment
Planned action
Consider how implementation approach can leverage equality , for example:
- Specifically review equality issues from EIA and consultation to inform implementation approach including safe recruitment, sexual safety, safeguarding, and meeting people’s mental health needs, reasonable adjustments and communication needs.
- Consider further engagement with people who use services or organisations who represent them, as implementation develops.
- Consider briefing CQC teams on equality issues to consider in making decisions on registration applications and in assessments, in line with tackling sexual safety, anti-racist principles and human rights approach.
- Consider how implementation approach to decisions and refusals can advance equality - for new providers and existing providers, wanting to extend registration into events.
Actions to be completed by
Policy, Engagement, Registration and Ops teams – post-consultation.
Sign-off
This equality impact assessment was signed off by Lucy Wilkinson, Deputy Director Equity and Rights, Policy and Strategy, and Antoinette Smith, Deputy Director or Director on 7 May 2026.