Three different legal processes, covering NHS commissioning, fire governance and policing, are currently being used to redraw public service boundaries around the new strategic authorities. In every case, the new route drops the same thing: the specific step that used to let public bodies or the public object before the change happened.
What do the NHS, fire and police changes have in common?
NHS commissioning, fire governance and police boundaries are all being redrawn to match strategic authorities, the new mayoral and combined authority regions created under separate devolution legislation. Three different legal processes are being used for this work, one for each service. Despite having little else in common, all three processes remove the same thing: the step that used to let the people or public bodies comment before the change was made.
The changes sit inside a wider plan. The Cabinet Office’s 31 July 2026 Rewiring the State statement commits to aligning regional police forces, fire and rescue services and Integrated Care Boards (ICB) with strategic authority boundaries by the end of this Parliament.
This builds on the earlier English Devolution White Paper, which set out a policy of mayors taking on police and fire functions once boundaries lined up. That was a statement of policy direction, not an automatic legal transfer. The actual transfer happens through the three routes described below.
In each of the three examples, there is a useful distinction to hold onto: changing which organisation is in charge and where its boundary lines sit, against changing what is actually delivered to patients, residents or communities. The first kind of change is the one being fast-tracked. The second still usually requires consultation.
How does each of the three laws produce the same result?
The first example is the NHS. The normal rule is that a substantial change to health services requires consultation with the local council. Regulation 24 of the 2013 health scrutiny regulations removes that requirement specifically for setting up or closing down an ICB, as long as the change does not also amount to a substantial change in the services themselves.
NHS England, which runs the boundary change process, says a separate duty to involve patients and the public in service changes does not apply either, because that duty covers what an ICB commissions, not its boundary. It does require support from the relevant local councils, though published guidance does not say whether that support amounts to a veto or a procedural step.
The second example is fire, and it is more clear-cut. Before 2026, a police and crime commissioner who wanted to take over fire governance had to consult people across the police area and publish a response to what they said, under Schedule A1 to the Fire and Rescue Services Act 2004. The 2026 Devolution Act created a new route instead. It lets the Secretary of State hand fire and rescue authority functions straight to a mayor or combined authority, without that consultation step.
The third example is police. The Police Act 1996 gave affected bodies at least four months to object before certain boundary changes go ahead. The 2026 Devolution Act created a new type of boundary change, specifically to transfer police and crime commissioner functions to a mayor, and did not bring that new type within the four month objection process.
Three services, three different legal processes, and one result each time: the step that let the people or public bodies object before the change happened is not there in the new route.
What does this pattern mean for the strategic authority programme?
None of this means public accountability has disappeared. The NHS still expects meaningful engagement with affected ICBs, local councils and partner organisations, and the normal public involvement duties still apply once an actual change to services is on the table.
What has narrowed, in all three sectors, is something more specific: the guaranteed chance to weigh in on whether the new organisation should exist in that shape at all, before it is created. For a resident, that is the difference between having a say on how something is run, and having no say on whether it should exist at all.
This follows the same shape as the change described in our last article, which covered how strategic authorities themselves are created. In the House of Lords on 29 January 2026, government described the aim as streamlining the transfer of fire and police functions to mayors where boundaries already align, and the case for administrative streamlining should not be dismissed.
Three different legal processes reaching the same conclusion is not an accident of drafting. It is a sign of where the priority sits. That is the same gap identified in our last article, now stretched across services that shape how millions of people are policed, protected and treated.
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