Commission for the Future of Counselling & Psychotherapy
In October 2025 the Partnership of Counselling and Psychotherapy Bodies (PCPB) established an independently chaired Commission for the Future of Counselling and Psychotherapy. The commission is examining the future landscape of the professions and the key issues affecting the sector, professionals, services and clients.
Submission by Dr Elizabeth Cotton info@survivingwork.org Submitted 26.3.26
Section 1: State of the Sector
The issue I would like to raise within this consultation exercise is the impact and regulation of digital mental health providers, including online therapy platforms and the use of private practice management platforms. Changes in the psychotherapy sector need to be reflected in the work of the professional bodies and the PCPB in order to have a role in the oversight of the ethics of practice within this fast emerging sector (Cotton, 2025).
The growth of private medical insurance companies in the UK, online therapy platforms and use of AI technologies mean that the sector will experience a growth in insecure ‘platform’ work (Garofalo, 2024), risks of automation of therapeutic services, and performance management across the sector introduced through the uptake of practice management companies, often owned by private medical insurance companies (PsiAN, 2025).
What we will also see is a rise in legal cases being taken against digital therapy providers – including consumer actions (via Advertising Standards Agencies), professional standards and accreditation of digital therapy platforms, notably in the UK in relation to Employee Assistance Programmes (EAPs) (BBC File on 4, 2024), and in the future through trade unions on behalf of platform workers around algorithmic harms (Worker Info Exchange, 2021), data transparency and algorithmic transparency in relation to both patients and therapists (Palantir, Medact, 2025)
The recent complaint made against Health Assured to the BACP by the BBC is an important indication of the implications of digitalization and the range of actors involved in attempts to regulate psychotherapy. The submission came from a BBC Radio 4 File on 4 programme looking at the EAP sector in the UK, principally HealthAssured. It raised serious and systemic issues around the quality of therapy provided audited by BACP and NCPS who accredited its services, and the EAPA has ruled it is in breach of its Ethical Code of Practice. The PCPB and its members will need to develop a clear and informed set of principles and practices to defend the profession in these future challenges.
Evidence
BBC File on 4 (2024) Investigating EAPs [ Available at https://www.bbc.co.uk/programmes/m001x4lk]
Cotton E (2025) UberTherapy: The new business of mental health. BUP.
EAPA (2026) BBC File on 4 Allegations – Outcome [Available at https://www.eapa.org.uk/bbc-file-on-4-allegations-outcome/]
Garofalo L (2024) Doing the Work: Therapeutic Labour, Teletherapy and the platformization of mental health. Data & Society.
Medact (2026) Briefing: Concerns regarding Palantir Technologies in NHS Data Systems.
PsiAN (2025) Practice Management Companies [Available at https://www.psian.org/practice-management-companies#compreport]
Worker Info Exchange (2021) Managed by Bots: Data driven exploitation in the gig economy. WIE.
Section 2: Regulation of the professions
This section relates to the joint submission by Counsellors Together UK (CTUK) and Surviving Work to the PSA’s Accredited Register Consultation in 2024. The data we use in this submission was carried out by Dr Cotton in collaboration with the CTUK in 2020/21 (1500 respondents) and 2023 (750 respondents) looking at the financial and professional landscape for counsellors and psychotherapists and the implications of SCoPEd. Our findings and submission argue that SCoPEd will lead to a deepening of pre-existing inequalities in the therapy sector:
65% earn less than £600 per week (gross income) which is the median earning for employed people in the UK
59% of respondents earn their main income in counselling and psychotherapy
23% increasing work outside of therapy to cover costs
Significant reduction in earnings of £0-99 per week to 17% in 2023 down from 30% in 2020/21
16% (14% in 2020/21) of respondents receive income based welfare benefits with 4% accessing food banks while training and 3% while working as counsellors/psychotherapists, the same figures for 2020/21
Only 3% of 2023 survey respondents felt that SCoPEd offered them higher opportunities for paid work and 1% felt it would lead to income increase, rising to 13% responding they anticipated a fall in income. As a result of these financial realities, a high level of 33% (30% in 2020/21) of respondents cannot see a future earning a living as a counsellor or psychotherapist.
2. Deepening inequalities in the sector
Within the psychotherapy and counselling profession there is a two tier system which is based on pre-existing inequalities in terms of class, race, gender and disability. The SCoPEd framework will entrench those inequalities already inherent in the profession by formalizing a system of unwaged work (450 unwaged clinical hours) tied to professional accreditation and associated costs of accredited trainings required to progress from category A to C and the raised cost of monthly professional membership fees.
For those respondents who had a view on SCoPEd 10% felt they would fail to get accredited under this new system and 19% felt it would lead to lower diversity within the profession, down from 40% in the 2020/21 survey. Only 1% felt SCoPEd would lead to higher diversity.
3. Further de-professionalisation of therapy
SCoPEd’s definition of Category C therapists misunderstands the nature of therapy and the diversity of practice within the profession. It subsequently leaves Category A and B in a regulatory grey zone about their work with unconscious material and therefore professionally unprotected. Given the rapid rise in associate and non-clinical roles within the NHS Talking Therapies and more widely within the privatized and digitalized therapy sector this fundamentally stands to undermine professional standards further rather than protect them.
