Would regulating counselling and psychotherapy make a difference?

I’ve argued on this blog in favour of making counsellors and psychotherapists protected titles in the same way as nurses, social workers, occupational therapists etc. A previous survey suggested that at least one in four counsellors or psychotherapists who were struck off by the BACP or UKCP for misconduct simply carried on practising. And that’s perfectly legal to do, because neither “counsellor” nor “psychotherapist” are protected titles.

In response, some have argued that there’s no point in having protected titles. Suppose you have a practitioner who’s been struck off and doesn’t want to stop practising, or doesn’t want to submit themselves to a statutory regulator, or simply never acquired any qualifications in the first place. If protected titles were brought in, all they would have to do is change their job title. Say, to “humanistic therapist” or “Jungian analyst”. I decided to test this hypothesis.

I put together a list of job titles along those lines. For comparison purposes, I also added the title “clinical psychologist”, which already is a protected title. The list was as follows.



Life coach


Humanistic therapist

Jungian or Freudian analyst

Clinical psychologist

Cognitive-behavioural therapist

I then created a short survey on Surveymonkey, with three questions asking what people would do when trying to access psychological therapies for mental health problems (yes, I know mental health isn’t the only reason people might see a counsellor or psychotherapist, but those that do are more likely to be vulnerable, and therefore more likely to be in need of protection from unscrupulous or incompetent practitioners).

The three questions I asked were:

  1. Which of those titles they had accessed therapy from in the past
  2. Which titles they would look for when trying to access therapy
  3. Which titles they would accept therapy from if offered

I then passed around a link to the survey on Twitter, and also on a couple of mental health Facebook pages. I got 151 responses.

Here’s a PDF file of the results, which I’ll summarise more briefly here.

Q1 From which of the following professionals have you previously accessed psychological therapies for a mental health problem (tick all that apply)?

Counsellor 55.70%
Psychotherapist 32.89%
Clinical psychologist 26.17%
Cognitive-behavioural therapist 24.83%
Psychoanalyst 5.37%
Jungian or Freudian analyst 4.03%
Life coach 2.68%
Humanistic therapist 1.34%

I have never accessed psychological therapies for a mental health problem 22.15%

Q2 If you were looking for a professional to provide psychological therapies for a mental health problem, which of the following job titles would you be likely to look for?

Answered “very likely” or “quite likely”
Clinical psychologist 66.19%
Psychotherapist 64.93%
Counsellor 60.43%
Cognitive-behavioural therapist 50%
Psychoanalyst 24.41%
Humanistic therapist 21.26%
Jungian or Freudian analyst 9.6%
Life coach 7.09%

Q3 If you were offered psychological therapies from the following professionals for a mental health problem, how likely would you be to accept?

Answered “very likely” or “quite likely”
Clinical psychologist 73.57%
Psychotherapist 72.42%
Counsellor 64.79%
Cognitive-behavioural therapist 55.48%
Psychoanalyst 33.82%
Humanistic therapist 27.95%
Jungian or Freudian analyst 11.77%
Life coach 11.6%

What this results suggest to me is that if regulation were brought in, and the baddies of the therapy world simply responded by changing their job titles…yes, they could do it, but they’d be at a significant commercial disadvantage. Suppose there’s a psychotherapist from the Jungian modality who decides, “Stuff that, I’m not going to be regulated. I’ll just call myself a Jungian analyst.” According to these results, he could potentially be looking at a loss of six-sevenths of his customers. People who were Googling around for a psychotherapist wouldn’t be looking for him, and if he was touting for trade he’d have people telling him, “No thanks, I don’t want a Jungian analyst. I want a psychotherapist.” That could well be enough of a loss of business to make him either suck it up and accept regulation, or go looking for a new career in the burger-flipping industry.

An additional observation is that as for the suggestion that regulation would be disastrous for the counselling and psychotherapy professions – well, it certainly doesn’t seem to be harming clinical psychologists, at least in terms of  public confidence. They may have been only the third most-popular in terms of who people had previously seen, but they were the profession that people were most likely to look for and to accept help from.

Another observation is that people were more likely to look for and accept help from a psychotherapist than a counsellor, even though the BACP takes the view that there isn’t really any meaningful difference between the two professions. It does show that job titles do matter in terms of how professionals are perceived.

Looking at the results, it seems that if “counsellor” and “psychotherapist” were to become protected titles, then there would be other titles that would need to be protected along side them. “Cognitive-behavioural therapist” seems like an obvious example, though this would bring in an added complication in that a lot of CBT is done by doctors, nurses, social workers etc. Realistically, if this were made a protected title, there would probably need to be some sort of exemption in the legislation, along the lines of, “You can still practice CBT if you’re  registered with the Nursing and Midwifery Council, General Medical Council, Health and Care Professions Council etc.”

