Health in the UK after Brexit: Moving apart or stuck together?

With the support of the Health Foundation, the Health and International Relations Monitor project explores how the dramatic changes to UK international relations following Brexit have affected the UK’s new ability to regulate everything from its neighbours, from trade and institutional ruptures to medicine to travel differently.

This report, the final in the series, provides updates based on data and legal analysis on drug supply issues, staff movement, and procurement issues. The new reality after leaving the single market continues to be linked to rapid change.

We also look at four areas of less important to health, meaning Brexit’s new course in the UK: artificial intelligence (AI), fundraising, specialized qualifications and patients moving across borders. He held the London and Austrian roundtable together with industrial industries, regulators and experts, exploring AI regulations in depth.

NHS and Social Care Experts

• Following Brexit, the UK continues to rely heavily on the extremely high migration of medical staff from outside the EU. In the UK, two-thirds of registered nurses have come from staff trained outside the UK or the European Economic Area (EEA) since their exit from the Single Market due to the end of 2020.
• By November 2024, one in 11 (9%) of all NHS doctors in the UK had retained nationality from one country listed by the World Health Organization (WHO) and a lack of staff members that other countries should not employ.
• Following a sudden tightening of policy, the recent collapse of inward movements of social care workers shows just how unstable this approach is without EU rights stability.
• The UK is in the course to be meaningfully distributed by reducing the number of clinical training hours required for nurses to qualify to fall significantly below what EU law requires. This is not outside the scope required by other comparable countries, but it may rule out the possibility of reestablishing mutual recognition of nursing qualifications with the EU.

Procurement and drug supply

• The high medical shortage and troublesome levels noted in previous reports in this series continue with no indication of improvement in key indicators. We previously concluded that this was not primarily due to Brexit, and that other EU countries are also suffering from substantial shortages. However, data now confirm that the UK has the lowest growth rate of G7 drug imports due to reduced EU imports. This shows the specific impact of leaving the EU.
• The UK’s Procurement Act of 2023 is moving procurement away from EU law. Carveout frees the English NHS from the requirements to go through many full sourcing processes, a requirement created by unique attempts to operate the market within public services since the 1990s.
• Also, rather than simply using the lowest offers, they create some space to prioritize local business and social and environmental goals. However, this is not the case that some people wanted to limit the space for corruption and exploitation by their suppliers.

The UK is forking from the EU with its approach to AI regulation

• The UK has taken a fundamentally different approach to AI regulation, against the AI ​​law passed by the EU last year. While EU law creates a system that classifies and evaluates all uses of AI, the UK has directed regulators in each sector to take their own approach based on shared principles.
• Rhetorically, the EU emphasizes security and protection of rights, but the previous UK government emphasized its openness to innovation and its desire to attract investors. However, in reality, for AI systems aimed at treating or diagnosing as medical devices, the UK and EU systems primarily share technical standards.
• The cost of business that has to follow two systems remains a problem for the UK of AI medical devices, even if they are similar. If divergence increases over time due to different EU regulations principles, AI companies feel pressure to prioritize standards in a much larger EU market (the “Brussels effect”), at least, even if some people look at the rules.
  It’s more burdensome than UK regulations.
• If the UK follows plans to stop recognition of EU medical devices approvals in 2030, this will either accept the costs of additional regulatory systems or stand up to companies producing new products with a sharp choice that doesn’t serve the market in the UK.
• As it is based on separate types of products, there is no obvious way to deal with AI systems intended to be used in this way. It is becoming more and more common as generative systems, including medical professionals, are used throughout society. Open AI’s GPT-4.5 is not sold as a medical device,
  There is no doubt that both patients and experts use it occasionally to inform their diagnosis.

There is no single strategy for health and Brexit in the UK

• Five years after leaving the EU, the UK has adopted a very diverse approach to divergence in law and regulations. In many areas it either sticks to inherited EU law or actively imitates its large neighbours. However, in sourcing, staff training, and AI, we made different choices, but the degree of differences is often exaggerated. Meanwhile, the UK is struggling to find a new balance due to migration, medicine and funding.
• In all these areas, constant change in technology and EU law and policy means that it is not a policy issue that Brexit can solve, but a source of continuous tension and pressure. For sectors that frequently include international trade, including AI, divergence generates intrinsic costs from companies that comply twice. This creates the present disadvantages that exist to the essential advantages.
• The UK’s various strategies in key areas of health policy will complicate the fundamental move to reorganize with the EU, despite being a favorable approach in other policy areas.