What do the NHS contract changes and CMA review mean for dental practices?

From April 2026, the biggest changes to the NHS dental contracts in two decades are set to take effect, reshaping urgent care delivery, funding for complex patients, and how prevention is prioritised. Simultaneously, private dentistry is under the spotlight, with the Competition and Markets Authority (CMA) launching a market review that could potentially heighten standards around fair pricing and patient communication.

This blog outlines the main changes to the NHS contract, who is most likely to feel the impact, and what the new urgent care and complex care pathways mean in practical and financial terms. It also explores the CMA review, focusing on its significance for practice owners and clinicians working in private or mixed settings.

How could the NHS contract changes affect different dental professionals?

The NHS dental contract changes, coming in from 1 April 2026, are the most significant since the current contract was introduced in 2006. They aim to build on the reforms announced in June 2022, including a new mandatory requirement for urgent care delivery, fixed-fee pathways for complex patients, a stronger push towards prevention, and funded quality and appraisal schemes.

It is crucial to note that these reforms come with no new investment, the government describes them as a redistribution of the current contract base.

This also means the impact will vary. Practices already delivering high levels of urgent and complex care may see their income better reflect their workload, while those built around routine check-ups on regularly attending patients could see reductions in revenue.

What are the main NHS contract changes?

Urgent and unscheduled care

From 1 April 2026, dental providers must deliver 8.2% of their contract value as unscheduled care activity in 2026/27, a value equal to 11 courses of treatment per £10,000 of negotiated annual contract value (NACV).

This is accompanied by a new £75 payment, displacing the existing 1.2 UDAs for unscheduled care. The fee will be split into two parts: 1) a £15 fixed credit per required course of treatment 2) a £60 activity credit per delivered course of treatment.

Courses of treatment above the required number earn a £75 credit, which converts to UDAs at the provider’s nominal value and is recorded in the NHS BSA system. Furthermore, providers excluded from the 8.2% requirement who get 1.2 UDAs for unscheduled care will also receive a £75 credit per treatment, converted to UDAs as above. Separate contracts for unscheduled care remain unaffected.

Overall, these changes will mean contract holders face two separate delivery targets: the 8.2% urgent care element, and the remaining 91.8% for routine/complex care.

Complex care pathways

Three new holistic care pathways will be introduced from June 2026:

Pathway Eligibility criteria Payment
1 ≥5 teeth with caries into dentine, no periodontal disease £284
2 ≥5 teeth with caries into dentine, currently unstable periodontal disease £709
3 New diagnosis of Grade C periodontal disease £248

 

Although a commencement date hasn’t been set, providers will have the opportunity to enrol patients on these pathways and earn monthly credits at the rates mentioned above. These credits will then be converted into UDAs based on the provider’s nominal value. Monthly reports will also be necessary to receive the credits.

The pathways will be implemented to fulfil the government’s aim of providing fairer funding for patients with significant care needs.

Prevention and skill-mix

Several changes are expected to move away from treatment, and towards clinical prevention, including:

  • Fluoride varnish: A new sub-band 1 course of treatment (0.5 UDAs) will enable suitably trained dental nurses to apply fluoride varnish for children between examinations.
  • Fissure sealants: Re-categorised from Band 1 to Band 2, payable at 3 or 5 UDAs depending on number of teeth affected.
  • Denture modifications: A new Band 2a sub-band at 3 UDAs for standalone modifications, and denture repairs increased to 2 UDAs.

Quality improvement and appraisals

  • Quality improvement programme: Providers can choose to register for this programme, which aims to enhance the clinical appropriateness of recall intervals. Participating practices receive £3,400 per year but must register by 8 May 2026.
  • Funding appraisals: £213 per eligible clinician (associate dentists, therapists, hygienists, including locums) on completion of annual appraisal.

What is the CMA review of private dentistry?

On the 5th of March, The CMA launched a market review of private dentistry, a sector now worth around £8.4 billion and representing roughly 69% of UK dental spending.

​The review aims to look at how patients find and compare providers, whether pricing is transparent and justified, and how treatment options are communicated, including cosmetic and elective work.

For practice owners, this could lead to more rigid expectations around fee transparency, advertising and consent, particularly where margins are highest. For associates and clinicians on private fee-sharing or bonus arrangements, any future pressure on pricing could also affect personal earnings. Membership and plan-based models may also face closer scrutiny on how they are structured and presented.

​No regulatory changes have been announced yet, but the intended direction is clear. Practices with consistent, well-documented pricing and strong patient communication are well-positioned. Where private fee structures are inconsistent or lack clear justification, it is advisable to undertake a thorough review, preferably with an expert, ahead of the publication of the CMA’s findings.

What steps can practices and professionals take now?

Review your income mix.

Understand the current split between NHS and private income, and how much of your NHS work is routine versus urgent or complex. This is the starting point for assessing how the contract changes will affect you.

Model different scenarios.

Work with your accountant to stress-test your 2026/27 income under the new contract structure, particularly the dual-target requirement for urgent care and the potential reduction in routine check-up volumes.

Audit your private pricing.

Map out your key private income streams, identify where pricing is variable or hard to justify, and consider how it would hold up under greater scrutiny.

Check your patient communication.

Make sure treatment options, fees and consent processes are clear and well-documented, both for compliance and for building patient trust.

Review your long-term plan.

Whether you’re looking to grow, consolidate, or eventually sell, these changes alter the financial picture. Your NHS-private balance, earnings quality and regulatory exposure all feed into practice value and lender confidence.

Closing thoughts

The practices and professionals who come through these changes in the strongest position will be the ones who plan early rather than react late. If you’d like to talk through what the reforms mean for your specific situation, get in touch with our specialist dental accounting team using the form below.

We always recommend that you seek advice from a suitably qualified adviser before taking any action. The information in this article only serves as a guide and no responsibility for loss occasioned by any person acting or refraining from action as a result of this material can be accepted by the authors or the firm.

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