Policy paper

DHSC counter-fraud strategy: 2026 to 2029

Published 23 July 2026

Applies to England

Ministerial foreword

The Department of Health and Social Care (DHSC) is responsible for delivering the health and care system in England and for overseeing wider UK health policy, including health security, medicines and vaccinations, and elements of scientific research.

The UK health system is built on the principle of equity, and the NHS remains one of our greatest national institutions. It has become integral to our way of life and something we all, quite rightly, hold very dear. In July 2024 Lord Darzi was commissioned to lead an independent investigation into patient access, the quality of healthcare and overall performance of the NHS. The report set out the way forward. Our 10 Year Health Plan for England sets out how we will make these changes.

This government is committed to its mission to build an NHS Fit for the Future. To do this, the NHS must transform so that it remains sustainable. Waste must be reduced and innovation encouraged so that every penny goes to where it is intended - into frontline health services and not into the hands of fraudsters. Fraud is taken seriously across health. It is important that we continue to learn and develop new and innovative ways to combat the threat effectively in what is a rapidly changing risk landscape.

Being tough on fraud and its causes means a better protected NHS and better patient care, with treatment getting to those who need it most and not those seeking to take advantage of the system. At a time of sustained investment in the NHS, it is vital that every pound is protected and used as intended, supporting the long-term sustainability of patient services and successful outcomes. Ambitious targets drive performance. DHSC and the health family exceeded its previous challenging 3-year target of preventing, detecting and recovering £500 million of fraud. This amount is equivalent to the funding for over 3,000 NHS nurses over a 3-year period. Now we want to go further. I am excited to announce a new target of £600 million over the next 3 years.

This new target will be complemented with comprehensive annual DHSC counter-fraud action plans to further tackle fraud and its root causes and set out clear additional annual tasks and metrics. This will allow DHSC to respond in an agile way to new and emerging fraud threats throughout the life of this strategy.

Karin Smyth MP

Minister of State for Health (Secondary Care), Department of Health and Social Care

10 Year Health Plan

The government has a mission to create an NHS Fit for the Future through 3 shifts, from:

• hospital to community

• analogue to digital

• sickness to prevention

A strong counter-fraud response underpins these changes. Counter-fraud ensures that investment in infrastructure, technology and community‑based care is protected, secure by design and gives value.

Effective counter-fraud activity is required to provide a safe, modern and digitally enabled NHS.

Counter-fraud ensures that money goes to the front line to provide and improve services. It also ensures that money is not lost, maximising the impact of funding. Counter-fraud is also important in ensuring that any new scientific or technological development is providing value and results.

Organisational restructuring

The merger of DHSC and NHS England strengthens the approach to countering NHS fraud. Unifying strategic oversight, operational provision and policy will clarify and strengthen responsibility and accountability.

We will keep sight of emerging risks and address them. With clearer system governance, the merged organisation will foster an anti‑fraud culture, enhance visibility of threats and drive effective prevention, detection and enforcement.

The problem

In 2024 to 2025, DHSC spent £219.2 billion, including grants (£5.7 billion), estates (£8.1 billion), staffing (£0.3 billion) and procurement of services (£107.5 billion). This figure is only going to increase over the next Spending Review period.

Change, while vital to securing the future of the NHS, can create uncertainty and instability, leading to opportunities for fraudsters both internally and externally. It is therefore important to develop innovative and cost-effective solutions to tackle fraud and corruption.

Tackling health fraud is not only a financial imperative - it is essential to protecting patient services, maintaining ethical standards and upholding the NHS’s founding principle of equity in healthcare.

The cyber-enabled nature of many frauds and the methods used to launder the criminal proceeds often involve multiple jurisdictions. It is estimated that 67% of fraud reported in the UK is cyber-enabled. The emergence of artificial intelligence (AI) has added a new dimension to the risk and this is expected to grow in the future. This can lead to sophisticated and hard to detect attacks from both domestic and international actors.

International events can also impact the risk from fraud. We have learned from COVID-19 that we need to be prepared to act in the event of pandemics or any other national health crisis, but we know from experience there are many bad actors willing to take advantage of the situation. It is important we act quickly, carefully and proportionately in our response to such crises to maximise the value and impact of spending.

The NHS budget was over £192 billion for 2024 to 2025. Each year, the NHS Counter Fraud Authority (NHSCFA) carries out a strategic intelligence assessment (SIA). The SIA is an estimate of financial vulnerability to fraud, not a measure of actual fraud loss.

