NHS integrated care boards are not large NHS trusts. They commission differently, use a different legal framework for healthcare services, and make decisions at a level of strategic abstraction that means a supplier pitch focused on product features will almost always miss the point.

NHS integrated care boards are not large NHS trusts. They commission differently, use a different legal framework for healthcare services, and make decisions at a level of strategic abstraction that means a supplier pitch focused on product features will almost always miss the point.

Understanding how ICBs buy, who makes commissioning decisions, and what they are trying to achieve before approaching one is the difference between a conversation that goes somewhere and one that loops indefinitely.

Understanding how ICBs buy, who makes commissioning decisions, and what they are trying to achieve before approaching one is the difference between a conversation that goes somewhere and one that loops indefinitely.

How ICBs commission differently to NHS trusts

NHS trusts procure goods and services under the Procurement Act 2023. ICBs commission healthcare services under a different regime: the Health Care Services (Provider Selection Regime) Regulations 2023, which came into force on 1 January 2024.

NHS trusts procure goods and services under the Procurement Act 2023. ICBs commission healthcare services under a different regime: the Health Care Services (Provider Selection Regime) Regulations 2023, which came into force on 1 January 2024.

The Provider Selection Regime was specifically designed to give ICBs flexibility in how they select service providers, based on what is best for patients and communities rather than what a standard competitive tender process would produce. It allows ICBs to use direct award routes, to continue with existing providers where the service is performing well, and to run competitive processes only when the circumstances justify them.

The Provider Selection Regime was specifically designed to give ICBs flexibility in how they select service providers, based on what is best for patients and communities rather than what a standard competitive tender process would produce. It allows ICBs to use direct award routes, to continue with existing providers where the service is performing well, and to run competitive processes only when the circumstances justify them.

For suppliers, this has a specific implication. With NHS trusts, procurement tends to follow a recognisable pattern: requirement defined, tender published, bids submitted, contract awarded. With ICBs, particularly for clinical and community health services, the decision about whether to run a formal competitive process, who is eligible to participate, and on what basis a provider will be selected is itself a commissioning decision that happens before any formal procurement begins. A supplier who only engages at the point of a published notice has missed the part of the process where the most commercially significant decisions were made.

For suppliers, this has a specific implication. With NHS trusts, procurement tends to follow a recognisable pattern: requirement defined, tender published, bids submitted, contract awarded. With ICBs, particularly for clinical and community health services, the decision about whether to run a formal competitive process, who is eligible to participate, and on what basis a provider will be selected is itself a commissioning decision that happens before any formal procurement begins. A supplier who only engages at the point of a published notice has missed the part of the process where the most commercially significant decisions were made.

What ICBs are trying to achieve in 2026

NHS England's strategic commissioning framework, which ICBs are expected to adopt from 2026/27, sets out four stages: understanding the context, developing a long-term population health strategy, delivering through the payor function and resource allocation, and evaluating impact.

NHS England's strategic commissioning framework, which ICBs are expected to adopt from 2026/27, sets out four stages: understanding the context, developing a long-term population health strategy, delivering through the payor function and resource allocation, and evaluating impact.

The framework is explicit that ICBs should operate at a strategic level, leaving operational design to providers. It emphasises population health data, health inequality reduction, and outcome-based commissioning over activity-based contracts. It expects ICBs to commission across pathways of care, at place and neighbourhood level, often in partnership with local government.

The framework is explicit that ICBs should operate at a strategic level, leaving operational design to providers. It emphasises population health data, health inequality reduction, and outcome-based commissioning over activity-based contracts. It expects ICBs to commission across pathways of care, at place and neighbourhood level, often in partnership with local government.

Reading this framework before approaching an ICB surfaces three specific things to consider:

Reading this framework before approaching an ICB surfaces three specific things to consider:

1. The buyer is thinking about people.
2. They are looking for providers who can demonstrate impact on outcomes, not just capability to deliver a service.
3. They are operating in partnership with local councils and other system partners, which means the commissioning decision may not sit entirely within the ICB itself.

