Infected Blood Compensation Scheme Amendment 2025: A UK health and safety law update for duty holders

Infected Blood Compensation Scheme Amendment 2025: A UK health and safety law update for duty holders

What has changed

The infected blood compensation scheme (\u201cthe IBCS\u201d) was established by the Infected Blood Compensation Scheme Regulations 2024 (S.I. 2024/872). The IBCS was subsequently expanded by the Infected Blood Compensation Scheme Regulations 2025 (S.I. 2025/404) which revoked and replaced S.I. 2024/872.

Who is affected

The amendment affects NHS organisations, including trusts and other public sector health service bodies, and any entity involved in administering or handling IBCS claims.

Why it matters

The changes to the IBCS introduce updated governance and administration requirements for infected blood compensation matters. Organisations may need to adjust how claims are assessed, funded and recorded, and to align with broader health and safety governance expectations under UK health and safety law.

What organisations should do next

Prioritise governance and risk management activities to align with the amended scheme. Key actions include:

• Review the 2025 Regulations and any transitional provisions
• Map new requirements to existing policies, procedures and risk controls
• Update claims handling policies, record keeping and reporting practices
• Review and refresh risk assessments and incident management processes as they relate to IBCS claims
• Engage with legal and regulatory teams to interpret the amendments and identify transitional arrangements
• Provide training for staff involved in IBCS claims processing and governance
• Review contractor and partner arrangements for handling IBCS matters
• Consider aligning management systems such as ISO 45001 occupational health and safety management with the updated requirements
• Where appropriate, engage Synergos Consultancy for support on governance and risk management (health and safety risk assessments and Competent Person support)

Enforcement and sanctions

Regulators may enforce compliance with the IBCS amendments; non-compliance can affect governance, funding and reputational standing.

Wrap-up

The 2025 amendments to the IBCS warrant timely attention and proactive planning to ensure compliant and effective governance of infected blood compensation matters within UK health and safety law.