NMBI Professional Competence Scheme: Pilot Findings and Draft Rules

Is the NMBI Professional Competence Scheme mandatory yet?

Do you have to log hours yet? No. NMBI's own scheme page says the pilot has finished and that it is "revising and strengthening" parts of the scheme before formally introducing it. It expects to publish the finalised scheme in November 2026. Its pilot page adds that formal introduction is planned for January 2027. Doctors already work under a statutory competence scheme built on a plan; our guide on how to write a professional development plan for the PCS shows how that model works.

Those dates are plans, not law. The legal power to run a competence scheme is in Part 11 of the Nurses and Midwives Act 2011, and the Irish Statute Book's legislation directory still lists sections 87 to 91 as "Not yet commenced. Requires commencement order under s. 1(2)" (directory updated to 29 May 2026). NMBI's May 2026 findings report says the same: implementation "will be subject to commencement of the relevant provisions of Part 11".

When we checked in October 2026, NMBI had not published a final scheme, and we found no NMBI announcement of one. So for now, the mandatory part of your competence duty comes from the Code of Professional Conduct and Ethics, which NMBI says requires you to maintain your competence and keep your knowledge and skills current. NMBI states that this applies to all registrants, including retired registrants who want to stay registered or return to practice. Our overview of NMBI registration and CPD requirements covers the wider registration picture. This article goes further into the pilot itself.

Confirmed vs draft: an item-by-item split

The main risk right now is treating draft figures as rules. Everything in the right-hand column comes from documents NMBI itself marks as draft or pilot.

The draft figures come from NMBI's Professional Competence Scheme Guideline for Registered Nurses and Registered Midwives, which is watermarked "DRAFT" throughout and carries no date or version number. The findings report does not restate hour targets for the final scheme, so treat 60 and 450 as a working assumption only.

What Part 11 will require once it is commenced

Part 11 is short, and it explains why NMBI cannot simply switch the scheme on:

Sources: sections 88 and 90 on the Irish Statute Book, and the Law Reform Commission revised text of sections 87 and 89.

So commencement and the scheme are separate steps: the Minister commences Part 11 by order, and the scheme itself needs approval under s. 89(2). The one-year window in s. 89(1) runs from commencement, which is why NMBI tested the scheme in advance. NMBI's 2024 consultation report listed working with the Department of Health on statutory instruments and commencement as a next step. Without a commencement order, the January 2027 date cannot hold.

How the NMBI competence scheme pilot ran

The pilot followed a public consultation on the draft guideline, which closed on 16 February 2024 with 1,989 valid responses. NMBI's Board approved the consultation report on 27 November 2024. The pilot sites covered every division of the Register, across acute general hospitals, maternity hospitals, community care, education and social care services. The findings report sets out the sequence:

1. Plan phase (January to March 2025)

   Regional education sessions (271 attendees), self-assessment and a learning plan. 527 survey responses.

2. Do phase (April to September 2025)

   Participants completed CPD and practice hours. Pilot materials set a pilot-year target of 20 CPD hours and 150 practice hours, with short activities in the same category allowed to be combined into one recorded unit. 376 survey responses.

3. Employer phase (August to December 2025)

   Phase Two tested the Employer Facilitation Framework (employer survey: 33 of 69 responded).

4. Study phase (October 2025)

   Reflection on learning and its impact on practice. 306 survey responses.

5. Trial audit (13 January to 23 February 2026)

   A random sample from each site had six weeks to submit practice-hours verification, CPD records with reflections, and a signed declaration.

6. Close and final survey (April to May 2026)

   The pilot ended in April 2026. A final survey ran from 28 April to 8 May 2026 (290 responses), and the findings report followed in May 2026.

NMBI pilot findings: the numbers that matter

All figures are from NMBI's findings report. Read them with their denominators in mind. The 87% figure covers the 79 people who submitted, not all 115 sampled: 28 sampled participants did not respond. Of the 79 submissions, 7 were partially compliant and 3 non-compliant. In 9 cases the nominated verifier did not confirm practice hours, and those participants were not assessed as non-compliant.