A commercial conversation that addresses population-level outcomes, pathway integration, and partnership with local government is a fundamentally different conversation to one that describes a product's features. ICBs are commissioning solutions to population health problems they have already defined from data.

A commercial conversation that addresses population-level outcomes, pathway integration, and partnership with local government is a fundamentally different conversation to one that describes a product's features. ICBs are commissioning solutions to population health problems they have already defined from data.

Who actually makes ICB commissioning decisions

ICB decision-making structures vary across the boards, but several roles are consistent across them.

ICB decision-making structures vary across the boards, but several roles are consistent across them.

The Chief Executive has overall accountability for provider selection and procurement decisions. The Director of Finance has responsibility for the processes through which those decisions are made. But the people who shape what gets commissioned, and who therefore shape the specification before any formal process begins, sit across clinical, strategy, and population health functions.

The Chief Executive has overall accountability for provider selection and procurement decisions. The Director of Finance has responsibility for the processes through which those decisions are made. But the people who shape what gets commissioned, and who therefore shape the specification before any formal process begins, sit across clinical, strategy, and population health functions.

Place-based directors and system leads are increasingly significant. Under the strategic commissioning model, ICBs commission at place level, meaning the relevant decision-makers for a community mental health service or a digital primary care tool may be at place rather than ICB board level. Understanding the geography of an ICB's commissioning structure, and which place-based teams are responsible for the categories relevant to your offer, is commercially more useful than knowing who the Chief Executive is.

Place-based directors and system leads are increasingly significant. Under the strategic commissioning model, ICBs commission at place level, meaning the relevant decision-makers for a community mental health service or a digital primary care tool may be at place rather than ICB board level. Understanding the geography of an ICB's commissioning structure, and which place-based teams are responsible for the categories relevant to your offer, is commercially more useful than knowing who the Chief Executive is.

Joint commissioning with local government adds further complexity. ICBs are expected to commission in partnership with local authorities for integrated community and social care services. In some systems, this means the commissioning decision-maker for a category you sell into is a joint committee of NHS and council representatives, not the ICB alone. A supplier who has not mapped the local government partnership before a meeting is likely to discover in that meeting that the conversation cannot conclude without the council's involvement.

Joint commissioning with local government adds further complexity. ICBs are expected to commission in partnership with local authorities for integrated community and social care services. In some systems, this means the commissioning decision-maker for a category you sell into is a joint committee of NHS and council representatives, not the ICB alone. A supplier who has not mapped the local government partnership before a meeting is likely to discover in that meeting that the conversation cannot conclude without the council's involvement.

How to read what an ICB is planning before any procurement begins

What an ICB is planning before a formal procurement exists is visible in three sources.

What an ICB is planning before a formal procurement exists is visible in three sources.

1. Joint Forward Plans

   Joint Forward Plans

Every ICB publishes a Joint Forward Plan, updated annually, which describes their five-year priorities for health service development in their area. These plans name the service areas they intend to develop, the populations they are focusing on, and in many cases the commissioning intentions that will generate procurement activity over the plan period. A supplier whose offer connects to a priority named in an ICB's Joint Forward Plan has a hook for every conversation with that ICB before a single procurement notice is published.

Every ICB publishes a Joint Forward Plan, updated annually, which describes their five-year priorities for health service development in their area. These plans name the service areas they intend to develop, the populations they are focusing on, and in many cases the commissioning intentions that will generate procurement activity over the plan period. A supplier whose offer connects to a priority named in an ICB's Joint Forward Plan has a hook for every conversation with that ICB before a single procurement notice is published.

1. Board and committee papers

   Board and committee papers

ICB board papers are published publicly, typically monthly, on the ICB's own website. They contain references to planned commissioning exercises, provider performance data that may signal re-procurement, budget allocations for new service areas, and strategic partnership discussions with local government.

ICB board papers are published publicly, typically monthly, on the ICB's own website. They contain references to planned commissioning exercises, provider performance data that may signal re-procurement, budget allocations for new service areas, and strategic partnership discussions with local government.

