Category Archives: Government

Portrait of Stephen Brine - Uk Parliament Official

The Rare Diseases Action Plan: A refreshing focus on implementation

GK Strategic Adviser and former health minister Steve Brine examines the government’s new Rare Diseases Action Plan and its impact on people living with rare diseases. 

As someone who has spent many years engaged with health policy, both inside and outside government, I was genuinely heartened to see the England’s Rare Diseases Action Plan published to mark Rare Disease Day last month.

This fifth annual plan builds on the UK Rare Diseases Framework and sets out clearly how we intend to turn the strategic priorities I first produced as the minister into real improvements in people’s lives.

Rare diseases may, individually and as the name suggest, be uncommon – but collectively they affect a significant number of people – and even more indirectly via family members.

I have always been acutely aware how too many families face what is heartbreakingly called a ‘diagnostic odyssey’; years of uncertainty, multiple referrals, and repeated explanations before a condition is recognised and understood.

This isn’t just about medicine; it’s about dignity, continuity of care, and basic fairness across the NHS.

The new 2026 Action Plan wisely positions itself as a practical implementation of the Rare Diseases Framework’s four core priorities:

  • helping patients get a final diagnosis faster
  • increasing awareness of rare diseases among healthcare professionals
  • better coordination of care; and
  • improving access to specialist care, treatment and drugs.

But it does much more than repeat them, it brings them to life in the context of the Government’s 10 Year Plan for the NHS in England.

At its core, the plan seeks to show how system-wide reform – from digital transformation to community-based care – can make a real difference for people living with rare conditions.

One of the most meaningful aspects of this year’s plan is its emphasis on health equity, something ministers often say is central to their health mission.

For too long, people living with rare diseases have experienced variation in the care they receive, depending on where they live or what their condition is.

This is not unique to this cohort of patients of course but, for the first time in an action plan of this kind, the system explicitly recognises rare disease as a health inequality, and commits to addressing this through better data, targeted improvement work, and integration with NHS England’s longstanding approach to tackling inequalities.

This marks an important shift – one that sits right at the heart of a modern health service, and was important to me when drawing together the original priorities.

On the diagnostic front, progress is evident but needs to go further and faster.

The NHS Genomic Medicine Service now delivers genomic testing for more than 7,000 rare conditions, and there’s a renewed focus on significantly shortening that ‘odyssey’.

The re-procurement of the NHS Genomic Medicine Service (GMS) from April 2026 is welcome as is the suggestion, something I wish I had been able to do, the new contracts will give certainty and run for ten years from this spring.

What this renewed GMS should deliver is a forward-looking contract which embeds genomic technology into standard clinical pathways and, in-turn, makes a positive impact on diagnosis delays.

Last year also saw the establishment of pilot clinics for people with undiagnosed rare diseases that bring many more services ‘under one roof’.

Two of these pilot centres – one in the north and one in the south of England – are expected to be operational by autumn 2026. Their purpose is simple but should make a big difference; to give people who have exhausted standard lines of diagnosis a new path to understanding what’s wrong. This brings vital hope.

Coordination of care remains a longstanding challenge for people with rare conditions, for whom the term comorbidity was coined. This requires input from a range of specialists and can be very challenging for a health system such as the NHS.

To answer this, NHS England is looking at models of care that support rare disease collaborative networks (28 of which now exist) to join things up and bring that consistency across services.

Another significant advance is the work being done on so-called ‘novel’ therapies.

Regulators like the Medicines and Healthcare products Regulatory Agency have made commitments to change how rare therapies are treated, with a view to facilitating more timely access to the latest treatments.

These are the sorts of advances that not only push scientific boundaries, but also give real hope to individuals and families living with rare conditions. We need to see, soon, the first patient treated by one of these therapies to keep momentum in this space.

Of course, none of this has happened by accident. Central to the 2026 Action Plan’s development and delivery has been the voice of the rare disease community.

I launched the ‘National conversation on rare diseases’ in 2019 which gathered over 6,000 responses across the UK and directly informed the four priorities being settled upon.

This time, patient organisations, clinical experts and charities seem to have again provided insight, and lived experience, ensuring the new plan lands with the credibility it must have to be successful.

I have tried to be positive in this piece – and there is much to be positive about – but we shouldn’t fool ourselves there isn’t a LOT of work to be done.

Today, only around 5 % of rare conditions have an approved and effective treatment, and for too many people the journey towards diagnosis is more long wandering road than ‘odyssey’ which suggests an adventure eventually leading somewhere good.

This plan isn’t the endpoint – and it’s not meant to be. It is the next part of a long-term commitment which builds on the work I did, which in itself built on the 2013 UK Strategy for Rare Diseases.

Credit to the current team of health ministers, across the UK, who have agreed to further extend that work giving us further chances to address unmet need and prepare for the future.

As someone who has seen both the frustrations and the progress in this policy area over many years, I welcome the clarity, ambition and practical focus of the 2026 Action Plan.

