If the Medical Council selects you for a PCS audit, doctors practising in Ireland normally submit a copy of their Statement of Participation and nothing more. If you are short of the 50 annual hours, declare it honestly on your retention form and work with your scheme. Persistent non-compliance means three continuous years, and exemptions apply to leave, illness and mostly overseas practice, not to part-time or retired doctors.
Key points
- A Council audit checks your annual declaration; your scheme's verification checks your recorded activity. Answer both if asked.
- Under Rule 9(4) of S.I. No. 176 of 2025, the Statement of Participation is, subject to exceptions, the only evidence of CPD the Council accepts.
- You must keep CPD evidence for six years, and the Council can audit a PCS year for up to five years after it ends.
- A single short year is not "persistent" non-compliance. Scheme operators must notify the Council of persistent non-compliance, defined in the Guidelines as three continuous years.
- Refusing or failing to cooperate is more serious than a shortfall: the Act requires the Council to make a complaint in that case.
- There are no exemptions for working less than full-time, working in a non-clinical role or being retired.
Two different situations: an audit letter or a credit shortfall
"PCS audit" and "PCS non-compliance" feel similar, but they are two separate doors. An audit is the Medical Council verifying the declaration you made when you retained your registration. Non-compliance is about whether you actually met the annual requirements: enrolment within 60 days of 1 May, at least 50 hours of CPD and adherence to the Guidelines. You can be audited while fully compliant, and you can be non-compliant without ever being audited.
Door 1: "I have been selected for audit"
- You receive letters by post and email at your registered address.
- Practising in Ireland: send a copy of your Statement of Participation.
- Trainee Specialist Division or overseas: different evidence (see below).
- The real risk is not responding, which puts your registration at risk.
- Outcome is sent to you before your next annual retention form.
Door 2: "I am behind on my credits"
- Check whether a reduction or exemption already covers you.
- If not, close the gap before 30 April where you can.
- If you still fall short, tick "No" on the retention declaration.
- Your scheme supports you first; time-bound opportunities follow.
- Complaints are linked to persistence, non-cooperation or an inaccurate declaration.
You can be in both at once: audited for a year in which you were short. That is manageable if your declaration was honest.
Who checks what: scheme verification, the retention check and the Council audit
Three different checks can touch your PCS record, and each wants different evidence.
| Check | Who runs it | What it looks at | What you provide |
|---|---|---|---|
| Scheme verification | Your scheme operator (postgraduate training body) | A sample of enrolled doctors each year; all activity recorded on the scheme's electronic platform | Evidence supporting the activities you recorded, uploaded to the platform |
| Retention quality check | Medical Council | Your annual retention form answers compared with scheme data | Only if asked, for example proof of enrolment or your Statement of Participation |
| Maintenance of professional competence audit | Medical Council | A sample of doctors' declarations | A copy of your Statement of Participation (or the overseas or trainee alternatives) |
The Guidelines say training bodies run an annual verification of a percentage of enrolled doctors, that verification examines all recorded activity on the doctor's platform, that activity not supported by evidence "will not be considered", and that activity recorded outside the scheme's platform will be disregarded.
Operators describe their own verification differently. RCSI says it verifies roughly 3 to 5% of participants each year, starting in June or July, and notifies selected doctors by email. The Irish College of GPs says doctors who are successfully verified are removed from its selection pool for the following five years. Other schemes publish their own policies.
At annual retention, the Council quality-checks the information on retention forms against scheme data, and those checks can lead to a request for proof of enrolment or a Statement of Participation. The full retention process, including fees and the other declarations, is covered in our annual registration renewal guide.
Selected for a Medical Council PCS audit: what do you need to send?
The Council contacts a sample of doctors each year and asks them to support their declaration with evidence. It does not publish the sample size or selection criteria on its audit pages. Selected doctors receive correspondence by post and email, so keeping your contact details up to date is part of being audit-ready. If you have not been contacted, no action is needed beyond your normal professional competence activity.
What the Council asks for, by situation
| Your situation in the audit period | Evidence to submit (copies, not originals) |
|---|---|
| Practising in Ireland and enrolled in a scheme | Your Statement of Participation from a recognised postgraduate training body. The Council calls this "the only document we require" |
| Registered in the Trainee Specialist Division on a recognised training programme | Confirmation of your training status for that period |
| Practising overseas (under 30 days a year in Ireland, or wholly overseas) | The Overseas Practice Declaration, plus supporting documents from the CPD structure you are enrolled in abroad and/or the local regulator |
| Overseas in a system with no CPD structure or requirement | The Overseas Practice Declaration plus your own activity report (CPD log) |
The Council says there is no need to send certificates or evidence for individual activities, and that it may verify any document submitted. That reflects the law: Rule 9(4) says that, subject to any exceptions, a Statement of Participation is the only evidence of CPD acceptable to the Council.
