The Locum GP Pension Guide

Why this is harder than it should be

As a freelance GP locum you are, in NHS Pension Scheme terms, a Locum Practitioner. That status carries a peculiar burden: you are simultaneously the employee and the person responsible for collecting and remitting the employer's contribution. No payroll department does this for you. Miss a deadline and the pension for that work is gone permanently — not delayed, gone.

When you start as a locum GP, not only are you suddenly in charge of your own business, you also become responsible for your own pension compliance.

Who counts as a freelance GP locum

The regulations are narrower than most people assume. Locum work is defined in NHS Pension Scheme Regulations as 'to deputise or temporarily assist'.

You can pension via Forms A and B if:

• You are self-employed, deputising for an absent GP or working on a temporary basis in a surgery
• You are doing appraisal work

You cannot:

• If you work through a limited company. This is absolute and catches a lot of people who incorporated for tax reasons without realising the pension consequence.
• If you are a hospital-based or salaried GP locum — you are classed as an officer member instead.
• If the work is through an agency (as opposed to a chambers). Where a GP locum chambers is involved, the locum may still pension their income — chambers and agencies are treated differently, so check the specific arrangement rather than the label.

Irregular vs long-term: the test that actually matters

This is the trap that catches long-running arrangements — but the official test is not what most commentary claims.

NHSBSA's GP Member Pension Guide draws the line at irregular vs long-term, not at any fixed number of months. If the contract for services — the scheme's term for engaging you as a self-employed sole trader rather than employing you — is irregular, you can continue to pension the income as a GP locum using Forms A and B. If a GP is engaged under a long-term contract for services, they should be regarded as a Type 2 medical practitioner.

You will see a "six month rule" widely quoted, including in PCSE's own FAQ responses. That figure does not appear in the GP Member Pension Guide or on the Locum A form, and it is best treated as an administrative rule of thumb rather than a regulatory threshold. The regulatory language is "deputise or temporarily assist" and "irregular".

If you are no longer doing irregular work and become engaged on a long-term contract for services, the practice should complete a revised estimate of pensionable income form and pay employer and employee contributions directly to PCSE as though you were a salaried GP. You then stop filing Forms A and B — but you must complete the Type 2 self-assessment form at year end.

If you've been at the same surgery every Tuesday for a year, you are almost certainly not locuming for pension purposes. Sort this out prospectively; retrospective reclassification is unpleasant.

You cannot locum in your own surgery

If you are a GP provider, you cannot pension income as a freelance GP locum in your own surgery. This is stated explicitly on the Locum A form.

Out of hours and ICB work is not locum work

Out of hours work must not be recorded on Forms A or B, and the consequence is bigger than a form-choice error.

If you are a GP locum who also performs OOH work for an OOH provider on a self-employed basis, or works for an ICB on a self-employed basis, you are a Type 2 medical practitioner in that role. Your pension record will show both a locum practitioner post and a Type 2 post — and that means you must file a Type 2 self-assessment form at year end. See the Type 2 guide.

For a GP who is solely a locum, NHSBSA's rules table is specific and restrictive:

• OOH (self-employed): can only be pensioned as a Type 2.
• ICB (self-employed): can only pension ICB income for board or advisory work, on the GP SOLO form.
• Other ad hoc work: cannot be pensioned at all, except appraisals.

That last line surprises people. A GP whose only NHS work is locuming cannot pension miscellaneous ad hoc work — GPwSI sessions, section 12 work and similar — the way a salaried GP or partner can. Appraisal work is the exception.

If a GP locum is formally employed by an ICB under a contract of service, the ICB must create an officer pensionable post and pay contributions directly to NHSBSA.

The 90% rule and the money flow

GP locum pensionable income is 90% of your fee, excluding the employer contribution element. The remaining 10% is a fixed allowance for expenses, deemed non-pensionable.

The mechanics run as follows:

1. You invoice the practice for your session fee.
2. You multiply the fee by 90% — that is your pensionable pay.
3. You multiply the pensionable pay by 14.38% — that is the employer contribution, which the practice owes on top of your fee.
4. That amount is added to your session fees to calculate the total invoice value.
5. You then pay both the employer contribution you collected and your own tiered employee contribution to PCSE.

Your invoice should show a breakdown of session fees, pensionable value, employer contributions and the total amount invoiced. Invoices must clearly show the rate and amount of the employer's contribution as a separate charge.