The latest SIA estimates £1.346 billion of NHS funding is vulnerable to fraud. Fraud is the most common crime in the UK, increasing by 8% to 4.4 million incidents, according to the Office for National Statistics. Fraud is likely under-reported, with embarrassment and its hidden nature being key reasons.

The NHS operates in a complex ecosystem across many organisations, which creates opportunities for exploitation. The cyber‑enabled nature of fraud, use of AI by criminals, jurisdictional complexity and international events (pandemics, emergencies) all increase risk.

Our response

Fraud is a hidden crime. You have to find it to fight it. We will build on the success of the last strategy to develop our ability to deter, prevent, detect and recover losses.

We will work across both the NHS, social care sectors and the wider health and social care landscape with a spirit of collaboration.

It is important that resources are used strategically and effectively. This strategy is explicitly informed by the fraud, bribery and corruption risk assessment across DHSC and its arm’s length bodies (ALBs), ensuring a risk‑led response.

Our actions will be aligned with several other organisations to ensure a strong, robust and consistent approach to counter-fraud.

We will align with the:

• National Audit Office (NAO) report on tackling fraud and corruption against government

• Public Sector Fraud Authority’s (PSFA) cross government counter fraud functional strategy 2024 to 2027

• UK government’s economic crime plan 2, 2023 to 2026

• UK government’s fraud strategy 2026 to 2029

The consistent themes running through functional standards and national strategies are:

• driving efficiency

• maximising prevention and detection (disruption)

• whole‑system approaches

• training, education and culture change

• data and technology

Mission

Our mission is to build a sustainable health and social care system fit for the future by tackling fraud to:

• protect taxpayers’ money
• safeguard patient care
• build trust

Vision

Our vision is a health and social care system where public money is protected by design, fraud risk is minimised and every pound spent contributes directly to safe, effective and equitable care.

By 2029, DHSC will be an even harder target for fraudsters with:

• ‘secure by design’ systems

• improved fraud risk assessment (FRA) coverage

• consistent compliance with government functional standard GovS 013: counter fraud, including across ALBs

• stronger analytics capability

• mature counter‑fraud culture

Statement

We will take an approach that tackles fraud and enables the provision of health and social care outcomes. We will embed counter-fraud by design, identify fraud and be innovative, open, collaborative and challenging.

Target

Our target is £600 million over the strategy period. This includes the whole health group and is supported by PSFA. It shows a positive return on investment, demonstrates ambition and is realistic based on past performance as a benchmark.

Figures contributing to this include prevented and recovered fraud and additional benefits such as sanctions and cost awards.

Delivery

DHSC will work to ensure we meet the standards in GovS 013: counter fraud. We will set direction through the DHSC Counter Fraud Board and integrate this with DHSC’s wider strategy.

DHSC policy units will support the progress of actions around the 10 Year Health Plan principles. We will be:

• innovative (shifting from analogue to digital and using AI for risk identification)

• collaborative (from hospital to community - fraud must be managed end to end)

• open (prevention over cure and embedding risk management early)

We will also assess threats annually and review strategy effectiveness regularly.

Objectives

We will build on the previous strategy, maximising skills and resources across the health sector and government. We will focus on improving our people, processes, tools and deterrents.

By 2029 we will be a hard target for fraudsters. To do this we have identified 4 areas to develop:

• prevention and detection

• building our people and culture

• whole system approach

• enforcement and recovery

While all are important, we will be focusing on preventing, detecting and recovering fraud as a key measure of our success and impact.

Prevention and detection

We will:

• develop robust assessments of fraud levels using initial fraud impact assessments (IFIAs), fraud risk assessments (FRAs) and data analysis

• use analytics and AI tools to identify anomalies

• take early preventative action

• embed secure by design principles

Measurement and metrics

To demonstrate continuous improvement, outcomes and measures will include:

• a completed programme of FRA, based on an annual FRA plan

• completion of the fraud loss measurement course, leading to at least one evidence-based fraud measurement exercise per year

• increasing the FRA coverage by at least 25% each year

• materials to support and implement secure by design as a clear design feature

Building our people and culture

We will:

• create a holistic culture, embedding counter-fraud values and ideas across the department

• modernise training by continuous monitoring and adapting to ensure it is relevant, proportionate and accessible, and focused on specific risk areas

• expand the counter-fraud champions network (policy-based staff who can give basic counter-fraud process advice to colleagues) to increase access to bespoke counter-fraud knowledge and advice

