The ABP’s Response to the HCPC Proposal to Protect the Title “Business Psychologist”
In the late 2000s, The Association for Business Psychology (then The Association of Business Psychologists) played a decisive role in responding to The Health and Care Professions Council (HCPC) proposal to extend statutory regulation across all areas of psychology, including protecting the title of “Business Psychologist.” This period marked a critical juncture for the profession, as The ABP worked to ensure that regulation was appropriate, proportionate, and in the public interest.
The Context
The Department of Health (DoH) initiated proposals to bring all “practitioner psychologists” under statutory regulation via the HCPC. The primary driver for regulation was the protection of the public, particularly children and vulnerable adults, from potential harm. The HCPC – originally established to regulate health-related professions such as physiotherapists, dietitians, and occupational therapists – was identified as the regulatory body for psychology.
However, the proposals were written broadly enough to encompass occupational and Business Psychology, despite the fact that Business Psychologists operate outside the healthcare sector. Business Psychologists primarily work with organisations, teams, and leaders to improve effectiveness, performance, and employee experience, activities far removed from the clinical or therapeutic contexts at the heart of the HCPC’s remit.
The proposed inclusion of Business Psychologists raised serious concerns about misaligned regulation, unnecessary burden, and unintended consequences for the profession and its clients.
The ABP’s Intent
From the outset, The ABP’s intent was clear:
- To ensure that regulation, if applied, was proportionate and fit for purpose.
- To protect the professional standing and commercial viability of Business Psychologists.
- To prevent inappropriate health-focused regulation that could undermine the profession’s credibility and competitiveness.
The ABP emphasised that Business Psychology is not a health profession. Its closest comparators are human resources and management consultancy, neither of which were proposed for statutory regulation. Subjecting Business Psychologists to HCPC oversight risked creating unnecessary administrative and financial burdens while offering no additional public protection.
The Association also raised concerns about the implications of the British Psychological Society’s (BPS) requirements for Chartered status, which were embedded in the HCPC proposals. The BPS requirement for a first degree in psychology would have excluded many competent ABP members who held relevant postgraduate qualifications and extensive applied experience.
What The ABP Did
The ABP undertook a multi-pronged response strategy, engaging directly with government departments, regulators, the media, and its members.
Formal Consultation Responses
The ABP submitted a formal response to the Department of Health’s consultation on the Health Care and Associated Professions (Miscellaneous Amendments) No. 2 Order 2008. In this submission, The ABP argued:
- Business Psychologists seldom work with children or vulnerable adults and refer such cases to appropriately qualified professionals.
- The risk to the public from Business Psychology practice was not sufficient to justify statutory regulation under the HCPC.
- Imposing health-focused regulation on Business Psychologists, while leaving comparable professions such as HR and management consultancy unregulated, would disadvantage Business Psychologists commercially and could reduce the overall quality of organisational consultancy services.
Direct Engagement with Key Stakeholders
Letters were sent to the Department of Health, the HCPC, and Members of Parliament outlining The ABP’s concerns. These communications emphasised:
- The non-health nature of Business Psychology.
- The risk of regulatory overreach (“mission creep”).
- The need for proportionate approaches aligned with government policy on minimising unnecessary regulation.
Mark O’Sullivan (ABP Treasurer) and Francis Butler (ABP Chair) led much of this work, coordinating communications and ensuring The ABP’s position was clearly articulated.
Collaboration with the BPS and Other Stakeholders
While The ABP had been formed partly due to dissatisfaction with the BPS’s approach to applied Business Psychology, it nonetheless collaborated with the BPS where there was alignment. Both organisations expressed concern over the HCPC’s suitability as a regulator for non-clinical fields of psychology, although the BPS took a broader stance in support of statutory regulation across all psychology disciplines.
Public and Media Engagement
The ABP also took its case to the media. Letters to the Financial Times and other publications outlined how the proposed regulation risked harming small businesses and the UK economy. Media briefings explained the difference between clinical and Business Psychology in accessible terms, highlighting why the HCPC was an inappropriate regulator.
Internal Strategy and Member Guidance
Internally, The ABP prepared members for possible outcomes. Contingency planning included:
- Advising members who met Chartered Psychologist requirements to register with the HCPC if necessary.
- Considering alternative professional titles (e.g., “Organisational Psychologist” or “Work Psychologist”) should “Business Psychologist” become a protected title.
- Positioning The ABP to maintain credibility and competitive advantage regardless of the regulatory outcome.
The Outcome
The ABP’s sustained engagement, combined with similar concerns raised by other groups, led to a change in approach. Ultimately, “Business Psychologist” did not become a protected title under the HCPC, avoiding the imposition of inappropriate health-focused regulation on the profession.
While “Occupational Psychologist” became a protected title under the Health Care and Associated Professions (Miscellaneous Amendments and Practitioner Psychologists) Order 2009, The ABP successfully secured the ability for its members to continue practising under other titles without unnecessary regulatory burden. The ABP maintained that professional standards could be upheld through robust voluntary regulation, professional codes of conduct, and accreditation, without resorting to a misaligned statutory framework.
Legacy and Impact
The ABP’s work during this period demonstrated the Association’s capacity to represent the interests of Business Psychologists effectively at national level. Key impacts included:
- Maintaining professional autonomy: Business Psychologists retained the ability to practise without inappropriate constraints.
- Avoiding disproportionate regulation: The ABP successfully made the case that statutory health-focused regulation was unnecessary and potentially harmful for the profession.
- Strengthening The ABP’s credibility: The campaign positioned The ABP as the authoritative voice for Business Psychology, able to influence government policy and regulatory decisions.
The ABP’s actions also underscored the importance of sustained engagement with regulatory and policy processes. While the specific challenge of HCPC regulation of “Business Psychologist” has receded, the broader issue of professional recognition and appropriate regulation continues to be relevant, particularly as new titles, qualifications, and pathways emerge within the profession.
Conclusion
The ABP’s intervention in the HCPC proposals was a pivotal moment for the profession. By combining strategic advocacy, public engagement, and member support, The Association ensured that Business Psychology was recognised for what it is: a discipline rooted in robust science, focused on organisational effectiveness, and distinct from health professions.
The campaign reflected The ABP’s core mission: to champion the application of psychology in business, support professional excellence, and promote approaches that genuinely make working lives better. The success of this effort reinforced The ABP’s role as the leading voice for Business Psychology in the UK, capable of protecting the profession’s future while upholding the highest standards for its members and the organisations they serve.
Acknowledgements
The ABP would like to thank all who supported this work. We recognise those who lent their expertise and leadership to the campaign, as well as our members, and allies. Particularly:
- Francis Butler, Chair of The ABP 2004-2009, who was the lead signatory on the formal consultation submission to the DoH.
- Mark O’Sullivan, then Treasurer of The ABP, who coordinated much of the correspondence, media engagement, and strategic planning.
- The ABP Management Board who discussed and agreed strategic positions, prepared contingency plans, and oversaw communications to members.
- The BPS, who lent their support and collaboration to provide additional weight to arguments about the unsuitability of the HCPC for regulating non-health psychology disciplines.
- Our members, many of whom contributed case examples and expert commentary, strengthening The ABP’s credibility in discussions with policymakers.