What you're actually registering
Supported living services register for the regulated activity of personal care — the same activity as a home care agency. You are not registering the accommodation.
That distinction drives almost everything else, and it's where applications go wrong.
The separation of care and accommodation
CQC's guidance is explicit. Where people live in accommodation on the condition that they both need and receive a care service while living there, "there must be a real separation between the provision of personal care and the accommodation agreements" for the service to be correctly registered for personal care.
In practice this means a person's tenancy must not depend on receiving care from you, and they must be able to change care provider without losing their home.
If the two are bound together, you're not running supported living. You may be running a care home — which is a different regulated activity, a different application, and a registration CQC may refuse.
Is it supported living or a care home?
The test isn’t the building, the number of people, or what you call the service. CQC is explicit: “It is the nature of the care being provided by an organisation that determines if registration is required and which regulated activity is applicable, not local commissioning arrangements and/or what kinds of premises are involved.”
What decides it is whether care and accommodation are genuinely separate, or provided as a single package.
The quick test I use. Ask whether the person could do each of these without affecting their housing:
Stop receiving personal care altogether
Arrange for a different provider to deliver their care
Refuse the care provider or the housing provider access to their home
If the honest answer to any of those is no — if stopping the care would cost them their home — you’re describing a care home, whatever the paperwork says.
Signs the model is genuinely supported living. CQC’s indicators include separate contracts for care and accommodation with no overarching agreement restricting who provides the care; care and accommodation that run separately and don’t rely on each other; a genuine choice of care provider; the person having unrestricted access to every part of their home apart from co-tenants’ private space; and decisions about tenancy, rent and notice being made by whoever controls the accommodation, not by the care provider.
Signs it’s really a care home. CQC’s indicators point the other way where the same legal entity provides both with one group of staff and no clear separation; where two entities provide a combined package between them, whether companies in the same group or unrelated organisations working together; where the person must accept care from the accommodation provider in order to have the accommodation; or where people don’t hold genuine and valid occupancy agreements.
Two things providers get wrong
“We’re fine because the care company and the housing company are separate.” Not necessarily. CQC looks at how closely the two work together. A combined package delivered by two companies in the same group is still a combined package.
“We’re fine because everyone has a tenancy agreement.” Also not necessarily. CQC addresses this directly: even where people hold valid occupancy agreements, care and accommodation can still be provided as a single package. Inspectors look at whether the rights of occupation are linked to care from a particular provider.
The same organisation can do both — this isn’t prohibited. But where one legal entity provides care and accommodation, there must be separate agreements and the person must have a real choice about who provides their care. The separation has to be genuine, not presentational.
If you want a structured way to check your own model, the National Development Team for Inclusion’s Real Tenancy Test is the tool CQC itself points to.
Right support, right care, right culture
If your service will support autistic people or people with a learning disability — as most supported living services do — this is the guidance that decides your application.
Right support, right care, right culture is statutory guidance under section 23 of the Health and Social Care Act 2008. It replaced Registering the right support, and CQC confirms the underlying policy is unchanged.
The three tests:
Right support — the model of care and setting maximises people's choice, control and independence
Right care — care is person-centred and promotes dignity, privacy and human rights
Right culture — the ethos, values, attitudes and behaviours of leaders and staff ensure people lead confident, inclusive and empowered lives
CQC states it will only register providers who can demonstrate their service will maintain dignity and privacy and facilitate person-centred care, in line with best practice, and not be developed as new campus or congregate settings.
The six-bed myth
Many providers believe CQC applies a six-bed limit. It doesn't, and it says so directly: "CQC has never applied a 6-bed limit when registering and assessing providers."
The NICE guidance CQC refers to describes "small" services as usually no more than six people, and CQC continues to cite it — but it is clear this is not an absolute upper limit.
What CQC does say is that providers of larger services "will need to work to clearly demonstrate that they deliver high-quality, person-centred care", and that it is unlikely to register services not provided in a way similar to ordinary residential accommodation.
So size isn't a pass or fail. It raises the standard of proof.
Talk to CQC before you apply
For services supporting autistic people or people with a learning disability, CQC runs a pre-application process — and actively encourages it.
You complete a pre-registration questionnaire and email it to CQC. They put you in touch with a registration specialist for these services, who arranges a discussion of your proposals, helps you interpret the requirements and advises on the likelihood of registration.
