Care Homes 17 April 2026 7 min read

CQC Digital Records: What Your Care Home Software Actually Needs to Do

Digital records are no longer a forward-looking recommendation for UK care homes. As of December 2025, 82% of provider locations have adopted a digital social care record. CQC inspectors now routinely request remote access to them. This article sets out what the regulations require, what inspectors actually look for, and what your software needs to produce.

82%
of care provider locations using a DSCR (Dec 2025)
91%
of people in care now covered by a digital social care record
Reg 17
Health and Social Care Act 2008 — the regulatory basis for records

The Regulatory Foundation: Regulation 17

The legal basis for care home record-keeping requirements is Regulation 17 of the Health and Social Care Act 2008 (Regulated Activities) Regulations 2014. It requires providers to maintain records that are accurate, complete, and kept securely. The regulation does not specify digital records — it specifies good records. But the practical expectation from CQC has shifted considerably.

Records under Regulation 17 must be:

  • Accurate, with no errors or omissions in essential information
  • Complete, covering the full picture of a person's care needs and the support provided
  • Legible and clear, without ambiguity about what action was taken and by whom
  • Up to date, with entries made without undue delay
  • Secure, with appropriate access controls and privacy protections
  • Accessible when needed, by the people who need them including, where appropriate, CQC inspectors

Failure to maintain compliant records underpins a significant proportion of Regulation 17 enforcement actions. It is also one of the most common reasons a home is rated Requires Improvement in the Safe or Well-Led key questions.

How CQC Inspections Have Changed

CQC now conducts both on-site visits and remote evidence reviews. When a care home uses digital records, inspectors can request access to the system from outside the home. This is a practical change with significant implications.

CQC's own guidance is explicit: where digital records are available and accessible, inspectors will not ask for paper copies. They will only request specific formats where necessary for regulatory decision-making or enforcement. The working expectation during inspections is digital access, reviewed remotely or on-site through the provider's system.

What this means for your system: If your software cannot produce the records CQC needs cleanly, quickly, and in a format inspectors can navigate, you are creating a problem at the point when you can least afford one. Inspectors who cannot access records promptly, or who encounter gaps and inconsistencies, will draw their own conclusions.

CQC changed its assessment framework in December 2024, moving from scoring at evidence category level to scoring at quality statement level. The practical implication is that records are evaluated not just as a bureaucratic check but as evidence of whether the quality statements in Safe, Caring, Responsive, Effective, and Well-Led are being met in practice.

What Records Inspectors Look At

CQC inspectors do not work through a simple checklist. They are looking for evidence of how care is being planned, delivered, and reviewed. Digital records need to support that narrative, not just hold data fields. The key areas are:

Care plans

Care plans need to be person-centred, not template-driven. They should describe what matters to the individual, how they want to be supported, their preferences, and their assessed needs. Inspectors look at whether care plans reflect the person as an individual, whether they are regularly reviewed and updated as needs change, and whether the people delivering care are actually working to what the plan says. A system that produces generic, field-filled care plans that look the same for every resident will not support a Good or Outstanding rating in Caring.

Medication administration records (MAR / eMAR)

Medicines management is one of the areas CQC examines most closely. Under Regulation 12 (Safe Care and Treatment) as well as Regulation 17, providers must keep accurate records of medicines administration. MAR charts must show every dose: given, refused, or omitted, and with clear notation of the reason for any omission. Gaps are treated as potential evidence of unsafe practice.

Electronic MAR systems are now the norm in most registered homes. CQC guidance acknowledges that eMAR promotes clarity and reduces error risk through standardisation. But inspectors are clear that the system does not remove the provider's accountability for safe administration, competent staff, and effective oversight. An eMAR that shows consistent gaps or irregularities raises the same concerns as a paper MAR with the same problems.

Incident and accident logs

Every incident must be documented promptly with the full circumstances, actions taken, and follow-up. Inspectors look at patterns across incident logs. A care home with frequent falls that show no corresponding review of the resident's risk assessment or care plan is demonstrating poor governance, regardless of whether the individual records look correct. Your system needs to support root cause analysis and show that lessons are being identified and acted on.

Risk assessments

Risk assessments should be current, specific, and referenced from care plans. A risk assessment completed at admission and not reviewed for six months is a common finding in Requires Improvement reports. Systems need to support scheduled review prompts and to link risk assessments clearly to the relevant care plan sections.