What your Statement of Participation shows
Your scheme produces the Statement after the end of each PCS year, generally in May. Under Rule 9(3) it must show your name and registration number, the date you first enrolled, the CPD you undertook in enrolled years over the preceding five-year period, whether your scheme has verified that CPD, and a declaration where you did not reach 50 hours but a reduction or exemption under Rule 6(3), 6(4) or 6(6) applied. So approved leave should be recorded on the Statement itself.
The time windows that matter
The two periods line up. For the 2025/26 PCS year (1 May 2025 to 30 April 2026), the Council can audit until 30 April 2031, and the six-year retention period also runs to that point.
The one thing that turns an audit into a problem
The Council states that failure to respond to an audit "places your registration with the Medical Council and continuing right to practice medicine at risk", and that failure to cooperate is a breach of the Rules that may result in disciplinary action. A late or incomplete Statement can usually be sorted out with your scheme. Silence cannot.
How to prepare your audit response, step by step
The Council's letter sets the timeframe and how to submit. These steps follow the published process.
Read the letter and note the deadline and audit period
Check which PCS year or years are being audited and how the Council wants documents submitted.
Match your situation to the evidence table
Were you enrolled and practising in Ireland, in the Trainee Specialist Division, or overseas during that period? A mid-period change may mean evidence for two situations.
Download the Statement of Participation for each audited year
Download it from your scheme's portal. If you changed scheme, get a Statement from each operator for its years.
Check the Statement before you send it
Confirm your name and registration number, the enrolment date and the hours by category. If leave or a pro-rata reduction applied, check that the Statement records it. Ask your scheme to correct any error.
Send copies only, within the deadline
The Council asks for copies, not originals, and says no certificates for individual activities are needed.
Answer any separate scheme verification request too
If your scheme has also selected you for verification, that is a separate request. The Council says doctors who receive both should respond to both.
Wait for the outcome
The Council says you will be told the outcome, and any further action, before you complete your next annual retention form.
If your Statement is thin because of weak record-keeping rather than too little learning, tighten documentation for the current year. Our Documentation for Healthcare Professionals course covers clear, contemporaneous records more broadly, and the same habits make CPD evidence easier to keep.
What happens if you don't meet PCS requirements?
Falling short of 50 hours, or of a category minimum, in one PCS year is a compliance gap, not automatically a disciplinary matter. The framework has several stages before a complaint becomes possible.
Stage 1: your declaration at annual retention
When you retain registration, you declare that you were enrolled for the current year and that you achieved the minimum CPD requirements for the previous year. The Council says that if you are not compliant with your CPD requirement it encourages you to declare this by ticking "No", and that making an inaccurate declaration may result in a complaint. The honest "No" is expected; a false "Yes" is the risk.
Stage 2: support from your scheme
The Guidelines say training bodies will, in the first instance, identify and support doctors who are struggling to meet the CPD requirements, that doctors are reminded of their duty, and that time-bound opportunities will be provided to address compliance.
Stage 3: reporting persistent non-compliance
Each scheme operator must monitor its doctors' compliance, report to the Council on compliance in the form the Council sets, and notify the Council where it has reasonable grounds to believe a doctor has "persistently failed to demonstrate compliance" (Rule 13(c) to (e)). The Guidelines define persistently non-compliant as not meeting the annual requirements "for a period of three continuous years". A footnote excludes doctors who had pro-rata requirements in one of those years because they joined part way through.
Stage 4: what the Council can do
To investigate an alleged breach, Rule 9(6) lets the Council seek an explanation, call the doctor to a meeting, or ask for an undertaking or consent to referral to a professional competence scheme, or to requirements to improve competence and performance.
