Policy briefing: GOC thematic review of commercial practices
The AOP’s summary – and what it means for optometry
What has been published?
The General Optical Council (GOC) has published Commercial practices and patient safety: a thematic review. The report looks at how commercial practices affect patients’ access to safe eye care, and registrants’ ability to provide it. It covers five areas: sales targets and incentives; booking practices; sight testing times; transparency on pricing and NHS eligibility; and sight tests for children under five.
The review drew on the GOC’s 2026 registrant and public perceptions surveys, commissioned interviews, a survey of more than 1,100 registrants on overbooking and ghost clinics, online customer reviews, a review of 255 optical business websites, and NHS claims data on sight tests for young children.
In the review the GOC found no direct evidence that commercial practices have harmed patients, but described “a paradox of satisfied patients but a profession under strain”. Public satisfaction remains high, while registrants report widespread pressure:
- 47% of optometrists say the time allocated for a sight test is not enough to provide safe care
- 38% have felt pressure to see high numbers of patients in a way that affected safe care, and 23% have been asked to overbook clinics
- 31% feel pressure to meet commercial targets at the expense of patient care, rising to 43% in multiples compared with 19% in independent practices
- 57% of those who joined the register in the last five years say their training did not prepare them well to manage commercial pressures.
The review also found that only around a third of optical business websites show a sight test price, and that the top 10% of providers carry out 40–55% of all sight tests for children under five.
The GOC accepts that GOS fees “do appear to influence how eye care is being delivered”, but argues they do not explain all the pressures it identified. It has ruled out setting minimum sight test times.
Its main commitments are to review its Standards for Optical Businesses from late 2026, review how education prepares students for commercial pressures, strengthen its data on fitness to practise cases involving businesses, and hold a roundtable on children’s eye care. It asks professional bodies, including the AOP, to update their guidance and use their CPD to help registrants manage these pressures. It also asks commissioners to consider the impact of GOS contracts on care and workforce wellbeing.
What do we say?
We welcome this review by the GOC. It highlights what some of our members have told us for years: overbooked clinics, short test times and sales targets are putting pressure on safe care and pushing optometrists out of the profession.
We particularly welcome the GOC’s recognition that responsibility for these risks “cannot rest with individual registrants alone”. Since the GOC introduced the standards for optometrists and dispensing opticians, we have said that it is unreasonable to expect individual registrants to take responsibility for items that should sit with the business owner.
However, the GOC’s response does not yet match its own evidence. Its standards already say that commercial targets must not adversely affect patient care. The problem is not how the standards are worded, but that they cannot be universally enforced. Rewriting or updating them will make little difference unless business registration is mandatory and businesses face real consequences for breaching them. We are concerned that the fitness to practise cases highlighted in the report both ended with individual registrants being sanctioned, but it isn’t apparent if there was any action against the business. This is exactly what our members fear and why they are at times unwilling to come forward with their concerns.
With regards to ghost clinics, our position goes further than the GOC’s. We have been clear since 2020 that ghost clinics should not be standard practice, that extra bookings should never exceed a practice’s historic no-show rate, and that clinicians should not be routinely expected to work through breaks or to work longer hours to see extra patients. The GOC accepts that overbooking may be appropriate if it is “designed and managed” well, but sets no test for what that means.
We agree with the GOC that a fixed minimum test time is not the answer, because patients’ needs vary and setting a fixed time could be counterproductive to good patient care. What matters is that clinicians control their diaries and can give each patient the time they need, but to do this they must be supported by the business.
We support greater price transparency, but new requirements must be proportionate. The large practice groups already publish their prices as do many smaller practices. The sampling undertaken by the GOC needs to be more carefully considered before there is a rush to impose additional burdens on the profession when, as the GOC has said, the low level of NHS fees is part of the problem.
What are we calling for?
We are calling on the Department of Health and Social Care to set a timetable for legislation to regulate all optical businesses and, in the intervening time until that is possible, for the GOC to enforce its business standards and to set the tone for businesses. The GOC should also publish data on cases against businesses or where the impact of business practice was a material factor in the optometrist FTP case; and to protect and support registrants, including locums, who decline bookings beyond safe capacity.
What will we do?
We will update our guidance for members and employers on appointment times, sales targets and speaking up, and develop CPD to help students and early-career members manage commercial pressures. We will take part in the GOC’s review of its business standards and continue to support any member who raises concerns. If you are being asked to work in a way you believe is unsafe, contact us.
Read the GOC’s report: Commercial practices and patient safety: a thematic review
