The NHS Modernisation Bill (2026) matters less for what it builds than what it settles in national law. For the first time in England, the direction is towards treating a patient’s healthcare record as national infrastructure that can follow them across care settings, rather than being held by whichever institution created it.
This is a significant shift. The strategy has arguably been shaped by the lessons of the National Programme for IT, with one important correction: the aim is to federate existing digital patient records, not replace them.
A federated record, not a replacement programme
The proposed Single Patient Record (SPR) would draw from existing digital records and connect them through common standards. Shared care records have already proven that model regionally. The SPR aims to take the same principle to national scale, with standardised capabilities and greater opportunities for patients to access their information.
For businesses working with the NHS, this matters alongside the structural changes around the Bill. NHS England functions are moving into the Department of Health and Social Care, while buying power is consolidating into Integrated Care Boards (ICBs), with a longer-term transition towards integrated health organisations.
For technology suppliers, the more immediate change is the expectation that data can move safely and consistently between systems. We should expect pressure to expose data through conformant APIs, support write-back and provenance rather than read-only viewing, reduce commercial friction around API access; and make access and audit visible to patients.
From our experience working with NHS organisations to deliver shared care records, we know that connecting systems is only part of the answer. The information moving between them must also be accurate, timely, and usable within clinical workflows.
The practical risks sit beyond technology
The biggest risks to the SPR are not necessarily technological
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