Reflection was the sticking point

At the Study phase, 52% found the reflective process administratively burdensome and repetitive, and 44% wanted clearer guidance, structure and examples. Participants used familiar models such as Gibbs, Johns and Rolfe. For weak-versus-strong rewrites under another Irish regulator, see our CORU CPD reflection examples. Yet in the final survey, reflection on practice (20%) was ranked the most valued aspect almost as often as organising learning (21%).

How people paced the work

42% worked gradually through the year and 37% in stages; 21% left it close to the deadline or to the last minute. On impact, 41% cited greater awareness of professional roles and 22% better learning planning, but only 3% reported a direct change to practice or decisions, and 16% no influence.

Employers were aware but stretched

Every employer who responded knew about the duty to facilitate, and 97% were familiar with the scheme's requirements. The Director of Nursing or Midwifery was most often named as the accountable person (67%). Staffing, limited protected time and resources were the main barriers. (The report has minor internal inconsistencies, such as 37 sites in the overview but 36 in the final survey.)

What NMBI says will change in the final scheme

The findings report lists these planned changes, all aimed at the time and paperwork burden participants described:

The report also calls for more emphasis, at the planning stage, on the competence your own role and scope of practice require. A pilot-era NMBI presentation also showed planning milestones of national implementation in 2027 and an audit in 2030. These were projections on a slide, not commitments, and the final scheme will confirm the real audit timetable.

How nurses and midwives can prepare for the scheme now

"Low-regret" means worth doing whatever the final scheme says: your Code duty already applies, and every draft so far rests on a plan, learning, reflection and evidence of practice. None of these steps adopts the draft model.

• Keep a simple learning record. Note the date, duration, topic and evidence (a certificate or a few lines of notes) for meaningful learning, whether from work, reading or online CPD courses for nurses and midwives.
• Link learning to the Code. Get used to writing one or two lines on how an activity relates to the 2025 Code. Pilot participants found applying the Code one of the hardest parts. Our course on the six principles of the 2025 NMBI Code can help.
• Practise short, structured reflection. The final scheme moves to a three-prompt Study Statement, so brief reflections without identifiable details are good practice. Our Reflection for Fitness to Practise course works through Gibbs, Rolfe and Johns.
• Know who would verify your practice hours. In the pilot, verifiers were Directors of Nursing or Midwifery, line managers or HR staff. Agency and multi-employer staff may need to plan this earlier.
• Match learning to your scope. Base your next learning on what your current role actually asks of you, not on what is easiest to collect.
• Watch two pages. NMBI's Professional Competence Scheme page for the final scheme, and the Irish Statute Book entry for a commencement order.

If quality improvement is part of your role, it helps to know that the scheme is built on the same PDSA logic used in improvement work. Our quality improvement and clinical audit course covers running PDSA cycles in practice. Prescribers have an extra layer of competence expectations, covered in our guide to nurse prescriber CPD requirements in Ireland.

If you lead or manage nurses and midwives

Section 90 is the part most likely to change things at ward and service level. Once commenced, it requires employers to facilitate competence maintenance, and NMBI's Employer Facilitation Framework is how it proposes to describe that duty in practice. The framework, piloted in 2025 and still being refined, groups facilitation into two components:

• Learning opportunities: CPD information, annual CPD meetings, training on new policies and technology, online and in-person training, upskilling and access to learning resources.
• A supportive environment: workplace culture, a CPD policy, line manager support, planning and communicating CPD sessions, training needs analysis and access to a CPD e-portfolio.

Consultation respondents asked NMBI to define what "facilitate" means, how employers would be monitored and what recourse staff would have if not facilitated; small employers such as GP practices were a particular concern. Those questions stay open until the final scheme. The low-regret step for managers is to map protected learning time, training needs analysis and verification capacity now, without rolling out the draft model locally.

Mistakes to avoid while the scheme is still draft

Under the draft model the annual competence declaration would sit within registration renewal; see our guide to annual registration renewal for NMBI and other Irish regulators.

Checked against the official sources above in October 2026. The scheme is still in development, so confirm the current position with NMBI before relying on any figure.