GDC Scope of Practice for Dental Hygienists and Therapists: 2025 Guide

What is scope of practice in UK dentistry?

Scope of practice defines the treatments a registered dental professional is trained and competent to carry out. For dental care professionals (DCPs), the GDC publishes formal scope-of-practice guidance that sits alongside — and is supplemental to — the GDC’s overarching Standards for the Dental Team (2013). Working outside your scope of practice is a fitness-to-practise matter and may constitute an unlawful dental act under the Dentists Act 1984.

In practical terms, scope of practice for DCPs is determined by three overlapping factors: the GDC’s published guidance on what each DCP title is trained to do; the individual clinician’s verifiable competence (you must not carry out procedures you are not trained to perform, even if they fall within your title’s broad scope); and any local or contractual restrictions imposed by your employer or NHS contract.

Dental hygienist scope of practice

A dental hygienist is a registered DCP whose core clinical scope centres on the prevention and management of periodontal disease and oral health promotion. The current GDC Guidance on Scope of Practice (effective 1 November 2025) no longer publishes a fixed task list; instead it gives examples of the tasks dental hygienists generally undertake and stresses that the registrant must be trained, competent and indemnified for each one (GDC, 2025). Typical tasks include:

• Removing hard and soft deposits from tooth surfaces (supra- and sub-gingival scaling and debridement)
• Polishing teeth (supragingival) and applying topical fluoride varnish
• Taking and processing dental radiographs (subject to training and IRMER 2017 compliance)
• Taking study models
• Administering local analgesia, including infiltration and inferior dental block techniques where the clinician is trained and competent (the 2025 guidance no longer enumerates individual anaesthetic techniques)
• Providing oral health education and preventive advice
• Applying fissure sealants — explicitly within the dental hygienist scope ("managing and providing interventions for the prevention of dental caries including fissure sealants", GDC, 2025)
• Supplying and administering specified prescription-only medicines directly to patients on completion of appropriate training (see medicines exemptions below)

What dental hygienists cannot do (within scope): carry out indirect restorations, place permanent direct restorations (fillings on adult teeth), carry out orthodontic treatment, make or fit bite-raising appliances (e.g. splints), extract teeth of any kind, or prescribe medicinal products (GDC Guidance on Scope of Practice, 2025).

Dental therapist scope of practice

A dental therapist has a broader clinical scope than a dental hygienist. The authoritative pre-registration competency framework is now The Safe Practitioner (GDC, 2023), which replaced Preparing for Practice as the UK dental-education curriculum from September 2025. In addition to the hygiene tasks above, the GDC gives the following examples for dental therapists:

• Carrying out direct restorations on the primary and secondary (permanent) dentition. The guidance is material-neutral; choice of filling material (including amalgam) is governed by mercury legislation, not GDC scope. There is no full amalgam ban in Great Britain, but retained UK Mercury Regulation restricts amalgam in children under 15 and in pregnant or breastfeeding patients except where strictly necessary; Northern Ireland follows the EU phase-out (full ban from 1 January 2025)
• Extracting primary (deciduous) teeth only — the GDC’s 2025 boundary states therapists "do not extract permanent teeth"
• Applying fissure sealants on the primary and permanent dentition
• Taking impressions for study models; making or fitting orthodontic appliances is outside therapist scope, as therapists do not undertake orthodontic procedures
• Undertaking pulpotomies and placing pre-formed (e.g. stainless-steel) crowns on the primary dentition — explicitly within scope (GDC, 2025)
• Taking and reporting radiographs (subject to IRMER 2017)

What dental therapists cannot do (within scope): undertake indirect restorative treatment (crowns, bridges, veneers), carry out pulp procedures in the adult dentition (i.e. root canal treatment on permanent teeth), undertake orthodontic procedures, make or fit bite-raising appliances, extract permanent teeth, or prescribe medicinal products (GDC Guidance on Scope of Practice, 2025).

Hygienist vs therapist: side-by-side scope table

Direct access: what it means in practice

Since 1 May 2013, dental hygienists and therapists in the UK have been able to see patients without a prescription or referral from a dentist (the GDC announced the change on 28 March 2013, with effect from 1 May 2013). Patients can book directly with a hygienist or therapist, and the clinician can assess and treat them within their registered scope without a dentist being present. The 2025 Guidance on Scope of Practice continues to recognise direct access and cross-refers to the GDC’s separate Direct Access guidance.