At a time when Ministers in this government are (rightly) criticised for producing grand plans without much of a nod to implementation, it is refreshing indeed.

From Policy to Production: The EU’s Industrial Accelerator Act

The journey was long and the debates fierce. While the European Commission had initially scheduled its official presentation for November 25, 2025, it was only on March 4, 2026, that the Industrial Accelerator Act (IAA) was finally unveiled.

Justified by the imperative of economic security, this initiative marks a major turning point in the Union’s economic strategy. It aims to strengthen supply chain resilience while safeguarding the continent’s industrial capacity.

First mentioned in the Clean Industrial Deal under the name Industrial Decarbonisation Accelerator Act, the text was intended to stimulate demand for clean European products by introducing sustainability, resilience, and European preference criteria into both public and private tenders.

Although the final regulation has dropped the “decarbonisation” label, it retains its core essence. The Commission has set an ambitious sovereignty target: to increase the share of manufacturing industry to 20% of European GDP by 2035.

However, this text is the result of a laborious compromise. In the face of reluctance from certain Member States and internal tensions between several Directorates-General, some flagship measures had to be substantially reworked before reaching this final version.

Streamlining Industrial Procedures

Several measures within the IAA aim to facilitate and strengthen the deployment of industrial manufacturing capacities.

Facilitating Permit-Granting Procedures

This applies specifically to permit-granting procedures for industrial manufacturing and decarbonisation projects. Member States are required to establish a single application procedure, grouping all necessary permits within one application, accessible through a single access point.

A designated competent authority, responsible for coordinating the process, has 45 days to either acknowledge the application as complete or request any missing information. At the same time, all energy-intensive industry decarbonisation projects benefit from preferential treatment: they must be able to rely on the accelerated procedures provided for by the NZIA (Net-Zero Industry Act), as well as the environmental assessment streamlining measures proposed by the Commission in February.

Creation of Industrial Manufacturing Acceleration Areas

The regulation also mandates each Member State to designate industrial manufacturing acceleration areas on its territory.

Designed as true clusters of “industrial symbiosis,” these areas must provide a reinforced competitiveness framework. This includes the streamlining of procedures and the pooling of infrastructure, as well as access to financing, support for research and innovation, and the provision of a skilled workforce.

These areas are intended to prioritize manufacturing sites for sectors identified as strategic, namely:

  • Certain energy-intensive industries: manufacture of paper, coke and refined petroleum products, chemicals, rubber and plastic products, other non-metallic minerals, and basic metals;
  • The automotive industry: manufacture of motor vehicles, trailers, and semi-trailers;
  • Net-zero technologies identified in the NZIA (notably batteries, solar PV, and hydrogen).

Developing Demand for Clean European Products

One of the primary objectives of the IAA is to foster the emergence of lead markets for certain products in strategic sectors by imposing European origin requirements, low-carbon intensity criteria, or a combination of both.

An Outward-Looking European Preference

Arguably the most sensitive point of the text, the Commission’s proposal outlines, for the first time, the contours of a European preference (outside the field of defense). The IAA thus conditions access to certain public procurement contracts or public support schemes on compliance with a European origin criterion for the products supplied.

Regarding industrial production, only a few specific products are targeted:

  • Concrete and mortar, as well as any product whose performance depends mainly on these materials (including clinker and cement), intended for buildings and infrastructure. The required share of European origin is set at 5%.
  • Aluminium, and products whose performance depends mainly on it, used in buildings, infrastructure, and the automotive sector. The European origin threshold here is 25%.

For the automotive sector, the origin criterion applies only to pure electric vehicles (PEV), off-vehicle charging hybrid electric vehicles (OVC-HEV), and fuel-cell electric vehicles (FCEV) that are purchased, leased, rented or hire-purchased.

To satisfy this criterion, several conditions are set, such as final assembly within the Union, the integration of at least three main specific battery components originating in the EU, or a ratio where the total ex-works price of vehicle components (excluding the battery) originating in the Union represents at least 70% of the total ex-works price of all components. Specific conditions are also provided for small electric vehicles in the new M1E category, introduced during the automotive package of December 2025.

However, far from Chinese-style protectionism or the “Buy American Act,” this European version represents a middle ground between the need for protection expressed by part of European industry and the commitment of certain Member States to international trade.

This balance relies on several limitations, whether in the scope of public procurement and public support schemes affected by this European preference (see Articles 11 and 12), or in the actual location of the production country.

Indeed, Articles 8 and 9 specify that content originating from partner third countries (signatories of a free trade or customs union agreement, or parties to the WTO Agreement on Government Procurement) is deemed to be of Union origin.

Introduction of Low-Carbon Content Requirements

The IAA also imposes carbon emission requirements for certain products supplied in the context of public procurement or projects benefiting from public support. These requirements target concrete, mortar, and aluminium under the same conditions as the European origin criterion, but also include steel. Indeed, the proposed regulation stipulates that at least 25% of steel (as well as any product whose performance depends mainly on this material) intended for buildings, infrastructure, and motor vehicles, must meet low-carbon criteria.