Where a complaint becomes possible
The Medical Practitioners Act 2007 draws a clear line. Section 94 places a duty on every doctor to maintain professional competence and to cooperate with requirements in the Rules. Section 91(6)(a) says that where the Council considers a doctor has refused, failed or ceased to cooperate with those requirements, it "shall forthwith make a complaint". Section 91(7), as substituted from 6 May 2025, gives the Council a discretion to make a complaint where a doctor has had every reasonable opportunity to improve but remains below the required standard. Under the Guidelines, failing or refusing to submit requested documentation is also a breach that may lead to a complaint.
| Situation | What the framework provides |
|---|---|
| One year short, declared honestly | Scheme support and time-bound opportunities to address compliance |
| Three continuous years short | Persistent non-compliance: the scheme notifies the Council; Rule 9(6) options open |
| Still below standard after every reasonable opportunity | Council may make a complaint (s.91(7)) |
| Refusing, failing or ceasing to cooperate, or not submitting requested documents | Council must make a complaint (s.91(6)(a)) |
| False or inaccurate declaration | May result in a complaint |
Your PCS information is confidential
Section 95 of the Act requires anyone who obtains information through functions relating to a professional competence scheme to keep it confidential, subject to limited exceptions such as anonymised summaries, certain legal proceedings and court orders. Breaching that duty is an offence.
If a concern has already become a complaint, see our Medical Council remediation courses guide.
PCS exemptions and reduced requirements that genuinely apply
Before treating a low total as non-compliance, check whether the Rules already reduce or remove your requirement.
| Circumstance | What changes | What you must still do |
|---|---|---|
| Not practising in the State for more than 3 months in the PCS year because of maternity, parental, carer's, adoptive or other statutory leave, illness, or other substantive reasons accepted by your scheme (Rule 6(4)) | Exempt from the 50-hour requirement for that year | Give written certification to your scheme; stay enrolled (the Guidelines say you must still enrol); declare under Rule 8(a)(iii) |
| Practising in the State for less than 30 days in the PCS year and practising in another state (Rule 6(5)) | Exempt from Irish enrolment, the 50 hours and the Guidelines | Comply with the other state's competence requirements; complete the Overseas Practice Declaration at retention |
| Entered on or restored to the register, or starting or restarting practice in the State, on or before 2 March (Rule 6(3), 6(6)) | Hours reduced proportionately | Enrol within 60 days of registering; complete the reduced hours |
| Registered after 2 March | No enrolment needed until the next PCS year | Enrol for the new year from 1 May |
| Trainee Specialist Division, or visiting EEA practitioner on a temporary and occasional basis (Rule 5) | The competence Part of the Rules does not apply | Declare this at retention; trainees may be asked to confirm training status |
| Working less than full-time, in a non-clinical role, or retired | No exemption | Full requirement applies; retirement and semi-retirement are expressly excluded from Rule 6(4) |
The leave and illness route is in Rule 6(4), which also covers non-practising doctors who are not in a position to undertake CPD for that period, and expressly excludes retirement and semi-retirement. The Guidelines are blunt on the last row: "There are no exemptions for doctors working less than full-time, in a non-clinical role or retired." CPD during leave is encouraged but not mandatory.
How the pro-rata reduction is set out
For doctors joining part way through a PCS year, Table 2 of the Guidelines gives guide figures.
| Timeframe, as worded in the Guidelines | CPD hour requirement |
|---|---|
| Enrolled for less than 3 months into the scheme year | 12 hours |
| Enrolled for less than 6 months into the scheme year | 25 hours |
| Enrolled for less than 9 months into the scheme year | 37 hours |
Confirm your exact reduced figure with your scheme rather than estimating it.
Overseas and telemedicine
The Council's overseas guidance says doctors practising abroad must enrol in an Irish scheme once they spend a cumulative total of more than 30 days a year practising in Ireland, and that failing to make the overseas declaration at retention "will place your continuing registration at risk". The Irish College of GPs points out that telemedicine appointments with patients located in Ireland count as practising in Ireland. Once you pass that threshold, our guide to PCS enrolment and choosing the right scheme matches doctors to the 13 schemes.
A GP takes five months' maternity leave between September and January. She is enrolled for the year, so she emails her scheme's professional competence team in writing about the leave. Her Statement of Participation shows fewer than 50 hours with a note that the leave exemption applied, and at retention she uses the declaration for doctors covered by the leave exemption (Rule 8(a)(iii)) rather than ticking "No". If she is later audited for that year, the same Statement answers the audit.
How to notify varies by scheme: the Irish College of GPs asks doctors to email its PCS team about leave of three months or more.
