CONTEXT: In May 2020 during the COVID-19 pandemic, England implemented a 'soft' opt-out system of consent to deceased organ donation. As part of a wider evaluation, this analysis focused on the perceptions of health care professionals, specifically their experiences of implementation.

METHODS: Mixed-methods study informed by Normalisation Process Theory, based on two national surveys of health care professionals and interviews, observations and document analysis, across two case study sites. Routine NHS Blood and Transplant's audit data provided context.

FINDINGS: 70 interviews with 59 staff and 244 first and 738 second surveys. COVID-19 affected every aspect of implementation. Although supportive in principle, many staff were unconvinced that legislative changes alone would increase consent rates. Many staff were redeployed or left their jobs. As a result, staff were not able to work collectively as intended for implementation. Staff received routine donor audit data suggesting the law was yet to make a difference to consent rates, reducing their enthusiasm and commitment.

CONCLUSIONS: Implementation could have been more impactful if delayed. The National Health Service needs to reprioritise organ donation and relaunch the implementation plan in the post-pandemic period, though it is unlikely the changes will bring about a significant increase in consent rates.