Summary

BILM’s position is that UK tax relief for health screening should be extended so that more people can access checks proven to reduce illness and death from specific diseases. That should apply whether the checks are provided by an employer as a benefit, bought through salary sacrifice, or paid for by self-employed people and individuals. Relief should apply only to checks recommended by NICE or the UK National Screening Committee (UK NSC), delivered by qualified clinicians with a clear route into NHS care. It should not apply to unvalidated tests or broad test bundles.

What the law already provides

Employers can already provide one health-screening assessment and one medical check-up per employee each tax year free of income tax and Class 1A National Insurance, under section 320B of ITEPA 2003. The exemption does not have to be offered to all employees, and company owner-directors qualify as office-holders. Section 320C exempts up to £500 a year of recommended medical treatment, but only to help an employee return to work after at least 28 days of absence. It is a return-to-work relief, not a preventive one.

BILM welcomes these reliefs. Its concern is with where they stop.

The gaps

1. The self-employed and individuals get nothing. HMRC treats personal health spending as having a dual purpose (BIM37940, following Norman v Golder), so sole traders, partners and people paying for themselves cannot get relief on even the most evidence-based check.
2. Salary sacrifice probably removes the exemption. Section 320B is not on the list of exemptions protected from the optional remuneration rules in section 228A, so screening provided through salary sacrifice or flexible benefits appears to be taxable. HMRC has not issued guidance on this point.
3. The definitions are narrow and unclear. The section does not say clearly whether follow-up tests after a positive screen are covered or count as “connected to treatment” (EIM21765).
4. Government has not answered its own consultation. The 2023 joint HMT/HMRC consultation on tax incentives for occupational health closed in October 2023 and still has no published response. The Keep Britain Working review (November 2025) has since recommended tax relief on benefits in kind for employers who invest in workplace health.

BILM’s recommendations

1. Parity for the self-employed and individuals. Introduce a capped relief or deduction for one evidence-based screening assessment or check-up each year, overriding the duality rule for this purpose.
2. Protect relief under salary sacrifice. Add section 320B to the excluded exemptions in section 228A(5), which the Treasury can do by order, or at least publish clear HMRC guidance.
3. Limit relief to evidence-based checks. Clarify the definitions in section 320B(3) so that relief covers the checks set out below, including the NICE-recommended follow-up tests that confirm a positive result, and excludes unvalidated tests.
4. Respond to the 2023 consultation. Publish the government response and take Keep Britain Working’s recommendation forward, with preventive screening explicitly in scope.

What should qualify

In scope (backed by NICE or the UK NSC):

• blood pressure

• QRISK3 cardiovascular risk assessment with lipids

• HbA1c in at-risk adults

• BMI and waist-to-height ratio

• kidney tests (eGFR and ACR) in at-risk groups

• smoking, alcohol and physical activity review with brief advice

NHS cancer and AAA screening: AAA, bowel, breast and cervical screening are free on the NHS. Relief should support people to take up their NHS invitations, for example through reminders, help with booking and paid time off. It should not pay for private versions of these tests.

Out of scope: multi-cancer early detection tests, biological-age tests, whole-body MRI in people without symptoms (BILM’s position), broad unselected blood panels, and PSA testing outside the UK NSC targeted programme.

Safeguards: every qualifying check should be interpreted by a qualified clinician, processed by a UKAS-accredited laboratory, delivered by a CQC-registered provider where registration applies, and come with a clear route to the GP or NHS when something is found. The policy should be judged on whether it reaches people on lower incomes and those at higher risk.

Evidence

1. Honest framing: what the evidence does and does not support

BILM does not claim that health screening in general saves lives. The best evidence says it does not. A Cochrane review of randomised trials of general health checks in adults found no reduction in overall mortality (risk ratio 1.00, 95% CI 0.97 to 1.03) or cardiovascular mortality (1.05, 0.94 to 1.16) [1]. Health checks made up of many tests, given to unselected people, do not reliably improve outcomes.

Our case is narrower. Specific checks, aimed at people at risk and linked to proven treatment, do improve outcomes, and these are the checks that UK NSC and NICE already recommend. So all four of BILM’s asks stand or fall on the same test. Extending relief to self-employed people and individuals, protecting it under salary sacrifice, limiting it to evidence-based checks, and pressing for a response to the 2023 HMT/HMRC consultation on tax incentives for occupational health [2] are only justified if relief pays for this narrow set of checks and nothing wider. Every in-scope check below comes with clinician interpretation and a clear route into the GP or NHS.

