Eleven forces that will shape health consultations in the UK, 2026 to 2029

Public bodies are currently navigating the most challenging consultation environment they have faced in the past decade. Over the coming four years, how patient and public involvement is handled will be assessed based on increasing legal, ethical, and practical standards. The positive side is that it is feasible to be both more confident and more secure by establishing the right habits early on.

Below are eleven themes we believe will be most important, drawn from current guidance, live policy, and recent practice. Where we say do this, it is because the risk landscape or opportunity now requires it.

1) ICS duties to involve get sharper as a result

Integrated care boards are still a long way from bedding in, but the test is moving from having a strategy to showing how you worked with people and communities on real changes. NHS England’s statutory guidance sets the tone, and 2025 to 2026 planning guidance keeps public involvement and inequalities front and centre. If you cannot evidence the thread from engagement to decision, expect challenge. 

Do this:

• Traceability of each step, from question to option to decision, across all reconfiguration packs.
• Methods notes in consultation reports that describe how responses were considered.

2) Procurement reform changes expectations, even when the law does not demand a consultation

The Provider Selection Regime is now active across the NHS. It enhances transparency requirements related to provider choices and record-keeping, even when a formal consultation isn’t necessary. You will still encounter public questions about fairness, conflicts of interest, and the evidence supporting the selection of Provider A over B. Develop a habit of publishing your PSR rationale in plain English and clearly indicate how people can raise concerns. 

Do this:

• Publish a straightforward PSR summary alongside business cases.
• Pre-empt conflict by engaging staff, patients, and local partners early before making decisions.

3) AI is already in the room, on both sides of the table

Large language models shorten the time it takes the public to read, analyse, and draft strong responses. That raises the standard for how authorities explain assumptions, summarise feedback, and keep an audit trail. It also introduces risks, including synthetic campaigns and over-confident summaries. Expect to publish AI use statements and to preserve minority voices when using automated analysis. 

Do this:

• Respondents are using an AI game, both in the volume of responses and in the nature of the themes they are attempting to develop. 
• Train comms and engagement teams on safe AI use, aligned to sector guidance. 

4) Data trust will make or break your mandate

Public backing for data-enabled change is fragile. The Data (Use and Access) Act 2025 updates the UK data regulations, gradually implementing changes over the next few months. Anticipate increased inquiries about data sharing, secondary use, and opt-outs. At the same time, national data platforms are expanding, and media attention on their adoption remains intense. Consider data engagement a central part of your strategy, not a secondary task. 

Do this:

• Publish clear plain-English privacy notices for each project.
• Run targeted sessions with groups who are most wary of data sharing, then show how their feedback changed controls. 

5) Digital first, never digital only

Government monitoring now adopts WCAG 2.2 for public sector websites and applications. NHS services are required to comply with WCAG 2.2 AA for all services accessed by patients and staff. Considering that many adults find health information challenging, especially when numerical skills are involved, digital access alone is not enough—exclusion can be detrimental. Therefore, develop hybrid programs that serve both online and offline, low-literacy populations. 

Do this:

• Assess readability and numeracy, rather than merely translating. Utilise assisted access points in libraries and community venues.
• Publish accessibility statements that specify what works currently and what will be fixed by when.

6) Predetermination will trip you up if you treat engagement as theatre

Courts continue to distinguish clearly between acceptable predisposition and unlawful predetermination. The safest approach is to be cautious and disciplined: seek advice when proposals are still genuinely open, keep thorough records, and be mindful of what you communicate on social media. In essence, demonstrate to an impartial observer that you have maintained an open mind. 

Do this:

• Include a predetermination checklist in member and executive briefings.
• Make time announcements to prevent any impression that you decided beforehand.

7) Continuous engagement moves from aspiration to operating model

Five years after the initial calls, ongoing engagement now has practical frameworks and case studies. The LGA’s New Conversations defines how to make engagement instinctive, while recent local practice shows how hybrid programmes reach seldom-heard groups. For health, the benefit is fewer shocks and greater legitimacy when service change becomes unavoidable. 

Do this:

• Maintain standing panels during statutory consultations.
• Report regularly, including what you did not do and why.

8) Inequalities are a design constraint, not a nice-to-have

NHS England’s Core20PLUS5 continues to serve as the standard starting point for actions. Be prepared for increased scrutiny regarding whether your engagement effectively identified and listened to the most impacted individuals, and whether your proposed solutions narrow or widen disparities. From the beginning, align your consultation sampling, questions, and analysis with the inequalities framework to ensure a focused approach. 

Do this:

• Incorporate targeted boosts into sampling frames for Core20 groups.
• Assess the differential impact alongside full support, then release mitigations.

9) EIA-first is the safer default

The fastest path to a defensible decision is to start with the Equality Impact Assessment and keep it live. Map likely impacts early, design your questions to test them, and update the EIA as evidence comes in. Treat it as analysis, not a template. 

Do this:

• Require an EIA checkpoint before finalising options and again prior to the decision.
• Record each iteration and explicitly reference it in the decision paper.

10) Climate resilience and Net Zero will pull engagement into estates, models of care, and procurement

A net zero NHS is a formal policy, not just a slogan. Systems are updating their Green Plans for 2025 to 2028. Already, heatwaves, flood risks, and supply constraints impact safety and operations. Consultations on estates and service models must demonstrate how you balanced carbon footprint, resilience, and patient access. 

Do this:

• Explain the rationale related to carbon and climate for reconfiguration options in clear English.
• Collaboratively determine adaptation priorities with staff and communities most vulnerable to heat and access risks. 

11) Reconfiguration and ministerial call-in powers keep the bar high for assurance

Service change still involves political tension. The framework for the Secretary of State’s intervention power is active, emphasising the need for credible options, a clear rationale for change, and evidence of fairly considering feedback. Incorporate independent assurance into the plan as a standard element, not as a fallback. 

Do this:

• Publish a public roadmap that shows the approval and assurance stages before you start.
• Stress test options with Joint Health Overview and Scrutiny Committees early. 

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Red flags that invite challenge

• Decisions seem to be made before the consultation ends, or a senior figure pre-commits publicly. 
• PSR selections lacking a clear public rationale or presenting a rationale that ordinary readers cannot understand.
• Digital-only exercises that lack accessibility and do not include plans for participants with low literacy or offline access. 
• Climate and inequalities are left as an appendix rather than being integrated into options. 

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Final word

Better consultations are not about duration but about clarity, transparency in approach, and genuine inclusion. Over the next four years, successful teams will integrate ongoing engagement, EIA-focused design, transparent AI utilisation, and concrete evidence that they listened before making decisions. This approach ensures they remain both ambitious and defensible.