What is Fit and Proper Persons
The registered manager role: what "fit and proper" actually requires
"Fit and proper person" is one of those phrases everyone in social care uses and very few can locate in the regulations. It also gets applied to three different things, which is where the confusion starts.
So let me untangle it, and then talk about what the registered manager interview is really testing.
Three different duties, three different regulations
Under the Health and Social Care Act 2008 (Regulated Activities) Regulations 2014:
Regulation 5 — Fit and proper persons: directors.This applies to directors and those performing equivalent functions. It is a board-level duty and it is the one people usually mean when they say "the FPPR."
Regulation 7 — Requirements relating to registered managers. This is the one that governs your registered manager.
Regulation 19 — Fit and proper persons employed. This is your recruitment duty for staff generally: good character, necessary qualifications and skills, physically and mentally able to do the job, with proper checks including DBS.
They are separate duties with separate tests. Applying the wrong one is a good way to end up with a gap you did not know about.
What Regulation 7 requires
Your registered manager must be of good character. They must have the qualifications, competence, skills and experience necessary to manage the regulated activity. They must be able to properly perform the tasks intrinsic to the role. And the provider must hold the information specified in Schedule 3 in relation to them.
In practice, for adult social care, that generally means a Level 5 Diploma in Leadership and Management for Adult Care or an accepted equivalent such as the older NVQ Level 4, alongside genuine supervisory experience in the sector.
But qualification is the entry ticket, not the test. "Competence, skills and experience necessary to manage the regulated activity" is doing the real work in that sentence, and it is assessed against your specific service. A manager with strong residential experience applying to run a complex supported living service for autistic people will be asked about that gap, and rightly.
What the interview is actually testing
The fit person interview is not a quiz. I have prepped a lot of managers for it, and the ones who do well have understood what is being assessed.
Do you know this service, or do you know care in general?
The questions will be about your service. Your people, your model, your risks, your staffing. Generic good answers about person-centred care do not land. Specific answers about how you would manage a specific risk in this specific setting do.
Do you know the regulations that apply to you?
Not all of them by number. But you should be fluent in safeguarding duties, the Mental Capacity Act 2005, notifications, duty of candour under Regulation 20, and the regulations most relevant to your service type. If you are running an LD or autism service, you should be able to talk about the Regulation 18 training duty and the Oliver McGowan Code.
Do you know what is changing?
This is where a lot of managers are exposed at the moment, and it is a genuine differentiator. CQC's new sector-specific assessment framework for adult social care was published in draft in March 2026 and is due for implementation at the end of this year. The Supreme Court changed the definition of deprivation of liberty on 2 June 2026. The Mental Health Act 2025 is commencing in phases. A manager who can speak sensibly about those is demonstrating exactly the professional currency the role requires.
Would you say no?
This one is unspoken but it is there. Registered managers carry personal legal responsibility. The interview is partly assessing whether you will exercise independent judgement, or whether you will do what the provider tells you. If every answer defers to the owner, that is a problem.
Can you be honest about weakness?
A manager who says everything is fine is either not looking or not telling. Being able to name what is not yet good in your service, and what you are doing about it, reads as competence rather than as a confession.
For providers: the duty is yours too
I speak to providers who see the registered manager as the person who carries the regulatory risk. That is a misreading.
You have your own duties. Regulation 5 applies to your directors. Regulation 17 requires good governance across the service. And the practical reality is that a registered manager cannot deliver a well-run service without authority, resources and support.
Two things I would ask any provider to look at honestly.
**Does your manager have actual authority?** Over staffing, over admissions, over spend within a sensible limit. A manager who is accountable for quality but cannot decline an admission or authorise cover is in an impossible position, and it will show up in your Well-led rating.
**Are you supporting them?** Registered manager is an isolating job. Supervision, peer networks, access to advice and someone to think out loud with are not luxuries. Manager turnover is one of the strongest predictors of a service deteriorating, and it is usually preventable.
The absence problem
A practical point that catches people out. If your registered manager is going to be absent for 28 days or more, that has to be notified to CQC under the Registration Regulations 2009, and you need to tell them who is covering and how.
Extended absences without a plan, and long periods with no registered manager in post, are treated seriously. A service operating without a registered manager for months is in breach and it will be visible.
Equally, when a registered manager leaves, that is a change affecting your registration and must be dealt with promptly. Same when one joins.
What I would say to a manager thinking about it
It is a serious role and it carries personal accountability that most people underestimate when they take it. You can be held responsible individually, not just as an employee.
It is also, done well, one of the most consequential jobs in the sector. A good registered manager changes the daily experience of every person living in that service. I would not talk anyone out of it.
But go in with your eyes open, negotiate your authority at the start rather than after the first crisis, and keep your own professional development current. The regulatory environment is moving quickly this year and it is going to keep moving.
If you are preparing for a fit person interview, or you are a provider recruiting a registered manager and want help getting the process right, I'm happy to have a conversation.
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*Tiffany Nelson supports adult social care providers in England with CQC registration and inspection preparation. [tiffanynelsonconsulting.co.uk](https://www.tiffanynelsonconsulting.co.uk) | [Connect with me on LinkedIn](https://www.linkedin.com/in/tiffany-nelson-177784281)*
**Sources:** Health and Social Care Act 2008 (Regulated Activities) Regulations 2014, Regulations 5, 7, 17, 19 and 20 and Schedule 3; Care Quality Commission (Registration) Regulations 2009; CQC guidance on registered managers and on assessing applications.