Reading them before a meeting tells you what the board has been discussing, what priorities have received budget approval, and where the system is planning to develop services. Our guide to what public sector board papers tell suppliers covers the practical approach to reading these documents systematically.

Reading them before a meeting tells you what the board has been discussing, what priorities have received budget approval, and where the system is planning to develop services. Our guide to what public sector board papers tell suppliers covers the practical approach to reading these documents systematically.

1. Preliminary market engagement notices

   Preliminary market engagement notices

Before a formal procurement begins, ICBs conducting above-threshold procurements are required under the Procurement Act 2023 to publish preliminary market engagement notices for goods and non-healthcare services. For healthcare services under the Provider Selection Regime, market engagement may be conducted informally or through published market engagement exercises.

Before a formal procurement begins, ICBs conducting above-threshold procurements are required under the Procurement Act 2023 to publish preliminary market engagement notices for goods and non-healthcare services. For healthcare services under the Provider Selection Regime, market engagement may be conducted informally or through published market engagement exercises.

Both appear, where they are published, on Find a Tender or the ICB's own procurement portal. Responding to a market engagement exercise is the formal mechanism for influencing a specification before it is written. It is also one of the most consistently underused commercial levers available to NHS suppliers.

Both appear, where they are published, on Find a Tender or the ICB's own procurement portal. Responding to a market engagement exercise is the formal mechanism for influencing a specification before it is written. It is also one of the most consistently underused commercial levers available to NHS suppliers.

What the ICB merger means

England's ICB structure is currently in transition. The government announced plans to merge the 42 ICBs into approximately 26 boards, with the first mergers taking effect from April 2026 (they have now been merged into 36 boards) and further decisions expected through 2026/27. Most merged ICBs are developing new integrated commissioning strategies that reflect the combined priorities and geographies of their predecessor organisations.

England's ICB structure is currently in transition. The government announced plans to merge the 42 ICBs into approximately 26 boards, with the first mergers taking effect from April 2026 (they have now been merged into 36 boards) and further decisions expected through 2026/27. Most merged ICBs are developing new integrated commissioning strategies that reflect the combined priorities and geographies of their predecessor organisations.

For suppliers with existing ICB relationships, this transition creates a specific commercial risk. A relationship built with a commissioning team in one of the predecessor ICBs may not automatically transfer to the merged board. The procurement contacts, the strategic priorities, and the commissioning structures are all being reset. A supplier who does not know which of their target ICBs is merging, on what timeline, and what the successor structure looks like is working from an outdated map.

For suppliers with existing ICB relationships, this transition creates a specific commercial risk. A relationship built with a commissioning team in one of the predecessor ICBs may not automatically transfer to the merged board. The procurement contacts, the strategic priorities, and the commissioning structures are all being reset. A supplier who does not know which of their target ICBs is merging, on what timeline, and what the successor structure looks like is working from an outdated map.

Tracking which ICBs are merging, and building relationships with the relevant contacts in successor boards before the merger takes full effect, is one of the most time-sensitive commercial activities for any supplier with an ICB-focused pipeline. NHS spend transparency data, which shows which ICBs are actively spending in your category, tells you which boards to prioritise as their commissioning structures consolidate. See our guide to what NHS spend data tells you about where to sell next.

Tracking which ICBs are merging, and building relationships with the relevant contacts in successor boards before the merger takes full effect, is one of the most time-sensitive commercial activities for any supplier with an ICB-focused pipeline. NHS spend transparency data, which shows which ICBs are actively spending in your category, tells you which boards to prioritise as their commissioning structures consolidate. See our guide to what NHS spend data tells you about where to sell next.

What a good first conversation with an ICB looks like

The purpose of a first conversation with an ICB is not to sell a product. It is to understand their commissioning priorities well enough to know whether your offer is relevant, and to establish your organisation as a credible participant in their thinking before a formal requirement is defined.

The purpose of a first conversation with an ICB is not to sell a product. It is to understand their commissioning priorities well enough to know whether your offer is relevant, and to establish your organisation as a credible participant in their thinking before a formal requirement is defined.