The framework for assessing this low-carbon character varies depending on the nature of the products:

  • For construction products: it will be determined based on harmonised technical specifications or European Technical Assessments (ETA) adopted under the Construction Products Regulation (CPR).
  • For other products: the assessment will be based on the ecodesign requirements set by the ESPR (Ecodesign for Sustainable Products Regulation).

Enhanced Screening of Foreign Direct Investment

While remaining open to Foreign Direct Investment (FDI), the EU is establishing – via the IAA – a stricter framework for large-scale projects in strategic sectors (batteries, electric vehicles, photovoltaics, and critical raw materials).

From now on, any investment exceeding €100 million in a sector where a single third country controls more than 40% of global manufacturing capacity is subject to explicit approval. This decision falls either under a competent national authority, which each Member State is required to designate, or directly under the European Commission.

To be granted the authorization, the investment must satisfy at least four of the six compliance criteria established by the regulation. These criteria concern:

  • The degree of control exercised by the foreign investor over the European entity;
  • Guarantees for the protection of intellectual property;
  • The share of research and development expenditure localized in Europe;
  • The proportion of the workforce employed within the Union;
  • The level of sourcing of inputs of European origin.

If you would like to discuss the impact of the EU’s Industrial Accelerator Act in more detail, please do get in touch with the GK team or our European partner, Euros / Agency.

What is FemTech and is it the future of women’s health?

The term ‘FemTech’ refers to women’s digital health services in areas including reproductive health, menopause and maternal care. It covers medical devices, software, therapeutic drugs and consumer apps, amongst other innovative technologies. The concept of FemTech emerged in the 2010s in conjunction with discussions on gender equality in healthcare provision and the development of virtual care delivery models. As interest in the sector has grown, a new market has emerged for investors. The government has also caught wind of the importance that digitalisation plays in the future of women’s healthcare and is looking to promote the development of FemTech and is keen to encourage further investment in the sector.

Following backlash from the dire findings of the Ockenden maternity services review, which identified significant failings in the Shrewsbury and Telford Hospital NHS Trust, the Johnson-led Conservative government published its ‘Women’s Health Strategy for England’ in August 2022. The then government launched a call for evidence to support the development of the strategy, which led to stakeholders submitting requests for government support for the FemTech industry through improved collaboration between the NHS and private sector. The subsequent strategy encouraged the use of digital health technologies to support women’s access to information, healthcare professionals and healthcare options, stating ‘we want to see greater use of digital technologies to empower women by de-mystifying and simplifying the process for companies to scale and launch their products in the UK.’ The then government said that it would support stakeholders by working with National Institute for Health and Care Excellence (NICE) and the Medicines and Healthcare Products Regulatory Agency (MHRA) to speed up access to innovative health technologies.

The strategy fell by the wayside following successive changes in Conservative Party leadership. However, the Labour government is building on the Conservative’s work on women’s health policy and announced in October 2025 that it was developing a renewed women’s health strategy which would seek to reduce healthcare inequalities and improve women’s access to healthcare professionals. The strategy is being developed to work alongside the 10-Year Health Plan, the government’s long term plan for reforming the NHS in England. It is likely that the renewed strategy, when it is eventually published, will focus on reducing waiting times for women’s healthcare provision and developing new women’s health technologies. The timeline for the renewed strategy is currently unknown; however, the Department of Health and Social Care (DHSC) is likely to encourage stakeholder engagement with the process throughout 2026.

This is an important time for stakeholders working and investing in FemTech. The government is keen to encourage and promote the development of new FemTech solutions to support its wider policy objectives, such as reducing workplace absenteeism and modernising the delivery of health services. The government is looking to innovate and improve women’s healthcare by engaging with the industry and recognises that increased levels of digitalisation is the way forward.

If you would like to discuss the government’s approach to FemTech further, please contact Mariella Turley at mariella@gkstrategy.com

GK & Anchor Policy Spotlight: Emerging Regulatory Markets

The next decade and beyond will be defined by global challenges ranging from climate change and food security to geopolitical instability and competition for resources. Governments around the world will be forced to address these at pace, but many of the solutions will depend on technological advances and scientific discoveries that are only just emerging.

Curiosity has always been in GK’s DNA and over the last year we have dedicated considerable time to understanding and engaging with the emerging industrial sectors of the future. Ranging from technological developments in already highly regulated sectors to the sectors that are just emerging as future economic powerhouses, GK has put them under the microscope to unpick the political, policy and regulatory opportunities and challenges on the horizon.

This report is an introduction of that thinking to you. We know our investment community is keen to understand the risks and opportunities in these spaces to stay ahead of competitors in origination strategies, and most importantly, to invest for the future. With the decades of combined experience that informs our counsel, we pride ourselves on seeing the things that others don’t. Our team of consultants in the UK, Europe and the US is uniquely positioned to give a truly global perspective on understanding and growing the future sectors of the global economy.