‘At Regulatory Crossroads’: Psychology courses caught in UGC, NCAHP, RCI tangle, causing confusion

Catherine Gomes has an MSc in Neuropsychology from Christ University, Bengaluru. It is an emerging and highly-specialised field of psychology, among several others, such as forensic psychology, educational psychology and counselling psychology. However, upon completing her masters, Gomes was confronted with a very difficult question: which body should she register with to be able to work?

Was it the National Commission for Allied and Healthcare Professions (NCAHP) or the Rehabilitation Council of India (RCI)? For specialisations like hers, the regulatory structure is not clearly defined. After the NCAHP Act was passed in 2021 and the body set up in 2023, all except clinical psychologists were brought under its ambit.

When NCAHP released its model curriculum for applied psychology , it recommended the designation of “behavioural health counselor” following a four-year bachelor’s degree and “behavioural health psychologist” for those with masters’ degrees.

“India’s psychology profession is standing at a regulatory crossroads. In India today, the question of ‘who is qualified to practise psychology?’ doesn’t have a simple answer. Why? Because we’ve allowed licensure confusion to define the profession,” said Gomes.

Educators describe the regulatory framework for psychology as “fragmented” and highlight the need for a national body, on the lines of the Psychology board of Australia and the British Psychological Society in the United Kingdom.

Kalpana Srivastava, professor and director, Amity Institute of (Behavioural) Health and Allied Sciences, Amity University Noida, said, “India’s regulatory framework for psychology courses remains fragmented, with the University Grants Commission overseeing academic degrees and the RCI controlling professional licensing, leading to a disconnect between education and practice.”

Before NCAHP, all psychology courses except clinical and rehabilitation psychology, were under UGC.

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Psychology Courses: NCAHP, psychologists, specialisations

Under NCAHP, psychologists are brought under the larger umbrella of behavioral health professionals. In its model curriculum, the different specialisations of psychology are mentioned under the broader title of “job availability”. This is a problem.

Gomes explained, “Why is there no title protection like in other countries for each of these specialisations? The central registry under NCAHP is not active yet, so current enrollments are more symbolic than functional. Many other professions under NCAHP (e.g., physiotherapists, audiologists, medical laboratory technologists, optometrists) already have clear scopes and private practice rights, but psychologists don’t have clear guidelines yet.”

She highlighted that while the ones with specialisations are often forced to call themselves “counselling psychologists” to secure non-specialised jobs, or pushed to pursue courses like clinical psychology or diplomas.

Srivastava adds, “Neuropsychology in India does not currently appear to have a separate,standalone statutory council distinct from existing psychology and rehabilitation structures. In practice, neuropsychology depends on prior clinical psychology training and

institutional role definitions rather than separate direct registration. Counselling psychology and applied psychology are fluid categories. University degrees in these areas may support employment and further study.”

Earlier while speaking to Careers360, NCAHP chairperson Yagna Shukla had stated that the commission isn’t very keen on regulating the psychology programmes within the humanities’ domain.

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Psychology Courses: NCAHP’s model curriculum

Universities are still following the curriculum as standardised by the UGC. “We, at Amity University, continue to run university psychology programmes under

UGC guidelines through Amity Institute of Psychology and Allied Sciences (AIPS) and (AIBHAS) in the academic year 2026. NCAHP has separately issued a model curriculum for applied psychology and behavioural health”, which may influence future restructuring in allied-health-oriented psychology programmes,” said Ranjana Bhatia, acting director and head of AIPS.

In August 2025, UGC issued a public notice prohibiting all higher education institutions (HEIs) in India from offering psychology and healthcare and allied disciplines via open and distance learning (ODL) and online modes, from the July-August 2025 academic session onwards. This stopped admission to psychology at Delhi University’s School of Open Learning, Indira Gandhi National Open University and over 50 other universities.

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A study published in a Springer journal in January 2026, titled “Psychology education in India faces fragmented regulation and overlapping curricula”, by Chinchu C, psychologist and professor at Pondicherry University, details other problems with the curriculum.

“Despite its progressive intent, NCAHP’s B.Psy model curriculum is not without omissions and ambiguities. One significant hurdle lies in its restrictive entry requirements, which mandate prior study of psychology at the 10+2 level. This mandatory requirement would exclude the majority of students who take up the various combinations of science subjects because, in many instances, psychology is offered as a subject under the major stream of Humanities and not in the Science stream,” writes Chinchu.

The study also states that the NCAHP Act, 2021, by its “explicit language and associated rules”, currently governs only diploma and undergraduate (degree) programmes in psychology and other allied healthcare professions.

“Postgraduate psychology programmes (such as MA/MSc in Psychology) remain outside the direct purview of the Act, a distinction critical for interpreting the boundaries of recent UGC and NCAHP regulations. Most advanced societies mandate a master’s or even doctoral qualification to practice as a psychologist. Because of the regulatory gaps, the independent practice rights for psychologists remain ambiguous. The NCAHP Act distinguishes between ‘healthcare professionals’ who are eligible for independent practice and ‘allied health professionals’ expected to practice under supervision only, but neither the NCAHP Rules nor the model curriculum clarifies which qualifications or specialisations of psychology practitioners belong to each category,” says the paper.

RCI and psychologists

The Rehabilitation Council of India , also a statutory body under the ministry of social justice and empowerment, is currently the only body offering protected titles for psychologists. Its scope is limited strictly to disability and rehabilitation. The BSc, MA and diploma in clinical psychology and rehabilitation psychology qualifications fall under it.

“Post completion, students get CRR No. to practice in the field. For RCI-recognised clinical psychologists or rehabilitation professionals, RCI norms become critical because the training programme itself must satisfy RCI standards and the faculty profile may also be subject to RCI requirements,” said Bhatia.

The students after the registration can work as clinical assistants. Once they complete MPhil, they can work as clinical psychologists. Now, with the implementation of the National Education Policy, MPhil as a level has been discontinued.

“With MPhil removed , protected titles may now be granted at the master’s level itself, which could help bridge the severe treatment gap in India,” said Gomes.

But again, PhD in clinical psychology comes under RCI and PhD in psychology under UGC.

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Chinchu explains, “The RCI programme totals 176 credits and has a four-year professional track. Though the nomenclature mentions ‘Hons’, the syllabus does not explicitly mention eligibility for direct entry into PhD programmes after completion, as allowed in the UGC PhD Regulations, 2022.”

UGC-NCAHP-RCI Split: A separate council

Students and educators highlight the need for a unified regulatory system that integrates accreditation, training, and licensure, to end the current RCI-NCAHP-UGC split.

“A better way forward would involve establishing a single National Psychology Council, introducing tiered licensing, mandating supervised clinical training, and implementing a national licensing exam, thereby shifting from a degree-based system to a competency-based profession aligned with global standards,” said Srivastava.

Gomes cites examples from countries like the US, UK, Canada, Australia, and the UAE.

“In these countries, central bodies license multiple types of psychologists. Titles are protected based on training and scope, not just one degree. Clinical, counselling, health, and educational psychologists are all recognised as distinct professionals and practice rights are offered at the masters/doctorate level.Without role protection, regulation, or licensure, India risks de-professionalising its mental health workforce as well as encouraging malpractice and entry of quacks,” said Gomes.