Bupa requires HCPC registration plus one year of full-time post-qualification experience, or three years part-time at a minimum of two working days a week, indemnity cover, and an enhanced DBS certificate with a barred list check. AXA Health's published criteria for psychologists require HCPC registration and name no DBS requirement at all.
Those are meaningfully different bars, and almost nothing published compares them. Insurer pages rank for these queries, but they cover one insurer each, are hard to read, and actively block automated access, which means even AI assistants struggle to summarise them.
Bupa: the requirements
HCPC full registration as a practitioner psychologist. The protected title matters here; our guide to VAT and statutory registers covers why that registration does more work than most psychologists realise.
Post-qualification experience. One year full-time, or three years part-time working a minimum of two days a week. The part-time route is worth knowing about, because a psychologist building a private practice alongside NHS work often assumes they are excluded when they are not.
Professional indemnity cover.
An enhanced DBS certificate with the relevant barred list check.
The DBS requirement used to be a genuine trap
Worth understanding, because it explains why some psychologists gave up on Bupa recognition in the past.
Until 21 January 2026, self-employed people could only obtain a Basic DBS check. Enhanced checks had to be requested by an organisation on somebody's behalf, and a sole practitioner had no organisation to request one.
So a self-employed psychologist faced a requirement they had no lawful route to satisfy. People worked around it through an agency, a clinic they rented from, or a separate employed role, and some simply could not comply.
That changed. Self-employed practitioners can now obtain Enhanced checks, including with barred list checks where eligible, though only through a DBS Umbrella Body rather than directly. Our guide to DBS checks for self-employed practitioners covers the eligibility rules, which turn partly on whether you receive direct referrals from a regulated healthcare professional.
If Bupa recognition was blocked for you on this basis, the block has lifted.
AXA Health: a different bar
AXA's published individual recognition criteria require HCPC full registration in a recognised specialty.
Two differences from Bupa stand out.
No DBS requirement is named in AXA's published criteria for psychologists.
The five-year post-qualification minimum that appears in AXA's requirements applies specifically to ACP-registered child psychotherapists rather than to practitioner psychologists generally.
AXA also publishes which specialties it is currently accepting applications for, and states that if your specialty is not listed it is not accepting applications in that area. That is worth checking rather than assuming, because it changes.
The rule that affects your income
Bupa's arrangements prohibit recognised practitioners from invoicing members for a shortfall beyond the member's policy excess.
In practice that means the insurer's fee is your fee for those patients. You cannot set a higher rate and collect the difference from the client.
This is the calculation to do before applying rather than after. If Bupa's session rate is close to your private fee, the volume is probably worth it. If your fee is meaningfully higher, every insurer client is a discount you cannot recover, and filling your diary with them is a worse outcome than a partly empty diary at your own rate.
Is panel work worth it?
Depends on the stage you are at.
Early, with capacity to fill, insurer work is a reliable source of referrals that does not depend on your own marketing, and the administrative overhead is worth paying for a full diary.
Established, with a waiting list, it is a discount on work you could sell at full price, plus authorisations and claims to administer.
Most sustainable private practices take a proportion rather than all or nothing. Deciding what proportion, deliberately, is better than accepting whatever arrives.
What about the practical side?
Insurer work adds administration that self-pay work does not: authorisation numbers, sessions authorised against sessions used, excess amounts to collect, and claims to submit.
The failure mode is delivering sessions beyond an authorisation and discovering afterwards that nobody will pay for them. Tracking authorisation, sessions approved and sessions used against the client record, visible before you book the next appointment, is what prevents it. Atlacare holds insurance authorisations on the patient profile for that reason.
A caveat on these figures
Bupa's provider pages block automated access, so the criteria above were confirmed through indexed search results rather than read directly from the source. AXA's provider site was readable.
Confirm both in writing before you apply or make a commercial decision. Insurer requirements change, and a page summarising them ages quickly.
Before you apply
- Check you meet the experience bar, including the part-time route if that is your situation
- Get your DBS underway early, through an Umbrella Body if self-employed
- Confirm the specialty is open for applications
- Ask what the session rate is, in writing, before you commit
- Ask explicitly whether you may bill a shortfall
- Decide what share of your caseload you want insurer-funded
This is general information about insurer recognition, not commercial advice. Criteria and fee schedules change and vary between insurers. Bupa's criteria here were confirmed via indexed sources rather than direct access. Confirm the current position in writing with each insurer.
Sources: AXA Health, individual provider recognition · Bupa, mental health and wellbeing network · GOV.UK, DBS checks for self-employed people
Related: DBS checks for self-employed practitioners · Can I see clients who live abroad? · When police or courts ask for your therapy notes
