The financial vulnerability estimate has decreased since last year however; this is not indicative of a decrease in threat and is due to a change in data parameters.
Emerging trends and prevalent threats
Individuals returning to or entering the UK to access secondary care services without charge, including to access maternity services is highly likely. Maternity treatment in the UK is categorised as ‘urgent and necessary’ meaning costs are recovered after the treatment and not before.
£96.5m
vulnerable from an expenditure of £2bn
It is also likely that individuals will misuse visas in order to access NHS services. Intelligence suggests individuals have entered the UK on a visa specifically to access medical treatment.
Countries travelled from to the UK to access secondary care without charge
Individuals who are not ordinarily resident falsely representing themselves to gain access to NHS secondary care without charge whilst in the UK is highly likely.
It is a realistic possibility that individuals may falsify information in order to falsely claim reimbursement under the Immigration Health Surcharge (IHS) scheme. Individuals can apply online for a refund for IHS fees if they work in a healthcare setting such as a hospital, GP practice, care home or community healthcare facility. They must have worked in the role for at least 6 months and for an average of 16 hours a week.
Individuals receiving primary care, including prescriptions, whilst residing abroad is a prominent threat. Primary care is free at the point of delivery for everyone in England, however if moving abroad permanently you should notify the GP practice to be removed from the NHS register.
Furthermore, former and current British citizens permanently residing abroad but travelling back to the UK for primary and secondary care services is likely.
It is a realistic possibility that individuals are travelling to specific airports to avoid detection by border force and to gain access to the UK for NHS treatment.
PESTLE analysis
Political: Stricter student visa checks from 2025 may reduce abuse of the visa system, including cases where applicants are not genuinely studying.
Economic: Changes to healthcare eligibility and potential tariff-related healthcare cost increases in the United States of America (USA) may result in the continued increase in US citizens seeking NHS secondary care without paying.
Social: It has been reported that the number of paediatric invoices is rising in trusts as parents of babies being born in the UK fail to apply to regularise the child’s stay in the UK.
Technological: With advances in AI, it may be possible for individuals to forge identity documents such as passports or visas to fraudulently gain access to NHS services.
Legal: UK visa rule changes, including higher skilled worker thresholds and tougher English-language requirements, may reduce overseas visitors and dependants entering the UK.
Media Factors: The media reported a drop in UK visa applications in the last year as stricter immigration rules have been introduced, suggesting stricter immigration rules are already affecting net migration.
Reporting
During this reporting period, the NHSCFA received 544 reports compared to last year’s total of 396. Higher levels of international travel may have increased the opportunities for fraud to occur, the estimated number of inbound visits to the UK is estimated to have risen to 43.4 million in 2025 from 39.5 million in 2024, potentially creating an increase in reports.
| Thematic area | 2020-21 | 2021-22 | 2022-23 | 2023-24 | 2024-25 | 2025-26 |
|---|---|---|---|---|---|---|
| Fraudulent access | 290 | 310 | 296 | 406 | 396 | 544 |