NHS' 10-year plan sets out promising UK opportunities for product manufacturers
Published on 22nd September 2025
The plan's promotion of proportionate regulation and balanced risk assessment for new products may encourage innovation
The government's 10-year plan for the NHS published in July envisages a central role for manufacturers of innovative medical devices, who will welcome many elements of the plan to reform the delivery of UK healthcare.
Following the government's blunt declaration last year that "the NHS is broken", the plan represents the government's flagship policy to fix UK national healthcare with a pivotal role for the private sector and will inform policy decisions across the service for years to come.
NICE's expanded role
The plan proposes to enlarge the role of the National Institute for Health and Care Excellence's (NICE), including updating the technology appraisal process.
From April 2026, NICE’s technology appraisal process will be expanded to cover devices, diagnostics, and digital products that meet the NHS’s most urgent needs and support financial sustainability. This includes mandated funding by the NHS and accelerated commercial support. NICE will also be given a new role to identify which outdated technologies and therapies can be removed from the NHS to free up resources for investment in more effective ones.
In tandem with this, surgical robot adoption will be expanded in line with NICE guidelines and NHS trusts will be supported to increase robotic process automation for tasks such as data entry, inventory control, and referral management.
New 'innovator passport'
The government plans to create a new innovator passport by 2026, which will mean that once an innovation has been assessed by one NHS organisation as suitable for use within the service, further NHS organisations will not be able to insist on repeated assessments.
There will also be a new mechanism for a presumption of adoption for innovations that can demonstrate a step change improvement in quality where they are cost neutral and improve the quality of care.
Balance of risk
More broadly, the plan acknowledges that the healthcare system does not reliably apply proportionate regulation to new products and often demands perfection from new products even where the status quo is poor.
Risk managers will want to know if future regulations and government guidance will recognise that innovative medical devices may not always fully meet patient or consumer expectations and that this does not automatically mean the product is legally defective.
Manufacturers will be studying guidance, as it is updated, to assess how products can meet NICE's requirements. The introduction of new innovator passports may lead to welcome certainty in business planning. A formal recognition of the point that the risks of innovative products must be balanced against their benefits may reduce the risk of liability litigation that can inhibit innovation and lead to "safety first" product development.
Osborne Clarke comment
The 10-year plan introduces several promising opportunities for manufacturers of innovative medical devices. The industry will hope that the expansion of NICE's role to include devices, diagnostics and digital products will streamline the technology appraisal process, so that products meeting urgent NHS needs receive mandated funding and accelerated commercial support. Additionally, increased use of surgical robots and robotic process automation should be accompanied by clear guidelines and support for integrating advanced technologies into NHS operations.
The introduction of innovator passports by 2026 is expected to bring significant benefits, as it will prevent repeated assessments by multiple NHS organisations once an innovation is deemed suitable. This presumption of adoption for cost-neutral innovations that improve care quality will offer manufacturers greater certainty in business planning. Furthermore, the plan's acknowledgment of the need for proportionate regulation and balanced risk assessment for new products may reduce liability litigation risks, encouraging manufacturers to pursue innovative solutions without the fear of excessive legal repercussions.
This is the third Insight in our series on the NHS 10-year plan that has looked at the role of the private sector and digital health suppliers, with the next article focusing on opportunities for pharmaceutical manufacturers.
