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Although the legislation is a matter for the Welsh Government, and is administered by Welsh local authorities, the GCC recognises that acupuncture (commonly referred to as dry needling) is a common adjunctive therapy used by chiropractors and we have reached out to the Welsh Government to understand their expectations of Welsh chiropractors using this technique.

The below is offered as advice based on our understanding of the legislation and the expectations on chiropractors, but it is down to the professional judgement of each chiropractor to decide the appropriate approach for their own circumstances.

The legislation (in brief)

The Welsh Government's new licensing rules for special procedures in Wales came into force in November last year. These mean that anyone carrying out procedures such as piercing, tattooing, electrolysis and acupuncture (including dry needling) in Wales will need to be licensed as an individual, and will only be permitted to practise in approved premises. Eventually everyone licensed to offer dry needling and the other special procedures will be listed on the Special Procedures Wales Public Register.

What has happened already?

Anyone who was already licensed to do dry needling in Wales before 29 November (under the Local Government (Miscellaneous Provisions) Act 1982) will have been granted a transitional licence by their local authority until the end of February 2025 – however it is not clear that every Welsh local authority has notified every previously licenced business that they have issued these transitional licences.

What chiropractors need to do now

Chiropractors with a transitional licence will need to submit their application form under the new scheme by 28 February 2025. The application does not need to be agreed or finalised by local authority by this date, but the form must have been submitted in order for the transitional licence to continue to apply. If you continue to provide dry needling in Wales after 1 March without having applied for the new scheme, you will be committing an offence.

With this in mind, chiropractors are encouraged to make every effort to complete the application forms and submit them before the dealine. You may also wish to speak to the relevant local authority for further guidance. We note that the "model forms" include an opportunity to make further comments in explanation. Registrants may choose to use that space to explain how they intend to provide any outstanding information, or meet any outstanding requirements.

“I thought chiropractors were exempt from the legislation?”

In almost all cases - no. There has been some confusion about an exemption within the legislation for registered healthcare providers. While the definition of registered healthcare provider includes chiropractor, the Welsh Government has confirmed to us that the exemption ONLY applies if they are practising in the NHS, or in a premises that is registered and inspected by Healthcare Inspectorate Wales. The list of service providers required to register with HIW does not include chiropractic clinics. HIW have confirmed to the GCC that they do not inspect chiropractic clinics, and do not offer optional registration for chiropractic clinics.

Obtaining an individual practitioner special procedure licence.

Every person who will provide dry needling in a chiropractic clinic needs to apply for a special procedure licence from the local authority where they work. If you work in more than one area, you should apply to the local authority where you do most of your work.

To obtain a licence you will need to supply the local authority with

  • The details required in the model form – this includes disclosing unspent convictions for relevant offences, and declaring insurance cover.
  • A recent colour passport photograph
  • Proof of identity
  • Licence application fee
  • A basic disclosure certificate issued by the Disclosure and Barring Service (see below) or an overseas criminal record certificate as appropriate.
  • Evidence of a regulated Level 2 award in Infection Prevention and Control for Special Procedures Practitioners (see below).

Once it is granted, your individual practitioner special procedure licence will be valid for three years, and will be valid for the whole of Wales, as long as you are working in an approved premises that is referenced on your licence.

Further Details - Applying for a Basic Disclosure and Barring Service Certificate

A basic DBS check costs £21.50 and can be obtained from https://www.gov.uk/request-copy-criminal-record.

To use this service you’ll need to prove your identity using GOV.UK One Login. You’ll be able to create a GOV.UK One Login if you do not already have one.

You’ll need to provide addresses for the last 5 years (including the dates you lived at each address), and if you have them your:

  • passport
  • driving licence (full or provisional)
  • National Insurance number

It usually takes up to 14 days for you to receive your basic DBS certificate.

Further Details - Level 2 award in Infection Prevention and Control for Special Procedures Practitioners

This is a one-day course created by the Royal Society for Public Health (RSPH) and regulated by Qualification Wales. The purpose of the level 2 award is for learners to obtain a knowledge and understanding of; the importance of infection control and prevention, associated infectious and non-infectious hazards, good infection practice and controls based upon an awareness of the chain of infection and standard infection control precautions.

A list of the 11 centres that offer the course is available on the RSPH website.

Some (but not all) centres offer the course online either as a webinar, or as a “study at your own pace” package. However, we understand there is currently a backlog in offering the course – with not all centres able to offer an appropriate course to all candidates in time for the end of February.

When choosing a course you should consider if the exam fee is included within the cost, or if the exam needs to be purchased separately.

The examination

The examination is a 1-hour multiple choice paper, and the pass mark is 25 out of 30.

The exam can be taken in person (under exam conditions) or online (it is remotely invigilated). The online exam is likely to be more expensive due to the costs of remote invigilating.

A specimen paper and answer sheet are available from the RSPH.

The course can be recorded as part of your annual Continuing Professional Development for the GCC.

Applying for special procedure premises approval.

Every location where dry needling occurs will also need approval (this is akin to the previous system of inspections of premises).

For each premises you will need to provide:

  • The details required in the model application form. This includes:
    • Details of the responsible person, the premises and business. The responsible person must hold the Level 2 award in Infection Prevention and Control for Special Procedures Practitioners - even if they are not personally licenced to provide special procedures.
    • Details of the hygiene provision at the premises (how many workstations, washbasins, sharps disposal etc), including the equipment used in the sterilisation and cleaning, and the provision around PPE and first aid
    • Details of the record keeping for the business around patients, suppliers, cleaning and maintenance.
  • Proof of identity
  • Approval application fee
  • A plan of the premises
  • Evidence that the responsible person holds the Level 2 award in Infection Prevention and Control.

Once you have made the application the transitional licence will continue to apply until the local authority has completed their checks and granted the new new approval. The local authority checks are likely to include a visit (by appointment) by an officer to the premises.

Who do I apply to? List of relevant webpages for Welsh Local Authorities

Although there will be a national register, each local authority is responsible for administering the scheme locally.

The relevant webpage on special procedure licensing for each local authority is linked below, along with the method of application. Any further questions about applying should be made to the local authority. Most of these webpages also include specific contact details for the responsible team within the local authority.