2. In-scope checks and their evidence

Blood pressure. A meta-analysis of 123 trials found that each 10 mmHg fall in systolic pressure cut major cardiovascular events by about 20%, stroke by 27% and all-cause mortality by 13% [3]. NICE NG136 sets out how to diagnose hypertension (including confirmation outside the clinic) and how to treat it [4]. Many people do not know they have high blood pressure, and finding it is the first step to treating it.

CVD risk assessment with QRISK3 and lipids. QRISK3 was developed and validated in more than 10 million UK primary care patients [5]. NICE NG238 recommends QRISK3 to assess 10-year cardiovascular risk and uses it to guide lipid testing and statin treatment [6]. The value is in identifying people who will benefit from treatment, not in the test result alone.

HbA1c in at-risk adults. NICE PH38 recommends a staged approach: risk assessment first, then a blood test for those at high risk, then referral to intensive lifestyle support [7]. In an evaluation of the NHS Diabetes Prevention Programme, people who completed it lost a mean 3.3 kg and their HbA1c fell by 2.04 mmol/mol. However, only 19% of those referred completed the programme [8]. In a matched cohort of 18,470 people referred, compared with 51,331 not referred, referral was linked to a lower rate of conversion to type 2 diabetes (adjusted HR 0.80) [9]. This is observational evidence, but it is consistent across both studies.

BMI and waist-to-height ratio. NICE NG246 recommends using waist-to-height ratio alongside BMI to assess central adiposity and health risk [10].

eGFR and ACR in at-risk groups. NICE NG203 recommends testing kidney function and urine albumin:creatinine ratio in people with risk factors such as diabetes and hypertension [11]. It does not recommend testing the general population.

Smoking, alcohol and physical activity. NICE recommends brief advice and onward referral for smoking [12], alcohol [13] and physical inactivity [14]. These interventions are cheap and fit naturally into a clinician-led check.

NHS cancer and AAA screening: supporting uptake, not paying for private tests. Screening for AAA, bowel, breast and cervical cancer is free on the NHS [15–18]. BILM is not asking for tax relief on private versions of these tests. We are asking that relief-eligible checks find people who are eligible but have not been screened, and help them take up their NHS invitation through reminders, help with booking and paid time off from employers. The evidence for these programmes is strong:

• AAA screening in men cut aneurysm-related deaths by 42% in the MASS trial [19].

• One-off flexible sigmoidoscopy cut colorectal cancer incidence by 23% and mortality by 31% [20].

• Cervical screening was estimated to prevent up to 5,000 deaths a year among British women born between 1951 and 1970 [21].

• An independent UK review estimated a 20% relative reduction in breast cancer mortality among women invited to screening [22].

There is still a large uptake gap. In 2023–24, 68.8% of eligible people aged 25 to 64 in England were adequately screened for cervical cancer [23]. In 2024–25, 70.6% of invited women took up breast screening [24].

3. NHS Health Check: lessons on uptake and inequalities

The NHS Health Check is the nearest existing model to what BILM proposes. Over its first four years, 214,295 of 1.68 million eligible people attended. Per 1,000 checks, it found 38 new cases of hypertension and 9 of type 2 diabetes [25]. Attendance was low overall but slightly higher among more deprived people (14.9%) than among the more affluent (12.3%) [25]. A systematic review found that uptake varies with age, sex, ethnicity and risk level, and that how people are invited matters [26]. The lesson is that checks only help if they reach people at higher risk and lead on to treatment.

4. Harms, limits and exclusions

Screening causes harm as well as benefit. The same breast screening review estimated about three women overdiagnosed for every breast cancer death prevented [22]. False positives lead to anxiety, follow-up tests and procedures. The inverse care law, that “the availability of good medical care tends to vary inversely with the need for it”, warns that a relief used mainly by better-off and already healthier people could widen inequalities [27]. The relief should therefore be designed so that people with lower incomes and the self-employed can use it, and it should be judged on whether it reaches them.

In line with BILM’s position statement on blood tests, the following are excluded:

• Multi-cancer early detection (MCED) tests: no UK NSC recommendation and few studies have assessed their clinical validity, most of them in people already diagnosed with cancer rather than in people without symptoms, and there is no completed trial showing reduced mortality [28]. Positive results also create diagnostic demand that falls on the NHS.

• Biological-age tests: there are no agreed standards for validating biomarkers of ageing, and they have not been validated for clinical use [29].