4. Failure to address the future of therapeutic professions
The counselling and psychotherapy employment landscape will continue to be shaped heavily by the emergence of digital services, including within the NHS as well as the rapid growth of online therapy platforms and employment assistance programmes. We can anticipate the emergence of large and new digital providers and online therapy platforms as key providers in the UK. This platformisation of work raises with it issues of work intensification, standardization, patient confidentiality, data protection and workplace surveillance which will need to be managed both at individual and professional levels. None of this is addressed in the SCoPEd proposal.
Evidence
CTUK/Surviving Work Submission to the PSA [Available at https://www.survivingwork.org/surviving-work-blog/psascoped?rq=CTUK]
Section 3 Evidence and Research
The PCPB has a responsibility and an opportunity to engage with the growing body of research into the uberization of the therapeutic profession. This research involves engaging with diverse and interdisciplinary research to understand the scale and impact of digitalization, including notably the US researchers and campaigners who have been campaigning and working to regulate this unregulated sector. I urge you to follow the work of the Psychotherapy Action Network (PsiAN) in the US who carries out much of this research and advocacy in the US, and whose edited book outlines the issues that we in the UK will be facing as private medical insurance and platformization develops (Michaels et al, 2024). PsiAN, along with CTUK under Maria Albertsen prior to her death in 2024, works in partnership with The Digital Therapy Project which tracks the development of digital therapy in the UK and US.
Of particular importance in strategic research for PCPB will be genuine engagement with researchers and social justice campaigners in documenting algorithmic harms to both therapists and consumers of digital therapy. This will task PCPB and its members to listen to new and existing constituencies with a stake in the future of therapy, with a constructive rather than a defensive approach to new and often complex systemic, political and economic information. The invitation is not to directly carry out new research, rather to engage with the very many actors already carrying out socially engaged research into platformization and mental health that are emerging in the current AI debates.
Ultimately the regulation of the therapy sector means setting a clear intention to base future research and engagement on action around the pre-existing and deepening social inequalities and action directed at social justice.
Evidence
Cotton E (2025) UberTherapy: The new business of mental health. BUP.
Garofalo L (2024) Doing the Work: Therapeutic Labour, Teletherapy and the platformization of mental health. Data & Society.
Michaels LM, Wooldridge T, Burke and Muhr (eds) (2024) Advancing Psychotherapy for the Next Generation: Humanizing Mental Health Policy and Practice. Routledge.
PsiAN (2025) Practice Management Companies [Available at https://www.psian.org/practice-management-companies#compreport]
Slaney C (2026) (Ed) Counselling & Class. PCCS.
The Digital Therapy Project, www.thedigitaltherapyproject.org
Section 4 Future of the Professions
The priority must be to take a position on the uberization, digitalization and platformization of therapeutic labour that is informed by stakeholders and the extensive research behind current attempts to regulate platform work.
There is very little political will on the part of the UK Government to regulate digital providers in the NHS or more broadly to support the regulation of the platform economy.
There is also no evidence that the government has engaged with the extensive research that documents the harms of austerity (Pring, 2025) and ‘welfare reform’ and associated focus of NHS Talking Therapies to offer an entry into work for benefit claimants. Engagement with policy makers remains important but the lack of action to address inequalities and the harms of austerity policies within the mental health sector does not indicate any intention to review policy.
If there is a policy issue that PCPB should attend to it relates to the standardisation of psychotherapy within the NHS and associated performance management and data collection. The 'evidence base' for short term CBT is subject to increasingly open criticism for its attempts to misrepresent the effectiveness of NHS Talking Therapies, despite concerns being raised for over a decade (Rizq, 2014; Scott, 2018). This is an important threat to the legitimacy of the therapy profession, and increasingly a key part of the defence of the profession in future debates about uberization to challenge the performance cultures that exist.
In my research of IAPT/NHS workers about performance management their proposals for change focussed on the following policy lines of action:
Invest in staff: higher wages, progression and skills development
Review target culture
Carry out a full review of NHS Talking Therapy services
Greater funding of NHS Mental health services
Extend therapeutic modalities beyond CBT
Reduce caseloads
Fund the gaps in services (eg between primary and secondary care)
Review performance data collection
Refocus NHS Talking Therapies to mild-to-moderate clients
Re-integrate NHS Talking Therapies into the NHS/stop contractors
Stop payment by results
This might be a good basis for future lobbying and policy debates with the UK Government.
Evidence
Pring J (2024) The Department: How a Violent Government Bureaucracy Killed Hundreds and Hid the Evidence. Pluto Press.
Rizq R (2014) Perversion, neoliberalism and therapy: the audit culture in mental health services. Psychoanalysis, Culture & Society 19: 209– 218.
Scott MJ (2018) Improving Access to Psychological Therapies (IAPT): the need for radical reform. Journal of Health Psychology 23(9): 1136– 1147.
@survivingwork.bsky.social @survivingwk
@UberTherapy.bsky.social @ubertherapies