Proposed changes to SSSC registration requirements
Question 1: Adult day care services
Proposed rating: Mostly agree
SASW supports the principle of registration for support workers, practitioners and supervisors in adult day care services. These workers hold significant responsibility for people who may be at risk. Registration brings them within the Codes of Practice and gives the public a clear route to raise concerns.
Our support is qualified for three reasons.
First, adult day care is a diverse sector. It includes local authority services, large voluntary sector providers and very small community organisations. The SSSC will need role definitions that reflect this range. Definitions drawn too tightly around traditional building based day services will exclude workers doing equivalent work in outreach and community settings.
Second, qualification requirements must be matched by qualification supply. Registration without accessible, funded routes to the required award places the burden on individual workers and on employers with limited training budgets.
Third, fees matter. Many day care staff are on low pay. A registration fee that is modest in isolation is not modest to a worker on or near the real Living Wage. SASW asks that fee levels for new groups are set with an explicit affordability assessment, and that employer funded registration is encouraged as the norm.
Question 2: Offender accommodation services
Mostly agree
SASW agrees that practitioners, supervisors and managers in offender accommodation services should be registered. The people using these services are often at high risk and have complex needs. The work involves significant discretion, risk assessment and control over the daily circumstances of residents. That combination warrants regulation.
We raise two points.
First, the workforce in this sector is drawn from mixed backgrounds. Some staff have criminal justice or housing experience rather than social care qualifications. Some have lived experience of the justice system, and this is a strength rather than a barrier. Registration requirements must not exclude people with relevant convictions where those convictions do not bear on their fitness to practise. SASW asks that the SSSC states clearly how it will assess this group at the point of first registration.
Second, this sector already faces recruitment difficulty and high turnover. A poorly sequenced registration requirement risks losing staff. Transitional arrangements should give a realistic period to achieve qualifications while remaining in post.
We would also welcome clarity on how registration interacts with the wider reform of community justice and with the arrangements for services commissioned across local authority boundaries.
Question 3: Social work assistants
Mostly agree
SASW agrees that social work assistants should be registered. This group carries out work of real consequence with people who are often at risk. It is anomalous that they sit outside regulation while colleagues doing similar work in care services are registered.
Our qualified support rests on a concern about role boundaries.
The term social work assistant is used inconsistently across Scotland. In some authorities it describes a clearly defined support role. In others it describes staff carrying out assessment and case holding work that should be undertaken by a registered social worker. Registration of the group must not be used to legitimise that drift. It must not become a route to substituting qualified social workers with a cheaper alternative at a time of financial pressure on local government.
SASW therefore asks that the SSSC role definition sets out clearly what a social work assistant may not do, as well as what they may do. The definition should state that social work assistants work under the supervision of a registered social worker and do not hold statutory decision making responsibility.
Registration should also be accompanied by a career pathway. Many social work assistants are potential future social workers. The qualification requirement should articulate with routes into the degree, including the graduate apprenticeship.
Question 4: Registration of all social workers working in Scotland
Mostly agree
SASW agrees in principle. The title of social worker is protected. It follows that anyone practising under that title in Scotland should be accountable to the Scottish regulator, subject to the SSSC Codes of Practice, and subject to Scottish continuous professional learning requirements. The current position is confusing for the public and creates an accountability gap.
We identify three issues that need resolution before implementation.
Dual registration cost
Social workers registered with another UK regulator who take work in Scotland would face two sets of fees. This affects agency and locum staff in particular, and Scotland relies on that workforce in some areas. SASW asks that the Scottish Government and the SSSC consider a reciprocal or reduced fee arrangement, or a short term registration category.
Cross border and remote practice
The consultation does not define "working in Scotland". Clarity is needed on social workers employed elsewhere who undertake occasional work involving people in Scotland, those working across the border in the south of Scotland, and those practising remotely.
Timescale
Registration with the SSSC is not instantaneous. Setting a start date that does not take into account the additional demand for processing will create a period in which people are technically unable to practise. We would recommend that should this go forward that the SSSC issue a statement regarding this lag and the actions they will take to reduce anxiety within the workforce and in those cared for by this group.
We also note that this proposal will place additional demand on the SSSC registration and fitness to practise functions. That demand should be resourced.
Question 5: References to the General Teaching Councils
Strongly agree
SASW agrees. The amendments correct a factual inaccuracy in the Regulation of Care (Social Service Workers) (Scotland) Order 2024. The General Teaching Council for England no longer exists. The General Teaching Council for Wales was renamed the Education Workforce Council in 2015. Legislation should reflect the current position.
We suggest that the opportunity is taken to review the full list of bodies in Article 3 rather than making only these two corrections, so that a further amending instrument is not required in the near future.
Question 6: Further comments
SASW welcomes the direction of travel. Extending registration strengthens public protection and recognises the skill of workers who have been outside regulation for too long. We offer the following general points.
Cost has not been addressed.
The consultation sets out what will be required but is silent on who pays. Registration fees, qualification costs and the staff time involved in achieving qualifications all fall somewhere. In practice they fall on low-paid workers and on providers operating on commissioned rates that do not include registration/qualification fees. SASW asks that the Scottish Government publishes an assessment of the cumulative cost of these proposals and sets out how it will be met.
Qualification supply must be planned.
Adding three new groups to the Register creates demand for SVQ and related provision. That demand should be modelled with colleges and with the Scottish Funding Council before commencement, not after.
Regulation is not a substitute for workforce investment.
Registration raises standards only where workers have supervision, development time and manageable workloads. Across social work and social care, those conditions are not consistently present. SASW asks that these proposals are read alongside the workforce commitments in the Care Reform (Scotland) Act 2025 and the emerging National Social Work Agency programme.
Sequencing.
These changes will land alongside significant structural reform. We ask that commencement dates are set with regard to the wider reform timetable so that employers are not managing multiple implementations at once.