Worked example

A £500 session:

• Pensionable pay: £500 × 90% = £450
• Employer contribution: £450 × 14.38% = £64.71
• Total invoiced to practice: £564.71
• Your employee contribution (say tier 12.5%): £450 × 12.5% = £56.25
• You remit to PCSE: £64.71 + £56.25 = £120.96

The 14.38% includes an administration levy of 0.08%. The overall employer rate is 23.78%, with HM Treasury making up the additional 9.4% — so the practice genuinely only pays 14.38%, and you shouldn't be arguing for more.

Declare your intention upfront

You must inform your employer from the outset if you intend to pension your locum income. There is no liability on a surgery to pay over employer contributions if you are not pensioning the work. If you said you would pension it and then don't, you must return the employer contribution element to the surgery — or, for appraisal work, to NHS England or the LHB.

You can pick and choose engagements — but not days within one

Unlike other scheme members, a GP locum can decide whether to pension each individual period of work, and does not need to opt out of the scheme to decline.

But the choice is all-or-nothing within an engagement. If you elect to pension a period of locum work, you must pension all of it. Working a practice Monday, Tuesday and Wednesday, you cannot pension only Monday and Tuesday.

Nor can you vary the 90%: you cannot pension any more or less than 90% of the fee.

You must be on the performers list

To qualify as a GP locum in NHS Pension Scheme terms you must be a GP performer. A GP performing appraisal work who is not on a performers list does not qualify and cannot pension that income.

The 10-week rule

This is the single most consequential deadline in locum pensions.

NHS Pensions Regulations state you cannot pension a period of freelance GP locum work that ended more than 10 weeks ago. Any forms received after 10 weeks cannot be pensionable and will be rejected.

This applies regardless of when the fee for the work is paid to you. That deserves repeating: the clock runs from the date you worked, not the date you were paid. A practice that takes twelve weeks to settle your invoice has not extended your deadline.

The rule was temporarily suspended during the COVID-19 pandemic from 1 April 2022 but reinstated from 1 October 2022. It is fully in force now.

The window is effectively shorter than 10 weeks. Because Form A has to travel with the monthly Form B, the practical deadline is tighter than the regulation suggests. NHSBSA's own example: a locum ends an engagement on 5 April. The 10 weeks run to 14 June — but the locum must submit Form A alongside the May Form B in late May or early June. Submitting it with the June Form B at the end of June would breach the window.

So the real question isn't "has it been 10 weeks?" but "which monthly Form B does this work belong to, and has that gone yet?"

If you try to submit forms that don't comply with the 10-week rule on PCSE Online, you'll see an error message explaining the income cannot be pensioned.

The audit trail point: If you complete and submit your Locum A and B forms in PCSE Online, there's an audit trail showing when you submitted your Form A for practice approval, and no further evidence is required. If you take the manual route described below, you'll need your own evidence that the Form A was submitted for practice approval inside the 10-week window.

What matters is that the evidence exists, not which route produced it. The Form A requires practice sign-off, and if the practice sits on it, you need to be able to prove you submitted in time. PCSE Online does that for you; submitting by hand does it just as well provided you send the Form A by dated email and keep the sent message. Choose your route on other grounds — but whichever you choose, make sure something outside your own memory records the date it went.

Forms A and B

Form A is the record of work done, signed off by the practice. Only surgery work performed under a contract for services (that is, as a self-employed sole trader rather than an employee), where the locum is deputising for an absent GP or working on a temporary basis, may be recorded on this form.

Form B is the monthly summary and payment calculation. You can calculate the amount of pension contributions due on the GP locum Form B.

It is important to check and confirm the actual dates worked — if there are breaks of any length between your actual periods of work, you must enter each period separately, using Annex A if there are not enough boxes. This matters enormously for annualisation, below.

The two ways to submit

In England there are two routes, and both are perfectly valid. The forms themselves are the same; what differs is who fills them in, where the practice's validation happens, and how much of the audit trail you get without thinking about it.

Fully electronic, through PCSE Online. You complete the Form A in PCSE Online, which calculates the contributions from the income and tier you enter. The practice you did the work for — or NHS England, for appraisal work — is notified that a form is awaiting approval, and signs it off electronically inside their own PCSE Online account. Practices are required to approve Locum A forms submitted this way, but the ability to do so has to be assigned to the relevant staff by the practice's User Administrator for GP Payments and Pensions, which is a common reason for forms sitting unapproved. Only once the Form A is approved can you submit the Form B; PCSE Online then displays the UPR you must quote on your payment.

Fill the forms in yourself and submit them by hand. You complete Part 1 of Form A and send it to the surgery with your invoice; they validate Part 2, which is where the 90%, the 14.38% and the employer contribution are confirmed. You complete your own Form B and submit the forms through PCSE's GP pensions enquiries form, paying by BACS.

