This article considers comparable and near contemporaneous competition reforms in modernising Dutch and English healthcare: specifically, the development of sectoral regulators – the Dutch Healthcare Authority in 2006 and NHS Improvement as a result of the Health and Social Care Act 2012 reforms - with a competition focus and a defined relationship with the competition authorities. Despite distinctions between the Dutch health insurance system and the taxation-funded National Health Service in England, there are sufficient common aspects evident in competition policy development and the functional equivalence of the new sectoral regulators to make this comparative analysis beneficial for those interested in competition policy and healthcare modernisation.

The aim of this article is to examine two factors shaping the competition focus of the sectoral regulators and their relationship with the competition authorities: the regulators’ focus on patients and evolving ministerial oversight of healthcare modernisation. These factors are significant because they reveal not only tensions in equating patients and consumers, but also counterintuitive developments in the two countries. Taken together, these factors help explain why implementation of competition reforms in Dutch and English healthcare has proven difficult, so provide a better understanding for subsequent developments in both countries, or for other countries considering similar reforms.