“Psychoanalyst” also strikes me as one that perhaps ought to be added to any list of protected titles. I can think of other examples; say, “family therapist”. That said, it doesn’t necessarily need to be an endless list. Once you get down to some of the more obscure-sounding titles, then it’s likely to have a serious impact on a practitioner’s viability as a business.

So, would bringing in protected titles eliminate the risk of rogue practitioners carrying on in business? No, it wouldn’t. But would it reduce the risk? Yes, it would.


7 thoughts on “Would regulating counselling and psychotherapy make a difference?

  1. My own experience of being raped was when I saw a “Consultant Psychotherapist”. It turned out that he had no qualifications and was a salesman.
    I tried to complain to Trading Standards and was told that he could call himself a Consultant because people “consulted” him, and that because psychotherapist wasn’t a protected title, he could call himself that as well!
    So I agree that they should be protected!

  2. Why did you miss “nurse therpist” off the list, Phil?

    • Pretty much for the same reasons I didn’t include family therapist, occupational therapist or dolphin therapist – because it’s a sample, not a comprehensive list.

      The purpose wasn’t to give every possibility, but to see how a few different titles compare in their responses from the general public.

  3. Good post, although on the CBT issue, I think this would be a great opportunity for stopping untrained people offering CBT, rather than offering an exemption.

  4. If I understand you correctly then you are arguing that regulation based on protecting the titles “Counsellor” and “Psychoanalyst” would be more effective than the current regulatory framework (based on Accredited Registers) because your survey shows that it is not financially viable to practice counselling or psychotherapy without using the title “Counsellor” or “Psychotherapist”.

    There are two clear counter-examples to your conclusion, the first is that there are already therapists making a living even though they don’t use either titles; the fact that there were credible alternative titles for you to use in your survey indicates that working under those titles doesn’t stop people from practicing. To use your example, if practicing as a “Jungian Analyst” was unprofitable enough to stop unregulated psychotherapists switching to it then it would also be unprofitable enough to stop any current therapists practicing under that title, but there are Jungian Analysts out there.

    The second counter example is that your conclusion is at odds with the experience of chiropodists and physiotherapists. When the Health and Care Professionals Council (HCPC) was set up in 2003 “Chiropodist” (along with “Podiatrist”) and “Physiotherapist” were made Protected Titles. In 2007 the HCPC commissioned market research which found that the public were unaware of the difference between someone operating under unprotected titles like “Foot Health Practitioner” and “Sports Injury Therapist” and someone using the Protected Titles “Chiropodists” and “Physiotherapist”; some practitioners even complained that the titles used by unregistered individuals were more attractive to potential clients than the protected ones.


    I think you are overestimating the role of professional titles as marketing tools, there are plenty of marketing strategies that don’t depend on potential clients searching for someone with a particular title: such leafleting, display ads, word of mouth and search engines such as Google (if you Google “counsellor” it will pick up synonyms, phrases like “alternative to counselling” and “I studied as a counsellor”, none of which imply any particular title). Unless the potential client happens to know the significance of the alternative title being used then it will not factor in their decisions, the client will look at the unregulated “Jungian Analyst’s” leaflet and think, “Oh, so this person is offering a type of psychotherapy”; protected titles would stop unregulated practitioners from call themselves “Counsellor”, but they would be powerless to stop clients thinking of them as counsellors or using that term to describe them to others.

    On their own protected titles are just kite marks with delusions of grandeur (the same is true of Accredited Registers, they’re not quite as deluded but they are still just kite marks). Some professions with protected titles are effectively regulated (such as social working and occupational therapy) but others are not (such as chiropody and physiotherapy), and when you look at the ones that are effectively regulated you will see that the there is also another mechanism, such as licencing or the qualifications required by employers, that gives the regulations real teeth; the protected titles themselves are purely ornamental.

    That’s not to say that protected titles couldn’t be made to work, if “Counsellor” and “Psychotherapist” were protected AND that was followed up by a massive publicity campaign so that everyone knows what titles to look for then being unregulated would have a significant financial impact that couldn’t easily be overcome with a clever marketing strategy; but, once again, the same is true of Accredited Registers, if everyone knew that they needed to check that their therapist was on an Accredited Register then not being on one would stop you getting work. Ultimately I’d be happy with either approach, but on balance Accredited Registers have the distinct advantage of already being in law, so there would be nothing to gain by creating duplicate kite marks through protecting titles.

    Would regulating counselling and psychotherapy make a difference? Yes.

    Would protecting the titles of “Counsellor” and “Psychotherapist” make counselling any more regulated than it is at the moment? No.

  5. The missing word that really spoils you research, if that is what it is, Phil, is “therapist”. If somebody were to advertise as a “therapist”, everyone would know exactly what they meant and most would not see any difference between such an ad and one from a psychotherapist. Good luck with getting that word protected. Protected titles are a dead end. You would be far better off spending your energy promoting the PSA scheme so that those who want a registered therapist know how to ensure they get one.

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