"Not engaged in practice": a different mix, not fewer hours
Since May 2025 there is a separate category for doctors based in Ireland who declare at annual retention that they will not engage in the practice of medicine in Ireland. It is often mistaken for an exemption. It is not: these doctors still complete 50 hours, made up of a Plan (up to 5 hours), a mix of practice review or work-based learning activity (at least 25 hours) and accredited CPD (at least 20 hours). The change is that only doctors who practise must complete the 10-hour practice review activity.
There is a consequence for prescribing. The renewal declaration set out in the Medical Council (Evidence of Indemnity) Rules 2018 includes a statement that you will not be engaged in the practice of medicine during the registration period, or that your practice will not involve engagement with patients, with the note that ticking it "excludes you from the entitlement to issue prescriptions". If you still prescribe, even occasionally, that option is not for you.
Doctors who cannot or will not take part in a scheme at all are advised by the Council to consider voluntary withdrawal from the register. Withdrawn doctors are not entitled to practise medicine in Ireland and are not subject to professional competence requirements. That is a significant decision; check the Council's withdrawal and restoration information before taking it.
Recovering a shortfall within the PCS year
Nothing in the Rules or Guidelines provides for carrying hours forward or adding them to a previous year, and the Rules require 50 hours to be undertaken and recorded "in each scheme year". The practical window is therefore the current PCS year, which ends on 30 April.
Know your scheme's recording window
Some schemes allow a short period after 30 April to upload activity completed during the year. The College of Anaesthesiologists, for example, gave doctors until 14 May 2026 to upload 2025/26 activity, and says activity logged after its two-week grace period will not appear on the Statement of Participation. The Irish College of GPs asks doctors to record everything before 30 April.
Work out which category is short
Most shortfalls are in one category rather than the total. For doctors in practice, the minimums are 10 hours of practice review (one activity), 15 hours of work-based learning and 20 hours of accredited continuing education, with up to 5 hours for the Plan.
- Practice review short: a single audit, quality improvement project or practice evaluation needs to reach 10 hours. Our practice review ideas guide sets out options, and the Quality Improvement and Clinical Audit course explains audit design, PDSA cycles and re-audit.
- Work-based learning short: much of it already happens at work but goes unrecorded. Case discussions, teaching and multidisciplinary meetings count when recorded with reflection; see what counts as work-based learning.
- Accredited CE short: only activity your scheme accepts as accredited counts, so check before booking.
- Plan missing: a plan written late is still better than none; our PDP guide shows how to write one quickly.
Short on practice review or planning hours?Our Medical Council Practice Review and PDP course (3 hours estimated learning time) walks through building a PDP and choosing an audit, QI or practice evaluation for your ePortfolio. It is CPD; whether you can record it, and in which category, depends on your scheme's rules.
See what's coveredOnline courses are not accredited continuing education unless your scheme says so, so ask before relying on one for a specific minimum. For work-based learning, our Work-Based Learning and Professional Competence course focuses on recording routine clinical work with reflection.
In February, a hospital consultant sees that his ePortfolio shows 46 hours, but only 4 hours of practice review. His total looks close to 50, yet the category minimum is missed. He completes and writes up a re-audit of a prescribing standard his department already measures, records it with a short reflection, and logs three ward-teaching sessions he had not entered. By 30 April he meets every minimum and can answer "Yes" truthfully.
Mistakes that turn a shortfall into a conduct issue
- Ticking "Yes" when you are short. The Council encourages an honest "No"; an inaccurate declaration may result in a complaint.
- Ignoring the audit letter. Failure to respond puts your registration at risk, and failure to cooperate can trigger a mandatory complaint under s.91(6)(a).
- Assuming leave sorts itself out. The Rule 6(4) exemption depends on written certification to your scheme. Telling a colleague or your employer is not enough.
- Letting enrolment lapse while on leave or abroad. The Guidelines say doctors on leave must still enrol. If you do not stay enrolled, you will not get a Statement of Participation for that year.
- Recording CPD outside the scheme platform. Activity not recorded on your scheme's electronic platform is disregarded in verification.
- Discarding evidence after a year or two. Keep it for six years; the audit window runs five years after the PCS year ends.
Your audit-ready and catch-up checklist
If you have been selected for audit
If you are behind on credits
For the full statement of the annual requirements, the eight domains and how the PCS fits together, see our Medical Council CPD requirements hub.
Learning to close a PCS gap
CPD that can support the categories where shortfalls most often happen. Check how your scheme lets you record it.
