Who Commissions NHS Dentistry in England?
NHS dental commissioning is the process of planning, buying, and monitoring NHS dental services for a population: deciding which practices hold NHS contracts, setting the Units of Dental Activity (UDAs) each contract must deliver, and managing performance against those contracts. The important thing for any practice owner or associate to understand in 2026/27 is who actually does that job, because it has changed.
Until 2023, primary dental care in England was commissioned by NHS England, operating through its regional teams. Since 1 April 2023, responsibility for commissioning primary dental care has been delegated to Integrated Care Boards (ICBs). This was part of a wider delegation of pharmacy, optometry, and dental (POD) commissioning to ICBs, on the back of the Health and Social Care Act 2022. NHS England still holds national accountability and sets the framework, including the national contract regulations, but the local job of holding and managing your contract now sits with your ICB.
An ICB is the statutory NHS body responsible for planning and funding most NHS services across a defined geography. There are around 40 ICBs across England, each covering an integrated care system. Within each ICB there is a dental commissioning function (often a small team rather than a large department) that manages the GDS and PDS contracts in its area.
For practice owners, this matters in a very practical way. When you need a contract variation, when your year-end UDA reconciliation is settled, or when you ask for consent to novate the contract on a sale, the body you are dealing with is now the ICB, not an NHS England regional office. For associates, the commissioning relationship sits one level up (with your principal and their ICB), but it still shapes the volume and stability of the NHS work available to you.
What Does the Chief Dental Officer (CDO) Actually Do?
The Chief Dental Officer (CDO) for England is the most senior dental adviser within NHS England and works closely with the Department of Health and Social Care. The CDO provides system-wide clinical and professional leadership for dentistry: setting the clinical strategy and vision for oral health, advising on dental policy and workforce, championing clinical standards, and representing the profession at a national level.
What the CDO does not do is commission or manage individual practice contracts. The CDO is not the person who sets your UDA target, approves your variation, or signs off a novation. Those are local commissioning decisions, and since 2023 they sit with your ICB. The CDO operates at the level of national clinical leadership and policy, which then shapes the framework within which local commissioners (the ICBs) work.
This distinction trips up a lot of practice owners, so it is worth stating plainly. When a national policy or reform is announced, the CDO and NHS England may be central to designing it. How that policy actually lands in your practice, and what it means for your contract value and targets, depends on how your ICB implements it locally. The national level sets direction. The local commissioner runs the contract.
Who Does What: A Quick Reference
The table below sets out the practical division of roles, so you know who to approach for what.
| Body | Role in NHS dentistry | What it means for you |
|---|---|---|
| Chief Dental Officer (CDO) | Clinical and professional leadership, national clinical strategy, policy advice, workforce, clinical standards | Shapes the national direction, but is not your contract contact. You do not approach the CDO about your contract. |
| NHS England | National framework and accountability, contract regulations, national oversight of commissioning | Sets the rules of the system. Day-to-day primary dental commissioning has been delegated to ICBs since April 2023. |
| Your Integrated Care Board (ICB) | Local commissioning: holds and manages GDS and PDS contracts, year-end reconciliation, variations, consent to novation | This is your commissioner. You deal with the ICB dental commissioning team for anything to do with your contract. |
| NHS Business Services Authority (NHSBSA) | Administration: processing UDA submissions, payments, year-end reconciliation calculations, pensions | Handles the mechanics and the numbers, but does not make commissioning decisions. |
| Local Dental Committee (LDC) | Statutory representative body for local NHS dentists | Represents the profession locally and can support you in dealings with the commissioner. Worth engaging with. |
What an ICB Does for Your Dental Contract
Your NHS contract in England is almost certainly a General Dental Services (GDS) contract, the standard open-ended contract that the large majority of practices hold. A minority hold a Personal Dental Services (PDS) agreement, which is time-limited and often used for specialist or local arrangements. Either way, the contract is held with the commissioner, and since 2023 that commissioner is normally your ICB.
The ICB dental commissioning team is responsible for the practical management of that contract through its life:
- Contract management and monitoring: tracking your UDA delivery against your contracted target across the year.
- Year-end reconciliation: settling the position at the end of the contract year. Where delivery falls within 96% to 100% of target, the small shortfall is generally carried forward into the next year rather than clawed back as cash; below 96%, the commissioner recovers the overpayment for activity not delivered. Track your UDA delivery monthly so there are no surprises at year-end.
- Variations: any change to the contract (for example a change to the UDA target, or to the parties named on the contract) needs the commissioner's consent in writing.
- Consent to novation on sale: when a practice is sold as an asset sale, the contract transfers by novation, which the commissioner must consent to. A share sale keeps the contract inside the company, so no novation is needed.
