Simon Doyle, spokesperson for The Coalition for Responsible Digital Health, says that the King’s Speech has opened a door, but asks whether digital health will be let in.
The recent King’s Speech confirmed what many in digital health have been waiting to hear: the NHS is changing. A single patient record, a statutory growth duty on regulators and a system designed around how people actually access care today. The priorities are correct and the ambition here is sound. But the regulated digital providers already delivering a significant and growing share of UK healthcare have not yet been fully incorporated into the proposed infrastructure. If the infrastructure now being designed doesn’t account for how care is already being delivered, the NHS risks building a digital future on incomplete foundations and missing the opportunity to draw on years of real-world evidence, deployment experience and clinical learnings already accumulated by regulated digital providers.
Making shared records genuinely shared
The single patient record is potentially the most significant development for healthcare in a generation. Whether it delivers on that promise depends entirely on decisions that have not yet been made: who counts as an authorised provider, what access will look like in practice, and whether the consent and data-sharing framework reflects how patients actually move through the health system today. Many people do not follow a single, linear pathway through NHS services. They use multiple providers, moving between the NHS, digital services and in-person care, often all three.
Right now, regulated digital providers cannot routinely access the NHS Summary Care Record. The result is that patients are often asked to self-report their medical history, chase their GP for records, or repeat information they have previously provided elsewhere. This presents a barrier to the kind of joined-up, efficient care the SPR is designed to deliver.
Regulated digital providers are already held to the same workforce standards and regulatory requirements as their NHS counterparts. The gap is not in governance or clinical quality – it is in access to information. Consent-based, read-only access to relevant parts of the shared record for trained, regulated healthcare professionals working within governed digital providers would give them the tools to match the care they are already delivering.
Access would be patient-owned, consent-driven and role-based, meaning only the clinicians who need specific information to make safe prescribing decisions would see it. This is standard practice across the NHS. Extending it to regulated digital providers would build upon existing NHS principles of role-based, consent-driven access. The single patient record will not pilot beyond maternity and frailty care until 2028. In the years before any wider rollout, the case for interim consent-based access for regulated providers only grows stronger.
Growth duty: the right idea, missing the right regulators
The Regulating for Growth Bill is, in principle, what digital health has been missing. A statutory duty requiring regulators to actively consider economic growth and innovation could begin to shift a regulatory culture that has too often treated digital health as a risk to be managed rather than a growth vector to be supported. Applied properly, it could also do something else: help draw a clearer line between the responsible, governed providers operating to high clinical standards and the illegal online sellers and unregulated suppliers that regulators currently have far less grip on.
The problem is who is actually in scope: The Bill names Natural England, the Environment Agency and the Health and Safety Executive. The General Pharmaceutical Council, which regulates the pharmacies and pharmacists at the heart of digital prescribing, is not on the list. Neither is the Care Quality Commission or the Medicines and Healthcare products Regulatory Agency (MHRA). This matters because when regulatory requirements fall most heavily on already-governed providers, unintended market distortions can occur. It pushes patients toward unregulated sources. A growing number of people are already sourcing GLP-1s from gyms, personal trainers and illegal online sellers. Tightening the rules for responsible providers while leaving that market largely unchecked is not a patient safety policy, but the opposite. Bringing healthcare regulators into the scope of the growth duty would not lower the bar on patient safety. It would raise the bar on proportionality and, in doing so, make it harder for unsafe operators to exploit the gap.
GLP-1s: where the gap between policy and reality is hardest to ignore
As many as 3.4 million adults in England meet the current NHS clinical criteria for GLP-1 treatments. NHS England’s phased rollout will reach 220,000 people over three years. The shortfall is not filled by waiting lists. It is filled, in large part, by digital providers already delivering clinically governed, wraparound care to patients who have no other route to treatment.
Alongside NHS provision, Coalition for Responsible Digital Health members are already supporting substantial numbers of patients through clinically governed weight-management pathways. Combined data show a moderate harm rate of 0.04% across the coalition, with zero cases of severe harm and no instances where serious harm has been directly attributable to regulated digital prescribing alone. Robust protocols and strong clinical governance mean between 17% and 25% of applicants are rejected on clinical grounds before treatment even begins. These are not informal operators at the edges of the system. They are an active and accountable part of it, already generating the real-world evidence that should be informing policy.
According to the most recent analysis, obesity costs the UK economy £126 billion a year – a figure projected to reach £150 billion by 2035 without meaningful action. Tackling it requires Treasury, Business and Trade, and Work and Pensions to recognise responsible digital health as a strategic growth sector. The question is whether policy catches up before more patients are pushed toward unsafe alternatives and before the UK loses the window to make meaningful progress on obesity in the next decade.
This is a genuine moment of opportunity. Getting the single patient record right, bringing the right regulators into the scope of the growth duty, and recognising responsible digital health as a strategic part of the UK’s health and growth agenda are not niche asks. They are the difference between a digital NHS that works for everyone and one that simply replicates the old system in a new format.
