A representative sample of 31 trusts in England found smaller trusts of less than 5,000 employees had an average compliance rate of 92% and a backlog of three requests.

Medium trusts (5,000 to 10,000 employees) had an average compliance rate of 83% and a backlog of 13 requests, while the compliance rate for large trusts (with over 10,000 employees) fell to an average of 71%, alongside a backlog of 86 requests.  

Only around 0.4% of requests result in a complaint being dealt with by the ICO with the regulator saying trusts overall were doing ‘pretty well'.

The ICO identified a small number of trusts who need to take immediate steps to improve their FOI compliance. These are listed below.

Nottingham University Hospitals NHS Trust: compliance rate of 17% and almost 200 requests over a year old - resulting in an enforcement notice. 

Greater Manchester Mental Health Trust: backlog of over 20 requests, including five over nine months old in the final financial quarter of 2024/25 – resulting in a practice recommendation. 

Guys & St Thomas NHS Trust: compliance rate of 33% in March 2024 improving to 61% in May 2025 - resulting in a practice recommendation. 

Manchester University Hospitals NHS Trust: some shortcomings in relation to FOI compliance, however steady improvements being made – resulting in a practice recommendation.  

In addition, issued enforcement notices to University College London Hospitals NHS Foundation Trust and Portsmouth Hospitals University NHS Trust were issued earlier this year for poor FOI compliance and backlogs dating back several years.