One point that is consistent across the whole system, regardless of who commissions: there is no national UDA value. Each contract's per-UDA value was set from a historic baseline and uplifted over time, so it varies from contract to contract. When you are reviewing your own arrangement, or assessing a practice you might buy, always work from the per-UDA value written into the specific contract, not from any assumed national figure.
What the Move to ICBs Means in Practice
If you have held an NHS contract for several years, the move to ICB commissioning will not have changed your contract terms. Your GDS or PDS agreement continues under the same regulations. What has changed is the body you deal with, and the local context in which decisions are made.
Your point of contact is local
The commissioning function now sits within an organisation that also plans and funds the wider health and care system in your area. In principle, the intention behind delegation was more joined-up, locally responsive commissioning. In practice, ICBs are still relatively new bodies and dental commissioning is one function among many they carry, so the level of dental expertise and the responsiveness of the team can vary by area. Knowing who your dental commissioning contact is, and building that relationship before you need a decision, is a genuinely useful business step.
Local decisions, national framework
Because decisions are local, two practices in different ICB areas can have a different experience of the same national policy. A reform announced nationally is implemented by each ICB within its own budget and priorities. This is why a practice's commissioning history and the relationship with its ICB are real factors in due diligence when buying or selling.
Sale and novation now run through the ICB
When you sell a practice as an asset sale, the buyer needs the contract novated to them, and that consent comes from the commissioner, now the ICB. Some commissioners treat a change of ownership as an opportunity to review the contract, so the novation step is one to plan for early rather than assume it is a formality. We cover this in detail in our guide on how to transfer an NHS dental contract on a practice sale.
The Financial Angle: Why the Commissioner Relationship Matters
Your NHS contract is the single document that sets your NHS income, so the body that manages it is directly relevant to your practice finances. Three points are worth holding in mind.
NHS income is VAT-exempt. The supply of NHS dental care is exempt from VAT, as is private dental treatment with a therapeutic purpose. This is a feature of the type of supply, not of who commissions it, so the move to ICBs does not change the VAT position. Where a practice also provides purely cosmetic treatment with no therapeutic purpose, that side can be standard-rated and a practice with both exempt and taxable income operates partial exemption. The commissioning structure does not affect this; it is governed by the nature of the treatment.
Your pensionable position follows your contract. For practitioners, NHS pensionable earnings derive from NHS-related income, which ultimately rests on the contract value. A commissioning decision that changes your contract value or UDA target therefore has a knock-on effect on pensionable earnings, so it is always worth modelling the pension impact before agreeing to any variation, not just the income impact.
Read the contract before you negotiate. Whether you are agreeing a variation, settling a year-end position, or pricing a practice you intend to buy, the starting point is understanding what the contract actually says: the UDA target, the per-UDA value, the contract type, and the reconciliation terms. Our companion guide on how to read your NHS dental contract walks through each of those terms in turn.
Commissioning Across the UK
This article focuses on England, where the ICB delegation has changed the commissioning landscape. The devolved nations operate under different structures. In Scotland, NHS dental services run under the item-of-service Statement of Dental Remuneration rather than UDAs, commissioned through NHS Boards. Wales and Northern Ireland each have their own contractual and commissioning frameworks. If you practise outside England, the principle that you deal with your local commissioner still holds, but the specific body and contract structure will differ, so check your own nation's arrangements and take regional-specialist advice.
Practical Steps for Practice Owners
- Identify your ICB dental commissioning contact and keep the relationship warm before you need a decision.
- Track UDA delivery against target monthly so year-end reconciliation holds no surprises.
- Treat any proposed variation as a financial decision: model the effect on income and on pensionable earnings before you sign.
- If you are planning a sale, raise the novation early with the commissioner rather than treating it as a closing-day formality.
- Consider engaging with your Local Dental Committee to stay informed and to have representation in dealings with the commissioner.
- Read your contract closely, and keep the distinction clear: the CDO sets national direction, the ICB runs your contract.
The Bottom Line
NHS dental commissioning in England is now a local job. Since April 2023 it has been delegated to Integrated Care Boards, with NHS England holding the national framework and accountability, and the Chief Dental Officer providing clinical and professional leadership rather than managing contracts. For you as a practice owner, that means your ICB is the commissioner you deal with for variations, reconciliation, and consent on sale, while your GDS or PDS contract continues under the same rules with no national UDA value.
The commissioning relationship is part of the financial fabric of an NHS practice, and it is one that rewards being informed and prepared. For tailored advice on how your NHS contract and commissioning relationship affect your practice finances, including on a purchase or sale, speak to a dental-specialist accountant. Contact our team at Dental Finance Partners for a confidential discussion.