Direct access does not expand your clinical scope. You can only carry out treatments that fall within your registered scope of practice, regardless of whether the patient was referred by a dentist or self-referred.

1. Assessment responsibility shifts to you. You are responsible for taking an appropriate medical and dental history, identifying whether the patient needs to be assessed by a dentist, and making onward referrals where needed.
2. You must refer when you find something outside your scope — a suspicious soft-tissue lesion, a symptomatic tooth requiring root canal treatment, a complex periodontal case. This referral must be documented contemporaneously.
3. The GDC expects a documented pathway. Even in direct-access settings, you should have a clear protocol for onward referral and liaison with dentists (GDC Standards 2013, Principle 6).
4. Indemnity: before working under direct access, confirm that your professional indemnity or insurance cover explicitly includes this mode of practice, and check your specific policy wording with your provider.

What changed in November 2025?

The GDC published a revised Guidance on Scope of Practice on 16 September 2025, which came into effect on 1 November 2025 and replaced the long-standing 2013 document. The most important point for clinicians is what did not change: the revised guidance does not alter the scope of practice for any of the seven dental professional titles — it provides greater clarity on existing title boundaries (GDC, 2025).

• Indicative task lists removed. The previous detailed lists of permitted tasks are replaced with competency- and role-based descriptions and illustrative examples only.
• Emphasis on professional judgement. Registrants assess for themselves whether they are trained, competent and indemnified to carry out a task, rather than checking it against a fixed list.
• No new statutory instrument under the Dentists Act 1984. The change is revised GDC guidance, not an amendment to the Dental Auxiliaries Regulations. The separate legislative change that genuinely expanded what hygienists and therapists may do was the 2024 medicines-exemptions amendment (in force 26 June 2024).
• Direct access is unchanged and continues to be recognised.

Your GDC registration does not automatically entitle you to perform every procedure within your title’s scope. You must also hold verifiable training and be competent in each procedure — a requirement reinforced (not changed) by the 2025 update and flowing from GDC Principle 7.

Medicines exemptions: what hygienists and therapists can administer

Dental hygienists and therapists are not independent or supplementary prescribers and cannot prescribe prescription-only medicines. However, they are permitted to supply and administer certain specified medicines under exemptions set out in the Human Medicines Regulations 2012 (as amended) — specifically in Schedule 17, Parts 2, 3 and 4. These exemptions were introduced by SI 2024/729, in force from 26 June 2024, which allow suitably trained hygienists and therapists to supply and administer the listed medicines without a prescription, a patient group direction (PGD) or a patient specific direction (PSD).

• For administration (injectable local anaesthetics): 2% lidocaine with 1:80,000 adrenaline; 4% articaine with 1:100,000 or 1:200,000 adrenaline; 3% mepivacaine; 3% prilocaine with felypressin
• For supply during treatment: lidocaine/prilocaine periodontal gel; sodium fluoride varnish 50 mg/ml (2.26%); minocycline 2% periodontal gel; lidocaine 15% / cetrimide 0.15% oromucosal spray
• For patient take-home use: sodium fluoride 0.619% (2,800 ppm) paste; sodium fluoride 1.1% (5,000 ppm) paste; nystatin oral suspension

This list does not include systemic antibiotics or other general prescription-only medicines. Hygienists and therapists may additionally administer medicines under an appropriately authorised PGD or under a prescription issued by an authorised prescriber.

Documentation requirements when working within scope

Regardless of whether you work under direct access or in a supervised setting, the same record-keeping standards apply to dental hygienists and therapists as to dentists. The GDC Standards for the Dental Team (2013) and the FGDP(UK)/CGDent Clinical Examination and Record Keeping guidelines (2016) apply in full. Your clinical records must include:

• Date of appointment and the clinician’s name and GDC registration number
• The presenting complaint or reason for the appointment
• A current medical history, including medications, allergies, and relevant systemic conditions — updated at every visit
• Clinical findings documented specifically (BPE codes; pocket depths where charting is performed; plaque and bleeding scores; soft-tissue findings)
• Radiographic justification (IRMER 2017) and quality grading (PHE/FGDP 2020 A/N scale) where radiographs are taken
• The treatment carried out, the specific tooth (Palmer or FDI notation), materials used, batch number and expiry of any LA administered
• If working under direct access: the patient’s referral status, any onward referral made and to whom, and the timeframe
• Valid, documented consent, including material risks discussed in accordance with Montgomery v Lanarkshire Health Board [2015] UKSC 11

Records must be contemporaneous. If a complaint or GDC investigation arises, a dental hygienist or therapist’s clinical records will be subjected to exactly the same medico-legal scrutiny as a dentist’s — "if it isn’t recorded, it didn’t happen" applies with equal force.