Both forms word this route as what to do "if you are unable to use PCSE Online". That is an administrative preference, not a regulatory restriction — the forms remain valid and the contributions land on your record either way — but it does mean the manual route is the one you have to run properly yourself, and it is worth being deliberate about choosing it.

The case for doing it by hand is stronger than the official framing suggests:

• PCSE Online does not save you from the hard part. It calculates from the income and tier you enter. Annualisation is still your judgement call, and a wrong tier submitted online is just as wrong — it simply looks more authoritative on the way in.
• You end up holding the evidence. A validated Form A in your own files is a document you control. The online audit trail is a record in a system you can lose access to, and one you cannot produce yourself if a query arrives years later.
• The approval dependency cuts the other way. The online route cannot progress until someone at the practice with the right PCSE permission actions it. On the manual route the sign-off travels with your invoice, to someone at the practice who is already handling it.

The real cost is the audit trail, and it is fixable rather than fatal: send the Form A to the practice by email, dated, and keep the sent message. That is the evidence NHSBSA asks for, and it takes no extra effort if you make it the habit.

Wales has no online route. You complete Part 1 of Form A and send it with your invoice to the surgery, and send Form B plus all contributions to your LHB.

If you work through a chambers, the chambers administrator can upload your forms to PCSE Online on your behalf. Where the chambers cannot use PCSE Online, they may submit from their own email account, with or without your signature on the Form A. Either way the forms must still be validated by the commissioning surgery.

Neither route changes the 10-week rule or the payment deadline below. If you take the manual route, the Form A and Form B filler fills the real NHSBSA forms for you to get validated and submit, and warns you before the window closes.

Payment deadline

As a freelance GP locum, you must pay both your employee and employer contributions to PCSE (or the LHB in Wales) no later than the seventh day of the following month.

Your UPR

You'll be asked to include your Unique Payment Reference, which must match the UPR on the payment sent to PCSE. It's made up of your 8-digit NHS Pension Scheme membership number plus the 3-character form identifier 'LOC'. If the Form B does not include the UPR, your pension record may not be credited with this work.

Send your forms to one location only.

Appraisal work

NHS Pensions considers appraisal work to take between one and three days, and this time should be recorded as time worked. Additional days such as mandatory training beyond the maximum three days cannot be pensioned separately because they are included within the fixed appraisal fee. An appraisal fee can only be pensioned once, over a maximum of 3 days of pensionable service.

In exceptional cases your employer may authorise additional days before the work is carried out, in which case the fee is divided across all authorised days.

How you record it depends on whether the days run together:

• Three consecutive days — record one continuous 3-day period on Form A, with the entire fee against that period on Form B.
• Three non-consecutive days — record three separate entries on Form A, and divide the fee equally across the three days on Form B (one third each).

Those days count toward your pensionable service — which, as the next section explains, is worth having.

Recording sessions across a month boundary

If a single engagement spans two calendar months with no breaks, record and invoice each month separately. Work running 29 June to 1 July is recorded as 29–30 June on the June form and 1 July on the July form. This ensures the correct contribution rate applies either side of any rate change, and that annualisation picks up the right scheme year.

You do not need a separate Form A for each day within the same month provided they're covered by one invoice. But if you invoice the same surgery separately for individual blocks, each invoice needs its own Form A.

Annualisation: the biggest trap

This is where locums lose money without realising it.

Your tiered employee contribution rate is based on all your GP pensionable income, not just your freelance locum income — and you must annualise your GP income to set the relevant tiered rate. All breaks, regardless of their length, count.

The formula: total GP pensionable income ÷ pensionable days of service × 365

NHSBSA's example: Dr B performs irregular pensionable freelance locum work across the year, totalling £30,000 over 60 pensionable days. Her annualised pay is £182,500, giving a tiered rate of 12.5%. She pays £3,750 on her £30,000 of actual income.

She is paying the top tier on an income that would put a salaried GP in a much lower band. That is not a mistake — it is how the rules work.

For 2026/27 the tiers run from 5.2% on earnings up to £13,259 to 12.5% on earnings of £67,669 and above. A locum working part of the year will frequently annualise into that top band.

How pensionable days are counted

The GP Member Pension Guide sets out rules that materially affect the denominator:

• Pensionable service is counted in actual working days, not sessions. If you work one session in a day, that is one day. If you work two sessions in the same day — even at different practices — that is still one day.
• Concurrent service is counted only once. If you hold a salaried post and also locum during the same period, overlapping days don't double-count.
• Consecutive days contracted together (say Monday to Wednesday) are recorded as one continuous period on Form A.
• Non-consecutive days (Monday, Wednesday, Friday) are recorded individually.

