New MedCo user agreements take effect on 30 November 2026. They write right to work checks into the contract, set an experience requirement for physiotherapists and widen data protection duties for every user.
MedCo gave advance notice on 30 September 2026 and published the new wording as tracked drafts. The notice covers every category of MedCo user: authorised users, direct and indirect medical experts, and MROs. Our guide explains what MedCo is.
Which MedCo user agreements are changing
All six. MedCo's notice lists them, along with a revised Ethics Policy:
- authorised users (claimant representatives and compensators registered with MedCo): version 9
- direct medical experts: version 7, with a supplemental agreement at version 3
- indirect medical experts, who take instructions through an MRO: version 8
- MROs: version 7, with a supplemental agreement at version 3
MedCo is not inviting general comments. A user who considers a change unreasonable can say why by email, and the reply must reach MedCo before 21 October 2026.
The drafts were issued ahead of formal contractual notice, so the wording could still change. What follows describes the drafts as published.
Right to work checks for medical experts
MedCo's notice says the agreements reflect right to work requirements it told users about on 4 September 2026. In the draft MRO agreement they appear as a new clause 6. It makes the MRO responsible for ensuring that every indirect medical expert it engages keeps a valid right to work in the United Kingdom for as long as they have access to the MedCo database.
The MRO must carry out a compliant right to work check before engaging an expert, repeat it as immigration legislation, statutory codes of practice and Home Office guidance require, and keep the records for the period the law prescribes. It must have proportionate processes to confirm that the expert doing the work is the person who was checked, and give MedCo copies of the records promptly on reasonable request.
On becoming aware of an actual or suspected breach, or of a Home Office investigation, enquiry, civil penalty action or enforcement action about illegal working by one of those experts, the MRO must tell MedCo immediately. It must also cooperate with any Home Office investigation.
Where subcontracting or substitution is allowed under the agreement, the MRO must make sure the subcontractor or substitute has the right to work before any work is done, and it stays responsible for their compliance.
MedCo may audit compliance on reasonable notice. It may suspend or end the agreement immediately, by written notice, where it reasonably believes the MRO has breached the clause or illegal working has occurred in connection with an expert it engages.
The draft agreement for indirect medical experts has matching duties. The expert must keep a valid right to work in the United Kingdom, give the MRO evidence of it before the agreement starts, and tell the MRO in writing if they lose it or learn of anything that may affect it.
A five-year requirement for physiotherapists
The drafts define a new term, Equivalent Registration: registration with the Health and Care Professions Council together with five years of relevant post-qualification experience in musculoskeletal injuries.
There is a transition. A physiotherapist who is listed before the new agreement takes effect, and does not have Equivalent Registration, must tell MedCo in writing before reaffirming the agreement. They then stay listed while MedCo carries out a quality assessment or peer review.
If that is successful and MedCo confirms it, they may remain listed until they reach Equivalent Registration, subject to any further assessment MedCo requires and to staying registered with the HCPC. If it is not, MedCo can withdraw accreditation or end the agreement.
Identity checks and availability
The drafts spell out what MedCo's due diligence on experts includes: an identity check, which a third party may carry out on its behalf, and checks on ICO registration and regulatory status. MedCo may also interview an applicant.
Availability is handled differently for the two kinds of expert. A direct medical expert who will be unavailable for two weeks must mark themselves as not operational on the MedCo database. After six continuous months as not operational, they must explain why in writing and seek MedCo's agreement to stay registered.
An indirect medical expert is measured by the expert data that MROs supply. If they do not appear in it within three months of their agreement starting, or for any further continuous six months, they must tell MedCo in writing why they are not available and seek its agreement to stay on the list.
Data protection duties
The draft definition of data protection legislation names the UK GDPR, the Data Protection Act 2018, the Data (Use and Access) Act 2025 and the Privacy and Electronic Communications Regulations 2003.
The drafts widen two existing duties, keeping data secure and reporting breaches. They used to cover the personal data shared with MedCo. Under the drafts they cover any personal data the user processes under or in connection with the agreement.
A known breach of security measures that has affected, or could have affected, that data must be reported to MedCo promptly and in any event within 24 hours. The user must also tell MedCo what it has done to remedy the breach and give MedCo any information it asks for.
The drafts add that a disclosure of that personal data to a third party, or a transfer of it outside the United Kingdom, must comply with data protection legislation.
The drafts for MROs, direct medical experts and authorised users also say that search data entered into the MedCo database must not contain personal data, and that no personal data about a claimant may be entered on the database or otherwise given to MedCo.
The Ethics Policy
The Ethics Policy already applies to authorised users, MROs and accredited experts. The revision simplifies its wording and extends some existing expectations to all users, such as cooperating with MedCo, keeping up to date with data protection legislation and following MedCo's guidance. It also adds two provisions.
A user who brings in a third party to help prepare reports must make sure that personal data is shared lawfully, and that the third party follows best practice and meets data protection requirements for the data it handles. Contingent payment arrangements in breach of the MedCo Rules are expressly ruled out.
What solicitors and insurers should check
Solicitors and insurers registered with MedCo as authorised users should read draft version 9. It widens the security and breach-reporting duties in the same way, and adds the provision on third-party disclosures and overseas transfers. MedCo's notice asks every user to consider whether any arrangement involving overseas processing or transfers of personal data needs review.
A separate change follows five weeks later. MedCo has also announced that MedCo medical reports generated from 4 January 2027 must contain all the information asked for by a revised RTA3 form, including the examining expert's name and relevant professional registration details. Using the RTA3 template itself stays optional.
Earlier changes are covered in our summary of MedCo updates for 2025 to 2026.
MedCo in numbers, August 2026
MedCo's Management Information pack for August 2026, published on 11 September, counts 35 MROs, 444 operational accredited medical experts and 986 authorised users on 1 September 2026, excluding suspended users.
In August, 13,854 searches for represented claimants ended in the selection of an MRO and 823 in the selection of a direct medical expert. Tier 1 MROs took 79% of those selections, Tier 2 MROs 15% and direct medical experts 6%.
Over the 12 months to August 2026 MedCo recorded 231,097 searches that resulted in a selection, 18,594 of them by unrepresented claimants using the Official Injury Claim service.
For a first report that must be sourced through MedCo, a MedCo search comes first, and we can be instructed only if we are shortlisted and selected. For other work, see how we arrange medical legal reports.
Checked on 4 October 2026 against MedCo's notice of 30 September 2026, the tracked agreements and Ethics Policy published with it, and MedCo's August 2026 Management Information pack. The agreements are drafts and may change before they take effect.
This article provides general information, not legal advice. Expert Medical Examination Ltd is an independent MedCo registered Tier 2 MRO and does not speak for MedCo.