• embed counter fraud by design in policies and processes

Measurement and metrics

To demonstrate continuous improvement, outcomes and measures will include:

• a variety of training material that has clear links to trends and risks, with feedback surveys to show counter-fraud knowledge has increased

• continued development of the counter-fraud champions

• clear signposting of counter-fraud requirements in key departmental processes

• policies and processes embedding counter fraud by design

Whole system approach

We will:

• encourage senior counter-fraud buy-in and accountability beyond counter-fraud teams

• engage with PSFA to develop our staff to ensure skills are maintained and current

• ensure ALBs are overseen and accountable

• develop ALB counter-fraud capability and compliance with the functional standards

• share intelligence with government and departmental colleagues

Measurement and metrics

To demonstrate continuous improvement, outcomes and measures will include:

• improvement in meeting GovS 013: counter fraud

• regular reporting to the accountable board member and the DHSC Audit and Risk Committee (ARC)

• an increase in the number of staff across DHSC and its ALBs trained to meet the standards set within the government counter fraud professional standards and guidance: fraud risk assessment

• regular reporting from ALBs showing progress against objectives through PSFA compliant action plans

• increased capability across ALBs

• regular sharing and receiving of intelligence and other trend reporting with departmental teams and other government departments

Enforcement and recovery

We will:

• increase recovery of detected fraud

• review COVID‑19 spending

• ensure clear reporting routes

• increase use of sanctions on fraudsters, including disciplinary, civil or other legal routes

• seek greater legal powers to pursue and recover funds, such as inclusion in the Digital Economy Act 2017, and greater cross-agency collaboration

Measurement and metrics

To demonstrate continuous improvement, outcomes and measures will include:

• an increase in recovered losses

• an increase in actionable fraud reports

• an increase in positive action against those found to have committed fraud

• use of new legal powers, when granted

Additional key performance indicators and progress trajectory

In the first year, we will establish strong foundations to enable actions by embedding counter-fraud into core processes, improving data and insight and strengthening system oversight. This will include:

• delivering the departmental FRA plan

• increasing engagement across new areas of the department

• introducing or enhancing guidance to support secure by design principles

• developing our dashboard reporting to senior leaders

Alongside this, we will track some additional indicators to measure effectiveness and maturity. These include:

• quicker completion of FRA and IFIA

• reducing the number of overdue FRAs

• the progress of the action plan

• the extent to which counter-fraud is embedded in key departmental processes

We will also begin to track where insight from data, analytics and FRA leads to tangible control improvements.

In subsequent years, we will build on these foundations by increasing coverage, consistency and impact. This will include:

• expanding FRA coverage across the department

• strengthening the use of data and analytics to identify risks

• improving capability through targeted training and the development of the counter-fraud champions network

We will also work across the health system to improve alignment with functional standards and strengthen oversight of ALBs.

Over time, this will allow us to move from measuring activity and coverage to demonstrating impact, including stronger evidence of prevention, improved control environments, and increased recovery and enforcement outcomes.

Accountability

All staff in DHSC and every NHS body are both responsible and accountable for securing against fraud. Within DHSC, senior civil servants are responsible for ensuring the work their teams provide is fraud-proofed, their staff are trained and risk is assessed as part of the development and delivery process.

Fraud accountability in the NHS in England sits locally with providers and integrated care boards who are responsible for robust controls and compliance. NHSCFA investigates allegations of fraud, bribery and corruption in the NHS, and DHSC and NHS England provide oversight and assurance.

AFU will support DHSC policy teams by maintaining training material, templates and guidance, and provide quality assurance and advice for risk assessment and management. AFU will also maintain an annual action plan, laying out how we will carry out specific actions.

We will report to ARC and PSFA quarterly on progress. ARC, and ultimately the DHSC Permanent Secretary, will be accountable for DHSC counter-fraud work.

Conclusion

By 2029, DHSC will be more efficient, accountable, data driven and capable. Reducing opportunity by identifying and reacting quickly to risks will make the department and health service less attractive to fraudsters.

Annex: delivery roles

DHSC Anti-Fraud Unit

DHSC Anti-Fraud Unit (AFU) provides support and co-ordination in the development and provision of counter-fraud work and holds to account those responsible for actions. It has a team of investigators who are members of the Government Counter Fraud Profession (GCPF). Their role is to investigate allegations of fraud and corruption in DHSC. AFU also offers support to its ALBs where the health service is not affected.

