The British government recently released the initial operational data following the implementation of the mandatory declaration system for organ transplants abroad. This system came into effect on April 1, 2024, with the aim of strengthening the monitoring and prevention of transplant tourism, organ trafficking, and related exploitative practices in the UK.
According to the Human Tissue Authority (HTA) in the UK, the first set of data following the implementation of this legislation was published in November 2025, covering the period from April 2024 to March 2025. The data revealed that in the first year of implementation, a total of 39 declarations were received, all from England. Among them, 38 were related to overseas organ transplants under the fourth provision, while one was submitted on the basis of the third provision due to “reasonable suspicion” of transplant-related crimes.
As of the time of the report, HTA had completed the review of 23 declarations, with 11 cases being referred to the police for further investigation due to potential involvement in organ transplant-related criminal activities. Another 15 cases were still under evaluation, with HTA mentioning the need to gather more information before making decisions.
Under the 2004 Human Tissue Act (Organ Transplant Information Provision) Regulations 2024, designated clinicians in England, Wales, and Northern Ireland must report to the HTA if they become aware of patients having undergone organ transplants abroad or suspect cases related to organ trafficking, commercial organ transactions, or modern slavery. Failure to fulfill the reporting obligation may constitute a criminal offense.
The background to the enactment of this legislation by HTA stems from years of concern in the UK Parliament regarding forced organ harvesting and transplant tourism issues, especially concerning allegations related to the organ transplant system of the Chinese Communist Party. Therefore, this system implements relevant amendments from the Health and Care Act 2022, expanding the UK’s legal jurisdiction over commercial organ trading and transplant-related exploitation to overseas territories.
HTA pointed out that since there was no statutory reporting mechanism for overseas organ transplants in the UK before, the data from the first year of reporting serves as an important baseline for future monitoring. However, the evaluation report also noted that there were some challenges in the initial operation of the system.
According to the evaluation report, there is still a need for clearer guidance on when clinicians should trigger a “suspicion-based report.” This is because almost all reports received in the first year were based solely on the fact that a patient had undergone a transplant abroad.
The report also mentioned that HTA often needed to request additional information from clinicians when processing reports, including donor identities, donor-recipient relationships, and patient addresses. Incomplete address information could potentially affect the efficiency of transferring cases to the relevant authorities.
HTA stated that in the early stages, the implementation of the system primarily involved collaboration with the Blood and Transplant Department of the National Health Service (NHSBT) to provide explanations and promotions to clinicians. Within the first 12 months, Wales and Northern Ireland had not received any declarations. With Scotland introducing a similar reporting obligation from July 1, 2025, HTA expects to further promote the involvement of clinicians nationwide in the UK.
A briefing document from NHSBT and HTA indicated that early reports mostly involved patients receiving kidney transplants abroad. The document highlighted that this system helps identify potential cases of transplant tourism and establishes procedures for referring cases to the police when criminal suspicions arise.
Furthermore, HTA mentioned that these reforms had previously received support from cross-party members of the UK Parliament, including Lord Philip Hunt of Kings Heath from the Labour Party, Lord Alton of Liverpool, and Baroness Finlay, the former President of the Royal Society of Medicine. The reforms also garnered support from human rights organizations, medical ethics groups, and transplant professionals.