• Whole-body MRI in people without symptoms: a high rate of incidental findings with no proven benefit, leading to cascades of further investigation.

• Broad blood panels: each extra test adds to the chance of a false positive, and this is the kind of package that failed in the Cochrane review [1].

• PSA testing outside the UK NSC targeted programme: the UK NSC does not recommend population screening for prostate cancer. It recommends targeted two-yearly PSA testing only for men aged 45 to 61 with a pathogenic BRCA2 variant and a relevant family history [30].

5. Workforce and productivity context

The figures in this section are context only. They do not show that screening reduces sickness absence or economic inactivity. In 2022, the UK sickness absence rate rose to 2.6%, the highest since 2004, with an estimated 185.6 million working days lost [31]. More than 2.5 million people are economically inactive because of long-term sickness [32]. The government said in 2023 that it would respond to the consultation on tax incentives for occupational health “in due course” [33], and it has not yet done so.

References

1. Krogsbøll LT, Jørgensen KJ, Gøtzsche PC. General health checks in adults for reducing morbidity and mortality from disease. Cochrane Database Syst Rev. 2019;2019(1):CD009009. doi:10.1002/14651858.CD009009.pub3. Available from: https://doi.org/10.1002/14651858.CD009009.pub3
2. HM Treasury, HM Revenue & Customs. Joint HMT-HMRC consultation on tax incentives for occupational health [Internet]. 2023. Available from: https://www.gov.uk/government/consultations/joint-hmt-hmrc-consultation-on-tax-incentives-for-occupational-health
3. Ettehad D, Emdin CA, Kiran A, Anderson SG, Callender T, Emberson J, et al. Blood pressure lowering for prevention of cardiovascular disease and death: a systematic review and meta-analysis. Lancet. 2016;387(10022):957-67. Available from: https://doi.org/10.1016/S0140-6736(15)01225-8
4. National Institute for Health and Care Excellence. Hypertension in adults: diagnosis and management (NG136). Available from: https://www.nice.org.uk/guidance/ng136
5. Hippisley-Cox J, Coupland C, Brindle P. Development and validation of QRISK3 risk prediction algorithms to estimate future risk of cardiovascular disease: prospective cohort study. BMJ. 2017;357:j2099. Available from: https://doi.org/10.1136/bmj.j2099
6. National Institute for Health and Care Excellence. Cardiovascular disease: risk assessment and reduction, including lipid modification (NG238). Available from: https://www.nice.org.uk/guidance/ng238
7. National Institute for Health and Care Excellence. Type 2 diabetes: prevention in people at high risk (PH38). Available from: https://www.nice.org.uk/guidance/ph38
8. Valabhji J, Barron E, Bradley D, Bakhai C, Fagg J, O’Neill S, et al. Early outcomes from the English National Health Service Diabetes Prevention Programme. Diabetes Care. 2020;43(1):152-60. Available from: https://doi.org/10.2337/dc19-1425
9. Ravindrarajah R, Sutton M, Reeves D, Cotterill S, Mcmanus E, Meacock R, et al. Referral to the NHS Diabetes Prevention Programme and conversion from nondiabetic hyperglycaemia to type 2 diabetes mellitus in England: a matched cohort analysis. PLoS Med. 2023;20(2):e1004177. Available from: https://doi.org/10.1371/journal.pmed.1004177
10. National Institute for Health and Care Excellence. Overweight and obesity management (NG246). Available from: https://www.nice.org.uk/guidance/ng246
11. National Institute for Health and Care Excellence. Chronic kidney disease: assessment and management (NG203). Available from: https://www.nice.org.uk/guidance/ng203
12. National Institute for Health and Care Excellence. Tobacco: preventing uptake, promoting quitting and treating dependence (NG209). Available from: https://www.nice.org.uk/guidance/ng209
13. National Institute for Health and Care Excellence. Alcohol-use disorders: prevention (PH24). Available from: https://www.nice.org.uk/guidance/ph24
14. National Institute for Health and Care Excellence. Physical activity: brief advice for adults in primary care (PH44). Available from: https://www.nice.org.uk/guidance/ph44
15. GOV.UK. Abdominal aortic aneurysm screening programme overview. Available from: https://www.gov.uk/guidance/abdominal-aortic-aneurysm-screening-programme-overview
16. GOV.UK. Bowel cancer screening programme overview. Available from: https://www.gov.uk/guidance/bowel-cancer-screening-programme-overview