A first conversation that works tends to do several things:

A first conversation that works tends to do several things:

• It references the ICB's own published priorities — their Joint Forward Plan, their population health data, their stated system ambitions — rather than a generic description of what the supplier does.

  It references the ICB's own published priorities — their Joint Forward Plan, their population health data, their stated system ambitions — rather than a generic description of what the supplier does.

• It asks questions about how the system is approaching a specific population health challenge rather than describing product capabilities.

  It asks questions about how the system is approaching a specific population health challenge rather than describing product capabilities.

• It establishes familiarity with the relevant commissioning team and framework, whether that is the Provider Selection Regime for healthcare services or the Procurement Act for goods and digital infrastructure.

  It establishes familiarity with the relevant commissioning team and framework, whether that is the Provider Selection Regime for healthcare services or the Procurement Act for goods and digital infrastructure.

Keeping the register conversational matters too. ICBs engage with many suppliers simultaneously across multiple commissioning programmes. The ones they invite back, and the ones they ask to contribute to preliminary market engagement, are the ones who demonstrated genuine understanding of the system's challenges rather than generic commercial intent.

Keeping the register conversational matters too. ICBs engage with many suppliers simultaneously across multiple commissioning programmes. The ones they invite back, and the ones they ask to contribute to preliminary market engagement, are the ones who demonstrated genuine understanding of the system's challenges rather than generic commercial intent.

For the practical preparation that goes into a meeting with an NHS organisation, our guide to how to research an NHS trust before a sales meeting covers much of the same ground for ICBs: checking spend data, reviewing board papers, mapping commissioning contacts, and understanding the strategic priorities before the conversation begins. The same discipline applies, with the additional layer of the Provider Selection Regime and the joint commissioning partnership structures that are specific to ICBs.

For the practical preparation that goes into a meeting with an NHS organisation, our guide to how to research an NHS trust before a sales meeting covers much of the same ground for ICBs: checking spend data, reviewing board papers, mapping commissioning contacts, and understanding the strategic priorities before the conversation begins. The same discipline applies, with the additional layer of the Provider Selection Regime and the joint commissioning partnership structures that are specific to ICBs.

Building ICB pipeline as a long-cycle discipline

ICB commissioning cycles are long. A priority identified in a Joint Forward Plan in 2025 may not generate a formal commissioning exercise until 2027. An informal market engagement in 2026 may lead to a formal procurement in 2028. The suppliers who build strong ICB pipelines treat this as a feature rather than a problem, early engagement in a long cycle is an advantage, not a delay.

ICB commissioning cycles are long. A priority identified in a Joint Forward Plan in 2025 may not generate a formal commissioning exercise until 2027. An informal market engagement in 2026 may lead to a formal procurement in 2028. The suppliers who build strong ICB pipelines treat this as a feature rather than a problem, early engagement in a long cycle is an advantage, not a delay.

The commercial discipline is straightforward:

The commercial discipline is straightforward:

1. Map your target ICBs from spend data and commissioning intelligence
2. Read their Joint Forward Plans and board papers on a regular schedule
3. Track preliminary market engagement exercises in your category
4. Build relationships with place-based commissioning leads, not just ICB board-level contacts.
5. Monitor the merger timeline to ensure your target account list reflects the structure that will actually exist in twelve months.

The ICBs commissioning in your category are publicly accountable organisations. Their plans, priorities, and commissioning intentions are published. A supplier who reads and acts on them early — before anyone else does — has an advantage that is not available at the tender stage.

The ICBs commissioning in your category are publicly accountable organisations. Their plans, priorities, and commissioning intentions are published. A supplier who reads and acts on them early — before anyone else does — has an advantage that is not available at the tender stage.

Arcamus tracks ICB spend data, commissioning signals, and contract award data across all NHS integrated care boards, giving commercial teams a current picture of which ICBs are active in their category and where procurement is planned. See what's happening in your target ICBs.

Arcamus tracks ICB spend data, commissioning signals, and contract award data across all NHS integrated care boards, giving commercial teams a current picture of which ICBs are active in their category and where procurement is planned. See what's happening in your target ICBs.