What the NHS England benchmarking tool actually checks (and why most GP websites fail)

Every GP partner I know has at some point opened a browser tab, typed in their own practice's website, and quietly winced. The page is often dated, occasionally incorrect, and almost always failing at least one of the standards the NHS officially expects it to meet. The standard in question is the NHS England primary care website benchmarking tool — and despite being the de facto scoring system for GP surgery websites, very few practice managers I speak to have read it line by line.

This article walks through what the benchmarking tool actually checks, what scores well against it, and the five gaps we see most often when we audit existing GP surgery websites. If you'd rather skip the reading and have us run the audit for you, our free compliance audit takes 90 seconds to request.

What the benchmarking tool is, in plain English

The NHS England primary care website benchmarking tool is a structured framework NHS England publishes for assessing whether a GP surgery's website meets the standards expected of a public-facing NHS service. It's used by ICBs and regional teams when they review practices' digital readiness, and it's the closest thing to an official rubric you'll find for "is my surgery website good enough".

It is not — to be clear — the same thing as the Public Sector Bodies Accessibility Regulations 2018 (which mandate WCAG 2.1 AA conformance), the Welsh Language Standards (which apply to Welsh practices and require genuine bilingual content), or the DSP Toolkit (which is about information governance more broadly). A site can score 100% on the benchmarking tool and still fail accessibility, Welsh-language, and DSP requirements. All four matter; they overlap; we treat them as a package.

The categories the benchmarking tool measures

The framework groups its checks into a small number of categories. The exact wording has evolved over time and varies a little between iterations, but the substance is consistent. The categories any practice should expect to be measured against are:

• Practice information. Address, opening hours (including out-of-hours and bank holiday arrangements), phone, email, accessibility of premises, named partners.
• Patient services. Online services for appointments, prescriptions, test results; signposting to the NHS App; how to register.
• Urgent care signposting. Clear, accessible routes to 999, 111, A&E, OOH GP services and pharmacy First.
• Transparency. CQC report links, named GP partners, ICB and Health Board references, complaints procedure, named accountable GP.
• Patient information. Health conditions, self-care advice, vaccination clinics, travel clinic, repeat prescriptions, sick notes.
• Accessibility. Alignment with the NHS Service Manual content standards, plain English, language-toggle where appropriate, accessibility statement.
• Privacy and data protection. A current privacy notice, cookie policy where applicable, named Data Protection Officer or equivalent, lawful basis for processing.
• Search and navigation. Findable from search engines for the practice name, clear navigation, working internal search where the site is large enough.

Each category includes more granular items, and a typical benchmarking exercise will produce a percentage score per category plus an overall score. There is no formal "pass" threshold, but anything below about 80% generally indicates meaningful gaps.

The five gaps we see most often

Across the audits we've run in the past year, five issues come up over and over again. Address these and you've done about 80% of the work to score well.

1. Out-of-hours and urgent care signposting buried three clicks deep

The benchmarking tool is unambiguous: a patient looking for what to do at 11pm on a Saturday should find it on the homepage, not after navigating two sub-menus. The fix is structural — a clearly-marked "Get urgent help" block, ideally above the fold, that lists 999, 111, OOH GP, pharmacy First and the local A&E. The phrasing matters: use the language patients use, not internal NHS terminology.

2. A missing or out-of-date accessibility statement

Under the Public Sector Bodies (Websites and Mobile Applications) (No. 2) Accessibility Regulations 2018, every NHS-funded website must publish an accessibility statement that is current and specific. We routinely find statements dated 2021, statements that point to the wrong regulations, or no statement at all. The benchmarking tool penalises all three. Writing a compliant statement takes about an hour. Our own accessibility statement is a reasonable template to start from.

3. Online services routing that doesn't reflect what patients actually use

Most surgery websites still treat "online services" as a single link to the EMIS or SystmOne patient portal. In 2026, that's a fail. Patients are using the NHS App as their primary route, with eConsult, AccuRx and Klinik all having a substantial share. The benchmarking tool expects each route to be signposted clearly, with plain-English descriptions of what each is for. We typically rewrite the entire online services landing page during a switch — it's the single highest-impact change we make.

4. Inaccurate or incomplete partner information

Named accountable GP, named partners, GMC numbers where applicable, special interests, languages spoken. The benchmarking tool scores transparency on partner information, and a surprising number of practices have a team page that hasn't been updated since two partners left. This is also where the law gets quietly serious — patients are entitled to know who their accountable GP is, and an out-of-date website can be evidence in a complaint.

5. No working complaints procedure

The framework expects a clearly-labelled complaints route with named contact, expected response time, escalation to the ICB or Health Board, and onward escalation to the Parliamentary and Health Service Ombudsman or Public Services Ombudsman for Wales. About a third of the sites we audit either don't have this or have it filed under a page nobody can find.

Why does this matter, beyond benchmarking?

You could read all of the above and conclude "this is a paperwork exercise". I'd push back hard on that view. Every item on the benchmarking framework exists because a patient — somewhere, at some point — couldn't get the information they needed in time. The 2am parent looking for OOH. The patient looking for repeat-prescription instructions. The relative trying to find the complaints address. The benchmarking tool is not a bureaucratic checklist; it's the codified lessons from thirty years of NHS digital communications going wrong.

It is also, increasingly, what inspectors look at. HIW in Wales and the CQC in England both review public-facing patient information when assessing whether a practice is well-led, safe and caring. If your benchmarking score is 60% and a key piece of patient information is missing from the website, that's not a hypothetical risk — it's evidence the inspector can cite.

What "100% by design" actually looks like

Every site we build is engineered against the benchmarking framework from day one. That means:

• Urgent care signposting in the homepage layout, never buried.
• A current, specific accessibility statement we keep updated.
• Online services routing that reflects the actual tools your patients use.
• Partner and clinician pages your practice manager can update in two clicks.
• A complaints procedure with named contact and escalation routes.
• An annual re-audit included for every customer, with a written report you can use as evidence in your own governance.

We also re-validate on every framework update. The benchmarking tool evolves — when items are added, removed or rephrased, every customer's site is re-checked within 30 days at no extra cost. That's what "100% by design" means in practice.

What to do next

If you've read this far, you probably suspect your current site has a gap or two. There are three sensible next steps:

1. Run your own site through the framework. The current version of the NHS England benchmarking tool is published on the NHS England website. Allow an afternoon.
2. Have us run it. Our free compliance audit covers the full benchmarking framework, plus WCAG 2.2 AA, HIW expectations (for Welsh practices) and a clinical-content review. You get a plain-English PDF report within five working days. Keep it whether you switch to us or not.
3. If your current provider is the problem, switch. If your site is missing items because the platform can't accommodate them, no amount of cleanup will fix it. Read our guide on how to switch GP surgery website providers without disrupting patients.

Practice Digital is a small team of practising NHS doctors, nurses, a head pharmacist and experienced practice managers. We started the company after auditing dozens of GP surgery websites and concluding the market was overdue a clinician-owned alternative.