How Nosht supports DCP documentation

Nosht provides structured clinical note templates designed for UK dental hygienists and therapists. Unlike AI audio scribes, Nosht’s templates are GDC-Standards-aligned and built around DCP workflows: periodontal assessment, root surface debridement, fluoride application, direct-access intake, and referral documentation. Templates prompt BPE recording and periodontal charting, capture medication/LA batch and expiry, include Montgomery-aligned consent prompts, and provide direct-access intake and referral pathway fields. No patient data is stored by Nosht; the completed note remains in your practice management system.

Can a dental hygienist work without a dentist present?

Yes. Since 1 May 2013, dental hygienists in the UK have been able to work under direct access, meaning they can see patients and carry out treatment within their scope of practice without a dentist being present or having issued a referral. However, the hygienist must be able to refer to a dentist when they identify findings outside their scope, and their indemnity must cover direct access practice (GDC Direct Access guidance, in force 1 May 2013).

What can a dental therapist do that a dental hygienist cannot?

The principal additional procedures within a dental therapist’s scope include: placing direct restorations (fillings) in both primary and permanent teeth, extracting primary (deciduous) teeth, and undertaking pulpotomies and placing pre-formed crowns on the primary dentition — all explicitly within scope per the GDC (2025). Both titles share the same periodontal and preventive scope. Therapists do not extract permanent teeth, carry out pulp procedures on adult teeth, or undertake orthodontic or indirect restorative treatment.

Can a dental hygienist or therapist prescribe antibiotics?

No. Dental hygienists and therapists are not independent prescribers and cannot prescribe prescription-only medicines, including antibiotics. They can supply and administer certain medicines under the Schedule 17 exemptions of the Human Medicines Regulations 2012 without a prescription, but that list does not include systemic antibiotics, and the exemptions mechanism does not confer prescribing rights. Antibiotic prescribing still requires referral to, or collaboration with, an authorised prescriber.

What does "working to scope" mean in practice?

Working to scope means only performing procedures you are registered and competent to carry out. It is not enough to be registered in a particular category — you must also hold verifiable training and be competent in each specific procedure you perform. If you have not carried out a procedure during your training, or if your skills have lapsed, you must not perform it until you have updated your competence, in accordance with GDC Principle 7 (Standards for the Dental Team, 2013).

What should I document when working under direct access?

When working under direct access you must document: the basis on which the patient attended (self-referral or dental referral); a full current medical history; clinical findings within your examination scope; any findings that require onward dental assessment, and the referral made; treatment carried out with consent; and the patient’s named dentist (if any). Failure to document onward referrals made for findings outside your scope is a significant medico-legal vulnerability.

Does direct access change my record-keeping obligations?

No. The same FGDP/CGDent and GDC record-keeping standards apply regardless of whether a patient was referred by a dentist or attended under direct access. The additional obligation in a direct-access setting is to document your assessment of whether the patient needed to see a dentist before or alongside treatment, and to record any onward referral.

Are dental hygienists and therapists subject to CQC inspection?

If you work in a CQC-registered dental practice (as virtually all dental practices in England must be), your records, clinical governance, and scope-of-practice compliance form part of the CQC inspection framework, which includes ensuring all clinicians are working within their registered scope. The devolved nations have their own regulators: Healthcare Improvement Scotland (HIS), Healthcare Inspectorate Wales (HIW), and the Regulation and Quality Improvement Authority (RQIA) in Northern Ireland.

What happens if I carry out a procedure outside my scope?

Performing a procedure outside your registered scope of practice may constitute an unlawful dental act under the Dentists Act 1984, expose you to a GDC fitness-to-practise investigation, and invalidate your professional indemnity. It may also give rise to civil liability if the patient suffers harm. The GDC takes scope-of-practice breaches seriously; cases have proceeded to fitness-to-practise hearings where DCPs have performed procedures explicitly excluded from their scope.