A Department of Health working group is looking at nurse revalidation.
Its latest report, issued at the end of last month, suggested the KSF was a possible method of gathering evidence on how nurses had developed their skills.
However, unions have raised concerns that the KSF could be used against staff, contrary to its original purpose as a development tool.
June Chandler, national officer at Unison, said: ‘It could be hijacked. We would not want it to be used in a way that would get someone struck off the register.’
Gary Kirwan, employment relations adviser at the RCN, added: ‘The KSF is just one way of gathering information and evidence about how someone’s career is progressing. We should look for other information for revalidation.’