AFU seeks to ensure that fraud prevention is built into DHSC policy development at the earliest possible stage and promotes awareness of fraud risks across the health group. AFU is a member of the Government Counter Fraud Function and is on the board of the GCPF.

As part of the wider cross-government counter-fraud agenda, AFU engages with PSFA and other government departments at a strategic level to prevent and deter fraud. AFU is also the departmental sponsor team for NHSCFA.

NHS Counter Fraud Authority

NHSCFA is a special health authority, established in November 2017. It carries out the Secretary of State’s counter-fraud functions in respect of the health service in England.

Over the course of the last DHSC counter-fraud strategy: 2023 to 2026, NHSCFA, working with partners, met its overall 3-year target of preventing, detecting and recovering £500 million of fraud.

NHSCFA is tasked to lead the fight against fraud, bribery and corruption in the NHS in England. NHSCFA acts as a repository for all information and intelligence related to fraud in the NHS and the wider health group. It also has oversight of and monitors counter-fraud work across the NHS. It will provide:

• strategic and tactical solutions to identified fraud risks

• counter-fraud standards

• comparative data to assess performance

Working together with our stakeholders, NHSCFA will drive improvement to the counter-fraud work that is undertaken across the NHS.

NHSCFA will collaborate with the NHS, DHSC and other relevant organisations to obtain better information and intelligence on the types of fraud the health group is exposed to and assist in putting in place effective measures to better prevent, deter and investigate fraud. NHSCFA will also be better equipped to provide valuable information to the health group on weaknesses and risks that can expose us to serious financial loss.

Arm’s length bodies

In addition to the counter-fraud work undertaken by NHSCFA and PSFA, other bodies at a national level such as NHS England, the NHS Business Services Authority (NHSBSA) and the UK Health Security Agency (UKHSA) routinely undertake activity to tackle fraud.

Since September 2021, it has been mandatory for all government departments and their ALBs to put in place a plan to comply with the government counter-fraud functional standards (GCFFS).

PSFA has developed a continuous improvement framework to provide consistent, comparable management information to support functional assurance and continuous improvement.

We continue to work with health ALBs to address areas for improvement and drive year on year improvements in compliance with the current standard.

Core national health ALBs have their own counter-fraud teams responsible for tackling fraud in their organisations. DHSC will continuously work with them to identify opportunities for further alignment of counter-fraud resources to make greater efficiencies or savings.

Government companies owned by the Secretary of State for Health and Social Care

These organisations, as limited companies, are regulated by the Companies Act 2006.

While they are not currently within scope of GCFFS, we are providing proactive advice and support to improve their counter-fraud capability, using the functional standards as a baseline.

Counter Fraud Board

Chaired by DHSC, the aim of the Counter Fraud Board is to bring together key national partners across health and the NHS, and assure urgency, pace and co-ordination in delivery of the counter-fraud agenda.

The board ensures a collaborative approach to its strategic oversight of the DHSC counter-fraud response, including the work of NHSCFA, NHS England, NHSBSA and UKHSA, ensuring it supports delivery of the DHSC counter-fraud strategy and that activity is co-ordinated to maximise progress against targets.

Counter Fraud Liaison Group

The Counter Fraud Liaison Group is chaired by NHSCFA. It brings together counter-fraud leads from each of DHSC’s ALBs and a representative from the companies owned by the Secretary of State for Health and Social Care, providing a forum and wider network to support each other.

Meeting each quarter, the group promotes best practice between organisations, and shares fraud risks that may affect other public health sector organisations and the wider health group. The aim is to set an engaging and relevant agenda, bringing in expert speakers from across government, including PSFA, which provides updates from the Cabinet Office.

Public Sector Fraud Authority

PSFA will provide oversight of our progress through our action plan. This plan will set out the actions designed to meet the objectives of this strategy, and our progress towards defined targets and metrics.

We will be expected to provide these updates on a quarterly basis and accept challenges on any targets or metrics.

Audit and Risk Committee

ARC provides independent challenge to hold DHSC’s senior leadership to account.

It challenges and assesses the robustness of how we manage financial and strategic risk, and checks if the department is meeting recommendations from NAO and Public Accounts Committee reports and investigations.

ARC’s responsibilities are to:

• consider the high-level risk register and the quality of DHSC risk management

• assess risks facing DHSC

• ensure that our risk management and internal control systems are effective

• consider our code of business conduct, including its policy on conflicts of interest and register of declared interests

• appraise anti-fraud policies, whistleblowing processes and arrangements for special investigations