At HLTH Compliance, we support hundreds of primary care providers across the country with governance, CQC compliance and quality assurance. As the NHS continues to evolve at pace, one of the most significant system-level changes currently underway is the restructuring of Integrated Care Boards (ICBs).

These changes will directly impact how services are commissioned, how providers engage with system partners, and how local oversight aligns with regulatory expectations.

This blog sets out what’s changing, when it’s happening, and crucially, what it means for your service.

Why Are ICBs Changing?

In March 2025, NHS England announced a requirement for ICBs to reduce their running and programme costs by 50% by December 2025.

To achieve this, ICBs are:

• Reducing duplication across systems

• Working across larger geographical footprints

• Restructuring leadership and governance arrangements

Alongside this, NHS England itself is being merged back into the Department of Health and Social Care, signalling a broader shift towards central alignment and system efficiency. Clustering vs Merging: What’s the Difference?

Clustering (Current State)

• Two or more ICBs working together

• Shared leadership, teams or committees

• Remain legally separate organisations

Clustering is essentially a transitional operating model to deliver cost savings and test collaborative working.

Merging (Next Phase)

• ICBs formally combine into one legal entity

• New governance structures and boundaries

• Requires ministerial approval

Importantly, clustering arrangements do not automatically define future merger boundaries.

Key Timeline

• By December 2025
  ICBs expected to achieve 50% cost reductions

• 1 April 2026
  First wave of approved ICB mergers go live

• Summer 2026
  Decisions on further mergers and boundary changes

• 1 April 2027
  Second wave of mergers expected to take effect

Where Are Mergers Happening First?

London

• North Central London + North West London 
  New West and North London ICB

East of England

Major restructuring into three ICBs:

• Norfolk & Suffolk ICB (merging Norfolk & Waveney + SNEE)

• Essex ICB (new combined footprint)

• Central East ICB (multiple ICBs merged)

South East

• Surrey & Sussex ICB (new merged entity)

• Thames Valley ICB (new structure)

• Boundary changes across Frimley, Hampshire and others

Midlands & South West

• Extensive clustering arrangements in place, with mergers likely to follow

North East & North West

• No clustering arrangements currently confirmed

What This Means for Primary Care Providers

While these changes are happening at system level, they will have real operational implications for providers.

Changing Commissioner Relationships

You may:

• Engage with new or larger ICB structures

• See changes in contract management and oversight

• Experience shifts in decision-making pathways

Evolving Local Priorities

Merged ICBs will operate across larger populations, meaning:

• Strategic priorities may broaden

• Local nuances may require stronger provider voice

• Place-based working becomes even more important

Governance and Accountability

With restructuring comes:

• New governance frameworks

• Potential delays or changes in communication

• Transitional risk in oversight and assurance processes

This is particularly relevant when aligning with CQC expectations around partnership working and system leadership.

Increased Focus on Efficiency and Outcomes

ICBs will be working within a £19 per head cost envelope, meaning:

• Greater scrutiny on value and outcomes

• Increased emphasis on data, quality and performance

• Stronger alignment with the 10 Year Health Plan

The CQC Angle: Why This Matters for Compliance

Although the CQC does not regulate ICBs directly, these system changes will influence:

• How services are commissioned and monitored

• How providers evidence partnership working

• How leadership demonstrates awareness of system pressures

Under the Well-Led domain in particular, inspectors increasingly expect providers to:

• Understand their wider system context

• Engage effectively with commissioners

• Demonstrate adaptability to change

Failing to recognise or respond to ICB restructuring could be viewed as a governance gap.

Risks During Transition

Periods of structural change can introduce risk, including:

• Lack of clarity in communication channels

• Delays in decision-making or approvals

• Shifts in local expectations or thresholds

Providers who remain proactive and informed will be best placed to navigate this.

How HLTH Compliance Can Support You

At HLTH Compliance, we are already supporting providers across England to understand and respond to these changes.

We help you:

• Interpret how ICB restructuring impacts your service

• Align governance frameworks with evolving system expectations

• Prepare for CQC inspections with clear evidence of system awareness

• Maintain strong, compliant relationships with commissioners

Final Thoughts

ICB clustering and mergers represent one of the most significant structural changes in recent NHS history.

While the intent is to improve efficiency and reduce duplication, the transition period will require providers to stay informed, agile and well-governed.

Need support navigating these changes?
HLTH Compliance is here to help you understand what this means for your service, your compliance, and your future inspections. Book in a call with our governance team today to find out how these changes affect your practice.