NHSBSA's worked example: a locum works 120 days across several practices in 2025/26 earning £60,000. Annualised income is £182,500, giving a 12.5% rate — £7,500 in employee contributions.

A second example shows appraisal days pulling the denominator up: 90 days of practice work earning £45,000 plus appraisal work on 10 separate non-concurrent days earning £4,635 gives 100 pensionable days, £49,635 total, and an annualised £181,167.75.

The two-sessions-in-a-day rule is the one that hurts. A locum doing full days rather than single sessions accrues pensionable days at the same rate but earns more per day — which raises annualised income without adding to the denominator. Working sessions spread across more separate days produces a lower annualised figure than the same income concentrated into fewer full days.

If you hold multiple GP roles

If you're a freelance GP locum or a GP performing additional locum work, you must account for all your aggregated GP pensionable income when setting the tiered employee contribution rate. The same rate must be applied to all your GP pensionable income.

NHSBSA's example: Dr E is a GP provider with £70,000 of practice profit plus £30,000 of locum income across 304 pensionable days. Annualised income is £120,065, giving a 12.5% rate applied to the full £100,000 — £12,500.

Do exclusive locums file a Type 2 form?

Only if you are genuinely exclusively a locum — and that's narrower than it sounds.

You do not file a Type 2 form if your only NHS work is freelance locum surgery work and appraisals pensioned through Forms A and B. You still carry the obligation to have paid the right tier, without the form as a mechanism to check it. If your Form B submissions used an estimated tier that turned out wrong once the year closed, you must identify and correct that yourself.

You do file a Type 2 form if any of the following applied during the year:

• You held a salaried GP post, even briefly
• You did self-employed OOH work — this makes you a Type 2 in that role
• You did self-employed ICB work
• You moved onto a long-term contract for services partway through the year
• You were a partner at any point (Type 1 certificate as well)

Given how many locums pick up OOH sessions, the genuinely exempt group is smaller than the label "exclusive locum" implies. If in doubt, file.

Record keeping

Always keep a copy of locum pension forms, because locum fees are an expense for the surgery.

Keep, at minimum: every Form A with practice sign-off (or the PCSE Online audit trail), every Form B, proof of payment to PCSE, and your invoices. There are various locum software packages available at minimal cost which can generate appropriate invoices and auto-populate the pension forms.

Reconcile at least annually against your Employee Contribution Statement on PCSE Online — that shows what PCSE actually received, which is the only figure that ends up on your record.

Practical takeaways

1. Ten weeks from the date you worked — and in practice shorter, because Form A rides with the monthly Form B.
2. Keep dated proof of when each Form A went for approval. PCSE Online records it for you; if you submit by hand, a dated email to the practice does the same job. It's the difference between a resolvable dispute and a lost pension year.
3. Limited company = no NHS pension. Chambers are fine; you must locum as a person, not a company.
4. Irregular vs long-term is the test, not any fixed number of months. Move to the salaried route prospectively.
5. Two sessions in one day is one pensionable day. Concurrent service counts once. This drives your annualised tier.
6. Declare your intention to pension upfront, and return the employer contribution if you don't follow through.
7. Self-employed OOH or ICB work makes you a Type 2 in that role — different form, and a Type 2 return at year end.
8. A solely-locum GP cannot pension general ad hoc work — only appraisals, plus ICB board/advisory work via SOLO.
9. All-or-nothing per engagement, and always exactly 90% of the fee.
10. You cannot locum in your own surgery if you're a provider there.

Sources

Verified against the NHSBSA GP Member Pension Guide V5 (23 April 2026) and the NHSBSA GP Locum Form A and Form B 2026/27 V1 (26 February 2026). The two submission routes above are taken from the instructions printed on those two forms and from PCSE's own guidance.

Worth checking each year, as forms and figures are reissued:

• GP locum Form A and Form B for the current year — NHSBSA, for the England and Wales submission instructions and the chambers rules
• Submit Locum A & B forms and Approve Locum A forms — PCSE, for the online workflow and the practice-side approval permission
• GP pensions enquiries — PCSE, the manual submission route
• NHSBSA annualising calculator and GP Tiered Contributions Guide

Note: the BMA quotes the employer contribution as 14.3%; the NHSBSA Locum A form gives 14.38% inclusive of the 0.08% administration levy. Use the NHSBSA figure for form completion.

Note: the widely-quoted "six month rule" for when locum work becomes salaried does not appear in the GP Member Pension Guide or on Form A. The official test is irregular vs long-term engagement.

A note on advice

This article is general information, not personal financial advice. Consider a specialist medical accountant before acting.