AXREM Response to Government’s consultation on the disclosure of industry payments to the healthcare sector
18 December 2025
In response to the Government’s consultation on the disclosure of industry payments to the healthcare sector, AXREM and our member companies welcome the stated direction of travel toward greater transparency. This aligns with our industry values of integrity and ensuring the NHS and our nation benefit from genuine value for money.
At the same time, having contributed to the consultation process, we are keen to understand the detailed requirements that will flow from the guidance so we can engage constructively and plan implementation in a way that supports patient care and productive supplier–provider relationships. In particular, we would appreciate clarity on the following:
- Scope and definitions
• The categories of payments/benefits to be reported (e.g., grants, sponsorships, consultancy, training, donations, in‑kind support), and any exclusions.
• Who is in scope (individual clinicians, healthcare organisations, teaching hospitals, research institutions), and treatment of multi‑party arrangements.
• How the guidance will align with existing professional registers (e.g., conflicts of interest held by provider organisations). - Thresholds, frequency, and timing
• Any monetary or materiality thresholds to avoid noise while preserving meaningful transparency.
• Reporting frequency (e.g., continuous register vs. quarterly/annual cycles) and submission deadlines.
• Transitional arrangements and reasonable lead‑in for suppliers—especially SMEs—to build processes and systems. - Format, interoperability, and data standards
• Required data fields, templates, and identifiers (organisation codes, clinician identifiers) to ensure comparability.
• Expectations for automation or API-based submission, and alignment to agreed standards (e.g., FHIR/DICOM/HL7 where relevant for interoperability in healthcare contexts).
• Accessibility requirements for publication (e.g., placement and discoverability on UK homepages vs. central registers). - Governance, assurance, and proportionality
• Expectations for internal assurance and any external audit or verification.
• Proportionality measures to ensure the scheme is not burdensome, does not create unintended barriers to collaboration, and does not impose disproportionate reporting overhead on SMEs.
• Treatment of commercially sensitive information and compliance with data protection obligations. - Consistency with existing industry codes
• How the guidance will dovetail with AXREM’s Code of Conduct and the COCIR Code of Conduct, which our members already follow, to avoid duplication and conflicting requirements.
• Whether conformance with recognised codes can be leveraged as evidence of good practice within the guidance
Going forward, we would welcome the opportunity to work with DHSC officials and other stakeholders to co‑design pragmatic, proportionate guidance that achieves the intended transparency outcomes without compromising innovation, service quality, or procurement efficiency. To that end, AXREM would be keen to support next steps in drafting requirements and co-development of reporting templates, with specific attention to SME impacts and mitigating administrative burden. Thanks to DHSC for engaging with our sector in this process. We look forward to collaborating on implementation details that uphold transparency and integrity while enabling suppliers and providers to focus on delivering for patients.
Sally Edgington, AXREM CEO said upon reading the government’s response:
“As CEO of AXREM, I am proud to see our sector engaging constructively with the Government’s consultation on disclosure of industry payments to the healthcare sector. Transparency is a cornerstone of trust, and our members are committed to ensuring that the NHS and patients benefit from genuine value for money. At the same time, it is vital that the guidance is clear, proportionate, and workable in practice.
We want to avoid unnecessary complexity or duplication, particularly for SMEs, while safeguarding the integrity of supplier–provider relationships that underpin innovation and patient care. AXREM stands ready to collaborate with DHSC and stakeholders to co‑design pragmatic solutions, ones that uphold transparency and accountability, but also enable our industry to continue delivering the technologies, services, and partnerships that improve outcomes for patients every day.
We welcome this dialogue and look forward to shaping guidance that reflects shared values of integrity, fairness, and collaboration across the healthcare community.”