To: The National Commission for Allied and Healthcare Professions (NCAPH) 

Subject: Suggestions and Recommendations in Response to the Draft Provisional Registration Framework Released in November 2026

First, we thank NCAPH for its efforts to regulate psychologists (except clinical psychologists) in India, and we appreciate that the draft provisional registration framework invites public feedback before 4th December 2026. 

While we welcome the proposed provisional registration provisions and the steps taken to accommodate certain categories of existing practitioners, we would like to respectfully highlight that there may still be some psychologists who do not fall within the proposed eligibility criteria and may consequently be left without a clearly defined transitional registration pathway, as they do not meet the criteria for regular, interim, or proposed provisional registration.

If psychologists who were legally and ethically practicing before these regulations came out are left without a transitional pathway, this could have a significant impact on their careers and put their existing employment at risk.

Psychologists who may be left out include-

1.     Master's degree in psychology without a Bachelor's degree in Psychology who have less than three years of work experience: This includes people who are meeting the provisional registration qualification criteria but don’t meet the eligibility criteria for work experience. (One alternative pathway for these individuals could be a longer-duration bridge course, which can be 1 year instead of 6 months.)

2.     Individuals who got their Master’s degree in psychology through online or distance learning before the ban on distance learning came into effect: People in this category do not appear to have been acknowledged in the regular, interim, or draft provisional registration categories.

3.     Individuals with a 4-year bachelor’s and a 1-year master’s in psychology: People in this category have not been recognized under any of the proposed registration categories.

Before these regulations came into effect, a Master's degree in Psychology was the educational qualification generally required to practice as a psychologist in India. With the introduction of these new regulations, we request that a fair transitional pathway be provided for all psychologists who are currently practicing, so that their careers are not disrupted.

Additional requests for an accessible and inclusive transition-

1.     Flexible bridge courses for working professionals: Since many individuals who may need to undertake bridge courses are already working professionals, it would be helpful if, instead of requiring the courses to be conducted entirely in regular mode, they could be offered in hybrid mode or with an option of weekend classes.

2.     Broader recognition of relevant work experience: Although a clear definition of the minimum work experience required in a health setting has not yet been provided, it is important to acknowledge that psychologists don’t just work in hospitals; they work in multiple settings, such as:

-Schools, colleges, and educational institutions.
-Corporate organizations and employee assistance programs.
-NGOs and community organizations.
-Counselling centers and mental health organizations.
-Tele-counselling and online mental health platforms.
-Independent and private psychological practices.

Hence, we request that experience gained in these and other relevant settings be recognized as relevant professional experience in the field of psychology.

3.     Recognition of independent and private practitioners: Many psychologists in India have their own private practices, and we request that this experience also be considered when assessing the minimum work experience requirement in a health setting. Such psychologists can provide documents such as self-affidavits or other relevant supporting documents, while ensuring that client confidentiality is maintained.

4.     Proof of current residential address: The draft provisional registration document mentions Aadhaar Card, Passport, Voter ID, and PAN Card as accepted documents for proof of address. However, if a psychologist is practicing in a city different from their permanent address, we request that alternative documents proving their current residential address also be accepted. These could include a No Objection Certificate, electricity, water or gas bills, mobile bills, etc.

5.     Protection of existing practitioners' careers and livelihoods: We request reasonable transitional arrangements so that individuals who were legally and ethically practicing under the framework applicable at the time are not suddenly left unable to continue their professional activities or placed at risk of losing their employment and livelihoods.

Our Appeal

We wish to emphasize that this Petition is not against the regulation of psychologists in India, and we support the Commission's efforts to strengthen the profession, uphold ethical standards, and ensure quality services.

Our request is simply that the transition to the new regulatory framework should also be fair and inclusive towards individuals who pursued their education, invested their time and effort, and entered the field of psychology in good faith under the educational and professional framework applicable at the time.