Staff records and competency documentation

Inspectors checking whether a home is Well-Led will look at whether the provider can evidence that the people delivering care are trained and competent. DBS checks, mandatory training completion dates, supervision records, and competency assessments all need to be current and accessible. This is typically managed in a separate HR or workforce module, but it needs to connect to the overall picture of safe staffing that inspectors examine.

The DSCR Standards: What Assured Systems Must Do

The Digitising Social Care (DiSC) programme, run by NHS England, maintains an Assured Solutions List of digital social care record systems. Systems on this list have been assessed against national standards for functionality, security, data interoperability, and the ability to safeguard sensitive information. Access to the NHS's £25 million funding for digital records is conditional on choosing a system from this list.

The technical standards that assured DSCR systems must meet include:

  • Data Security and Protection Toolkit (DSPT) compliance at "standards met" level. This covers data governance, cyber security, and information assurance.
  • Minimum Operational Data Standard (MODS) compliance, with a deadline of July 2026 for software suppliers. MODS defines the baseline data that care systems must record to enable interoperability across health and adult social care.
  • PRSB standards compliance, covering how care records are structured, particularly the "About Me" standard (key information the person wants professionals to know) and the Personalised Care and Support Plan standard.
July 2026 deadline: Software suppliers on the DSCR Assured Solutions List must achieve MODS certification by July 2026. This is a deadline for software vendors, not for care providers, but choosing a system from a vendor that has not met this deadline creates a real compliance risk. When selecting or renewing a system contract, ask your supplier whether they have achieved or are on track for MODS certification.

What "What Good Looks Like" Says About Digital Records

The NHS England "What Good Looks Like" (WGLL) framework describes the digital maturity levels that health and care organisations should be working toward. For social care providers, the framework sets out seven dimensions: Well Led, Ensure Smart Foundations, Safe Practice, Support Workforce, Empower People, Improve Care, and Healthy Populations.

Digital records feature across multiple dimensions. The framework expects leaders to understand the benefits of digital technology and drive adoption, not just tolerate it. Ensure Smart Foundations means having a modern, secure digital infrastructure with staff access to comprehensive, up-to-date records. Safe Practice means good data security to safely use and share information that improves care. The framework is aspirational rather than providing hard minimum thresholds for individual providers, but CQC inspectors use it as a reference point for what good governance looks like in practice.

The government's ambition, confirmed repeatedly through the DiSC programme, is that all CQC-registered care providers are "fully digitised" by the end of the current Parliament. Fully digitised means using an assured DSCR solution meeting the DSPT "standards met" level. The 18% of providers not yet using a digital social care record are increasingly outliers.

What Your Software Needs to Produce

Translating all of this into practical requirements, a care home system that will hold up under CQC inspection needs to:

  • Produce person-centred care plans that reflect individual needs, preferences, and goals — not templated text with names changed
  • Record every medication administration event in real time, with clear documentation of given, omitted, or refused doses and the reason
  • Log incidents comprehensively with timestamps, staff identification, actions taken, and links to follow-up reviews
  • Trigger review prompts for care plans and risk assessments at appropriate intervals, and flag overdue reviews
  • Provide inspector access without requiring manual preparation of a paper pack — records should be readable by an inspector navigating the system
  • Maintain audit trails showing who made each entry and when, which cannot be edited or deleted without a record of the change
  • Operate within DSPT security standards with appropriate access controls by role

A system that can do all of this cleanly — and does it in the normal flow of a working day without requiring staff to do extra documentation tasks — is one that genuinely supports inspection readiness, rather than one you prepare documentation for the night before the inspector arrives.

The Distinction Between What Is Mandated and What Is Expected

There is no single piece of legislation that currently sets a hard deadline requiring all care homes to use digital records. The obligation under Regulation 17 is to keep good records, not specifically digital ones. But the practical distinction between mandated and expected is collapsing.

When 91% of people in care are now covered by a digital social care record, when CQC inspectors routinely request digital access, when government funding is conditional on using DSCR-assured software, and when the government's stated goal is full digitisation by the end of Parliament, the question is no longer whether to adopt digital records but which system to adopt and how to make it work properly.

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