17. GOV.UK. Breast screening programme overview. Available from: https://www.gov.uk/guidance/breast-screening-programme-overview
18. GOV.UK. Cervical screening programme overview. Available from: https://www.gov.uk/guidance/cervical-screening-programme-overview
19. Multicentre Aneurysm Screening Study Group. The Multicentre Aneurysm Screening Study (MASS) into the effect of abdominal aortic aneurysm screening on mortality in men: a randomised controlled trial. Lancet. 2002;360(9345):1531-9. Available from: https://doi.org/10.1016/S0140-6736(02)11522-4
20. Atkin WS, Edwards R, Kralj-Hans I, Wooldrage K, Hart AR, Northover JMA, et al. Once-only flexible sigmoidoscopy screening in prevention of colorectal cancer: a multicentre randomised controlled trial. Lancet. 2010;375(9726):1624-33. Available from: https://doi.org/10.1016/S0140-6736(10)60551-X
21. Peto J, Gilham C, Fletcher O, Matthews FE. The cervical cancer epidemic that screening has prevented in the UK. Lancet. 2004;364(9430):249-56. Available from: https://doi.org/10.1016/S0140-6736(04)16674-9
22. Independent UK Panel on Breast Cancer Screening. The benefits and harms of breast cancer screening: an independent review. Lancet. 2012;380(9855):1778-86. Available from: https://doi.org/10.1016/S0140-6736(12)61611-0
23. NHS England Digital. Cervical screening programme, England 2023-24. Available from: https://digital.nhs.uk/data-and-information/publications/statistical/cervical-screening-annual/england-2023-24
24. NHS England Digital. Breast screening programme, England 2024-25. Available from: https://digital.nhs.uk/data-and-information/publications/statistical/breast-screening-programme/england-2024-2025
25. Robson J, Dostal I, Sheikh A, Eldridge S, Madurasinghe V, Griffiths C, et al. The NHS Health Check in England: an evaluation of the first 4 years. BMJ Open. 2016;6(1):e008840. Available from: https://doi.org/10.1136/bmjopen-2015-008840
26. Bunten A, Porter L, Gold N, Bogle V. A systematic review of factors influencing NHS health check uptake: invitation methods, patient characteristics, and the impact of interventions. BMC Public Health. 2020;20(1):93. Available from: https://doi.org/10.1186/s12889-019-7889-4
27. Tudor Hart J. The inverse care law. Lancet. 1971;297(7696):405-12. Available from: https://doi.org/10.1016/S0140-6736(71)92410-X
28. LeeVan E, Pinsky P. Predictive performance of cell-free nucleic acid-based multi-cancer early detection tests: a systematic review. Clin Chem. 2023;70(1):90-101. Available from: https://doi.org/10.1093/clinchem/hvad134
29. Moqri M, Herzog C, Poganik JR, Justice J, Belsky DW, Higgins-Chen A, et al. Biomarkers of aging for the identification and evaluation of longevity interventions. Cell. 2023;186(18):3758-75. Available from: https://doi.org/10.1016/j.cell.2023.08.003
30. UK National Screening Committee. Prostate cancer: screening recommendation. Available from: https://view-health-screening-recommendations.service.gov.uk/prostate-cancer/
31. Office for National Statistics. Sickness absence in the UK labour market: 2022. Available from: https://www.ons.gov.uk/employmentandlabourmarket/peopleinwork/labourproductivity/articles/sicknessabsenceinthelabourmarket/2022
32. Office for National Statistics. Rising ill-health and economic inactivity because of long-term sickness, UK: 2019 to 2023. Available from: https://www.ons.gov.uk/employmentandlabourmarket/peoplenotinwork/economicinactivity/articles/risingillhealthandeconomicinactivitybecauseoflongtermsicknessuk/2019to2023
33. Department for Work and Pensions, Department of Health and Social Care. Occupational health: working better – consultation responses. 2023. Available from: https://assets.publishing.service.gov.uk/media/655dfa4dd03a8d001207fe7d/print-version-occupational-health-working-better-responses.pdf

Conclusion

General health checks for everyone do not save lives, and BILM does not claim that they do. Targeted, evidence-based checks linked to treatment reduce deaths from specific diseases. Making those checks tax-free for employees, for the self-employed and for individuals, and protecting that relief under salary sacrifice, is a small, focused change that would make prevention easier to take up across the working population. BILM invites HM Treasury, HMRC and DHSC to act on the 2023 consultation along these lines.

Tax points are drawn from legislation.gov.uk and HMRC manuals as at 13 October 2026. This statement is not tax advice.