There is no single NHS commissioner
Integrated Care Boards now hold or exercise much of the local commissioning responsibility in England, including primary care and some specialised services. NHS England still legally commissions a number of services during 2026/27, while provider organisations and local authorities remain important buyers in their own right. The useful question is therefore not “who commissions the NHS?” but “who owns this specific service, budget and procurement route?”
Commissioning is one of those NHS words that sounds simple until you try to map it.
At its core, commissioning means assessing need, deciding what services are required, allocating resources, arranging provision and monitoring whether those services deliver the intended outcomes.
But commissioning responsibility can sit at different levels depending on the service. It can also be delegated, exercised jointly or delivered through collaborative arrangements.
What changed since our January 2024 review?
The direction described in the original article was broadly right: commissioning responsibility has continued to move away from a highly centralised model and towards Integrated Care Boards.
Several things are now clearer:
- primary care commissioning has been delegated to ICBs;
- some specialised commissioning functions have also moved into ICB-led arrangements;
- ICBs are increasingly expected to behave as strategic commissioners rather than operational management bodies;
- the ICB map itself was consolidated from 42 boards to 36 in April 2026;
- most remaining NHS England direct commissioning functions are expected to transfer to ICBs from April 2027, subject to legislation.
2026/27 is effectively a transition year
NHS England says ICBs will take a full leadership role during 2026/27 for services due to transfer in April 2027, even while NHS England remains the legal commissioner for functions that have not yet formally moved.
What do ICBs commission now?
ICBs are responsible for planning and commissioning a large share of local NHS services and for allocating resources across their populations.
The exact portfolio varies with delegation and local arrangements, but the broad direction includes:
Secondary & community care
ICBs plan and contract for major parts of local healthcare, including hospital, community and mental-health pathways, often across several provider organisations.
Primary care
ICBs hold delegated responsibility for primary medical, dental, ophthalmic and community pharmacy services under NHS England delegation arrangements.
Specialised services
Some specialised commissioning has already moved toward ICBs, while other functions remain with NHS England during the transition.
Joint health & care pathways
ICBs can work with local authorities and other partners through pooled budgets, joint commissioning and place- or neighbourhood-level arrangements.
Primary care: one of the biggest shifts
NHS England has delegated responsibility for the direct commissioning of primary medical, dental, ophthalmic and community pharmacy services to ICBs.
That includes contract management and supporting improvement and transformation across those services.
However, delegation does not mean NHS England disappears from the legal picture. NHS England currently retains overall accountability for those delegated functions and seeks assurance that ICBs are exercising them appropriately.
“Primary care” does not automatically mean the GP practice is the buyer. Depending on the requirement, responsibility may sit with the ICB, a Primary Care Network, a federation, an individual practice or another provider organisation.
Specialised commissioning is moving too
Specialised services have historically been a major area of direct NHS England commissioning.
The system has been moving toward greater ICB involvement in appropriate specialised services so that commissioning decisions can be considered alongside wider pathways and local population needs.
During 2026/27, ICBs are preparing to take a broader leadership role ahead of the planned transfer of most remaining direct commissioning functions in April 2027.
What stays with NHS England in 2026/27?
NHS England remains the legal commissioner for services that have not yet been formally delegated or transferred.
That distinction matters. An ICB may lead the commissioning work operationally during this transition while NHS England still retains the statutory commissioning responsibility.
For data and sales intelligence, both facts can be relevant: who legally commissions the service, and who is practically leading the work.
What happens from April 2027?
Subject to parliamentary approval, most of NHS England's remaining direct commissioning functions are expected to transfer to ICBs from April 2027.
NHS England has also set out plans for seven Offices for Pan-ICB Commissioning (OPICs), one in each NHS region.
These are intended to provide specialist commissioning expertise and support services that need to be commissioned across several ICBs rather than separately by every board.
That creates an important distinction for suppliers:
- some services will make sense at individual ICB level;
- some will be commissioned collaboratively across several ICBs;
- some requirements will continue to involve provider organisations directly;
- national policy and oversight will still shape the market even as commissioning moves locally.
Where does “place” fit?
The 2024 article focused heavily on commissioning being delegated down to “place”. That idea has not disappeared, but the language and governance are not identical across every system.
Place-based partnerships often align with local-authority areas and can bring together the ICB, councils, NHS providers, primary care and voluntary-sector partners.
Some systems delegate meaningful budgets or responsibilities to place. Others retain more control at ICB level.
So “place” should be treated as an organisational layer to investigate rather than a uniform statutory buyer type.
Commissioning is not the same as procurement
This is probably the most important practical distinction for suppliers.
A commissioner decides what needs to be provided, for whom, at what scale and with what outcomes. Procurement is one of the mechanisms that may then be used to arrange the supply of that service or supporting product.
The commissioning body and the organisation issuing a purchase order are therefore not always the same.
| Scenario | Commissioning influence | Likely buying / delivery organisation |
|---|---|---|
| System-wide clinical pathway | ICB | Could involve several trusts, community providers and primary-care organisations. |
| Hospital software | ICB may influence strategy or funding | Individual NHS Trust or Foundation Trust may procure and contract. |
| Primary-care service | ICB under delegated commissioning | Delivery may sit with practices, PCNs, federations or other providers. |
| Joint health / social-care service | ICB + local authority | Could use pooled budgets, lead-commissioner arrangements or joint procurement. |
| Highly specialised service | NHS England / ICB transition / pan-ICB arrangements | Depends on current delegation and service design. |
Provider organisations are still buyers
The rise of ICBs sometimes creates the impression that NHS Trusts stopped buying things. They did not.
Trusts and Foundation Trusts still run hospitals, community services, mental-health services and ambulance services. They employ large workforces, manage estates and technology, operate procurement functions and hold their own contracts.
The ICB may shape strategy or commission the clinical service, while the provider still buys the systems, equipment and operational services needed to deliver it.
What does this mean for public-sector sales?
A good NHS targeting strategy now needs to answer several questions before deciding whom to contact:
- Is this a commissioning issue or an operational provider issue?
- Does the responsibility sit at ICB, place, neighbourhood or organisation level?
- Has the function already been delegated from NHS England?
- Is the service expected to transfer in 2027?
- Is the requirement best handled by one ICB or collaboratively across several?
- Which named postholder owns the function inside that structure?
That is why “NHS contacts” is usually the wrong starting request. The useful answer depends on the service, responsibility and route to market.
Why Oscar keeps the history
NHS commissioning changes create a data problem as well as a policy problem.
When responsibility moves from NHS England to an ICB, or from one ICB into a newly merged board, the old names and structures remain scattered across historic documents, procurement notices and supplier CRMs.
Oscar's research tracks those relationships so that current organisations can be understood in the context of what came before them.
That is particularly useful when analysing contracts that began under CCGs, procurement notices issued by predecessor bodies, or postholders whose responsibilities have moved through several reforms.