CQC recommends doing this "at an early stage of your planning before you take investment decisions about your proposed service".
They can't promise registration from that conversation — only an assessment of a submitted application does that. But finding out your model won't be registered before you've signed a lease is worth a great deal.
Documents you need
The requirements are the same as for a home care agency.
Everyone must send
Statement of purpose
Complaints policy
Consent policy and procedure
Equality, diversity and human rights policy
Governance and quality assurance policies
Infection prevention and control policy
Medicines management and prescribing policy, including transportation of patient medication
Recruitment policy
Safeguarding policy and procedure
Public and employer liability insurance quote or certificate
Building control final certificate, where locations require building regulations approval
Extra for supported living services
Business plan and financial forecast
Evidence of legal occupancy
Service user guides
Staff training plan
Plus the additional form for personal care providers.
If you support autistic people or people with a learning disability
Positive behaviour support policy
Restraint policy
Plus the additional form for providers of services for autistic people and people with a learning disability.
No financial viability statement
Supported living services are exempt, along with home care agencies, care homes, corporate providers and NHS trusts. You still need a business plan and financial forecast.
Keep ready but don't send
Duty of candour policy
Freedom to speak up / whistleblowing / confidential reporting policy
List of risk assessments
Person centred care planning policies
Reportable incidents policy
Risk management policy
Sample care contract
Sample care plan
Staffing structure and rotas
Costs
Supported living is charged as community social care, the same as domiciliary care. There's no application fee. Once registered, the annual regulatory fee per location is:
£239 + (number of service users × £54.305)
With a ceiling of £92,558 at 1,700 service users or more.
For everything else — DBS checks at £20 basic or standard and £41 enhanced with barred lists, insurance, your registered manager, policies, training and software — see the costs section of my [domiciliary care registration guide], which applies equally here.
How long it takes, and what happens after you apply
CQC doesn't publish a timescale. Its guidance for personal care applications says the assessment "can take a few months" and that applications are assessed in the order received.
CQC introduced a two-stage process — initial checks, then assessment — for homecare applications in July 2025. Its published guidance on that process refers specifically to homecare. CQC hasn’t published anything extending it to supported living applications, though both register for the same regulated activity.
Why supported living applications fail
Everything in my domiciliary care guide applies here too — mismatched documents, template policies, an unprepared registered manager, a financial forecast that doesn’t match the business. But supported living applications also fail for reasons of their own, and they tend to be more fundamental. A home care application usually fails on paperwork. A supported living application often fails on the model itself.
1. The separation isn’t real
On paper there’s a tenancy and a separate care agreement. In practice, the person couldn’t change care provider without losing their home — because the landlord and the provider are the same people, or because the tenancy was only ever offered as part of a package.
What to do instead: test your model against the three questions earlier in this guide before you write a word of the application. If someone receiving your care couldn’t stop it, change provider, or refuse access without their housing being affected, the separation isn’t real yet. Fix the model first. No amount of good drafting will disguise it.
2. The service reads as congregate
CQC states it will not register services developed as new campus or congregate settings, and that it is unlikely to register services not provided in a way similar to ordinary residential accommodation. Applications fall at this hurdle when the proposal describes several flats in one building with shared staff, shared facilities and a staff office on site — a small institution rather than people’s homes.
What to do instead: describe the service from the perspective of someone living there. Where is their front door? What do they control? What happens that wouldn’t happen in an ordinary house? If the honest answers sound institutional, the design needs to change, not the wording.
3. PBS and restraint policies that could belong to anyone
These two policies carry more weight in a supported living application than almost anything else, and generic versions are obvious. A positive behaviour support policy that doesn’t mention how you’ll understand what someone is communicating, or a restraint policy that reads like a legal disclaimer, tells CQC you haven’t thought about the people you’ll actually support.
What to do instead: write them around the people you intend to support. What approaches will you use, who will be trained in them, how will you know they’re working, and what will you do when they’re not? A policy that describes your service beats a polished one that describes nothing.
4. A statement of purpose that doesn’t reflect Right support, right care, right culture
This is statutory guidance, and CQC assesses applications against it. Yet many statements of purpose read as though it doesn’t exist — full of the language of care delivery and empty of choice, control and independence.