- Medical Council Practice Review and PDP3 hrs est. learning · Plan your 50-hour PCS year, build a PDP and choose an audit, QI or practice evaluation for your ePortfolioSee what's covered
- Work-Based Learning and Professional Competence3 hrs est. learning · Turn routine clinical work into recorded learning, write reflection and map it to the Eight DomainsSee what's covered
- Quality Improvement and Clinical Audit3 hrs est. learning · Design an audit, analyse the quality gap, run PDSA cycles and re-auditSee what's covered
- Documentation for Healthcare Professionals3 hrs est. learning · Write clear, contemporaneous notes and use electronic records safelySee what's covered
Check with your scheme how, and in which category, you can record them.
Frequently asked questions
Does being selected for a Medical Council PCS audit mean I am suspected of something?
No. The Council contacts a sample of doctors each year to support the declarations made at annual retention. Selection is part of routine monitoring, and if you have not been contacted, no action is needed.
Do I need to send CPD certificates to the Medical Council if I am audited?
Not if you are enrolled and practising in Ireland. The Council says the Statement of Participation is the only document it requires and that there is no need to submit certificates for individual activities. Keep certificates for your scheme's verification.
How far back can a Medical Council audit go?
Rule 9(9) of S.I. No. 176 of 2025 lets the Council audit compliance for up to five years after the end of the relevant PCS year. Doctors must keep CPD evidence for six years from the start of each PCS year, which covers that window.
I missed the 50 hours by a few credits. Will I be reported to the Medical Council?
A single short year, declared honestly, is handled first by your scheme, which identifies and supports doctors who are struggling and provides time-bound opportunities to address compliance. Schemes must notify the Council of persistent non-compliance, which the Guidelines define as three continuous years.
Can I add last year's missing hours to this year's record?
The Rules and Guidelines do not provide for carrying hours forward or backward between PCS years, and 50 hours must be undertaken and recorded in each scheme year. Some schemes allow a short upload window after 30 April for activity done during the year; check your own scheme.
I am on sick leave for four months. Do I need to stay enrolled?
Yes. Under Rule 6(4), doctors who do not practise in the State for more than three months in a PCS year because of illness can be exempt from the hours requirement on written certification to their scheme. The Guidelines say such doctors are still required to enrol.
I live abroad but do occasional locums in Ireland. Do I need an Irish PCS?
If you practise in the State for less than 30 days in the PCS year and comply with the competence requirements of the state where you practise, Rule 6(5) exempts you from Irish enrolment and hours. You complete the Overseas Practice Declaration at retention. Once your practice in Ireland goes beyond that, you need to enrol.
Official sources used in this guide (20)
- Irish Statute Book, S.I. No. 176 of 2025, Medical Council (Maintenance of Professional Competence) Rules 2025 (2025)
- Irish Statute Book, S.I. No. 176 of 2025, HTML version (2025)
- Law Reform Commission, Medical Practitioners Act 2007, section 91 (revised, 2025)
- Law Reform Commission, Medical Practitioners Act 2007, section 94 (revised, 2025)
- Law Reform Commission, Medical Practitioners Act 2007, section 95 (revised)
- Irish Statute Book, S.I. No. 222 of 2018, Medical Council (Evidence of Indemnity) Rules 2018 (2018)
- Medical Council, Maintenance of Professional Competence Guidelines (2025)
- Medical Council, Updates to annual CPD requirements: information booklet for doctors (2025)
- Medical Council, Key differences between current and new MPC Framework (2025)
- Medical Council, Audit Information for Doctors (accessed 2026)
- Medical Council, Monitoring and Audit (accessed 2026)
- Medical Council, Statement of Participation (accessed 2026)
- Medical Council, Annual retention FAQ: professional competence requirements (2026)
- Medical Council, Overseas Doctors (accessed 2026)
- Medical Council, Doctors not in active practice (accessed 2026)
- Irish College of GPs, PCS FAQ: Doctors in different working circumstances (accessed 2026)
- Irish College of GPs, PCS FAQ: About professional competence (accessed 2026)
- Irish College of GPs, PCS Enrolment Guidance (accessed 2026)
- RCSI, Professional Competence Scheme FAQs (accessed 2026)
- College of Anaesthesiologists of Ireland, PCS year 2025/2026 ends on 30 April 2026 (2026)
Checked against the official sources above in October 2026. Rules and fees change, so confirm current requirements with your regulator or scheme.