What to do instead: go through your statement of purpose against the three tests. Right support: does your model maximise choice, control and independence? Right care: is it person-centred, and does it promote dignity, privacy and human rights? Right culture: what will leaders and staff actually do differently? Make it specific. “We promote independence” says nothing; describing how someone will choose their own staff, or come and go as they please, says a great deal.
5. Larger services with no answer to the obvious question
CQC has never applied a six-bed limit, and says so. But it’s clear that providers of larger services “will need to work to clearly demonstrate that they deliver high-quality, person-centred care”. Applications for larger schemes fail when they simply don’t address this — as though size weren’t going to be noticed.
What to do instead: if your service is larger, answer the question before it’s asked. Explain how people will have genuinely individual lives, their own front doors, their own staff where possible, and their own routines. Size isn’t a bar. Silence about size is.
The pattern? Home care applications fail on documents. Supported living applications fail on the model — and a model that isn’t right can’t be rescued by better paperwork. That’s why the pre-application discussion matters so much here, and why it’s worth testing your model before you commit to a building.
Frequently asked questions
Is supported living registered differently from a care home? Yes. Supported living registers for the regulated activity of personal care. A care home registers for accommodation for persons who require nursing or personal care. They're different applications with different requirements, and the distinction rests on whether care and accommodation are genuinely separate.
Does CQC limit supported living services to six people? No. CQC states it has never applied a six-bed limit. It refers to NICE guidance describing small services as usually no more than six people, but says this is not an absolute upper limit. Larger services need to demonstrate more clearly how they deliver person-centred care.
Do I need a financial viability statement? No. Supported living services are exempt. You still need a business plan and financial forecast.
Should I talk to CQC before applying? If you're supporting autistic people or people with a learning disability, yes. CQC encourages it, runs a pre-application process with a registration specialist, and recommends doing it before you make investment decisions.
Can the same company own the housing and provide the care? It isn’t prohibited, but it’s harder, and it’s where most supported living applications run into trouble.
CQC’s guidance is clear that the providers of care and accommodation “are not usually the same legal entity” — but it also says that even where they are, there must be a clear separation between the accommodation and the personal care. So the test isn’t who owns what. It’s whether the separation is real and demonstrable.
Where one organisation does both, CQC expects separate agreements for the care and the accommodation, and the person must have a genuine choice about who provides their care. In practice that means someone could end their care arrangement with you and bring in another provider while staying exactly where they are.
Two things to be aware of. First, using two companies doesn’t automatically solve it — CQC looks at how closely the entities work together, and a combined package delivered by two companies in the same group is still a combined package. Second, having tenancy agreements in place doesn’t settle it either. CQC says directly that care and accommodation can still be a single package even where people hold valid occupancy agreements, and inspectors look at whether rights of occupation are tied to care from a particular provider.
If you’re planning a model where you’ll be both landlord and provider, it’s worth testing it against the National Development Team for Inclusion’s Real Tenancy Test — the tool CQC itself points to — before you commit to a building.
Do I need a consultant? For supported living, more often than for home care — and for a different reason.
With a home care application, the care model is usually straightforward and the risk is in the paperwork. You can manage that yourself with time and attention. With supported living, the risk is in the model. If the separation between care and accommodation isn’t real, or the service reads as congregate, no amount of careful drafting will fix it, and you may only find out after you’ve signed a lease.
So the question isn’t really whether you need help with the application. It’s whether you’re confident your model is one CQC will register. If you are, and you’ve done this before, you can likely handle the paperwork yourself. If there’s any doubt — particularly if you’ll be both landlord and provider, or the scheme is larger, or it’s your first supported living service — getting that tested early is worth far more than help with the forms later.
CQC’s own pre-application route is free, and I’d always suggest using it. Where I add something is in getting your model and your evidence ready before that conversation, so it’s a productive one.
Supported living applications rarely fail on the quality of care someone intends to provide. They fail because the model isn’t quite what CQC can register — and that’s much cheaper to discover now than after you’ve taken on a building.
If you’d like your model tested before you commit, or support through the application itself, my CQC Registration Support page explains how I work and what it costs. If you’re at the earlier stage of working out whether your idea will fly, book a free readiness call and we’ll look at it together.