We are now just over halfway through the second year of the Competition and Markets Authority’s (CMA) direct consumer enforcement regime under the Digital Markets, Competition and Consumers Act 2024 (DMCC Act). Over the past 6 months, the CMA’s new consumer enforcement regime has moved firmly into delivery phase. We have secured practical results for consumers while sharpening our focus on the harms and reforms that will shape the year ahead. ## Our work so far this year Since April 2026, we have: * opened 6 new investigations into Ryanair, Euro Car Parks, Microsoft, Virgin Atlantic, Trainline and Red Driving School, taking the total number of investigations we have opened to 20 * settled 7 of our cases * ordered redress of over £2.3 million and imposed fines of over £11.8 million * secured compensation for heating oil customers whose contracts were cancelled Alongside our investigations, we have also continued our work to promote compliance, including: * publishing our updated unfair contract terms guidance (CMA37) and holding a webinar for businesses * writing to private parking operators and the wider car parking sector about the importance of complying with consumer law * issuing an open letter to domestic heating oil suppliers about ensuring their terms are fair * writing to suppliers of liquefied petroleum gas to remind them of their obligations under consumer protection law ## Looking ahead In the months ahead, we will continue to focus on practices that can cause significant consumer harm across markets, including continuing to bear down on drip pricing, misleading time limited offers or fake reviews. But our investigations into Adobe, Euro Car Parks, Ryanair and Microsoft show we are also willing to investigate conduct by individual businesses. We will act on intelligence and where there are problems, we expect businesses to put issues right quickly. ## Pricing practices and online choice We will continue to tackle drip pricing, partition pricing and online designs that obscure the true cost of a purchase or distort consumer choice. We have settled 7 of our 8 original online pricing practice investigations launched in November 2025, most recently Gold’s Gym, Wayfair and Buy It Direct, imposing penalties of over £6,000,000 and securing over £440,000 in consumer redress in these three cases. Our newer investigations into Virgin Atlantic, Trainline and Red Driving School show that complete, accurate pricing remains a priority so consumers always know the total price that they will pay. We are also reviewing how online retailers disclose delivery fees and expect to provide an update shortly. Using our intelligence capabilities, we are also watching for businesses who might be using misleading discounts. ### Our expectation: Discounts must be genuine and businesses must show the total price clearly and throughout the purchasing journey, without opting customers in by pre-selecting extra services. Online journeys should support informed choices. The rules are clear, and businesses have had ample time to comply. ## Fake and misleading reviews We continue to progress our investigations into Autotrader, Feefo, Dignity, Just Eat and Pasta Evangelists over concerns that consumer law on misleading reviews may have been broken, and we expect to provide a further update in the coming months. We have provided clear guidance about publishing consumer reviews and complying with consumer protection law. ### Our expectation: Businesses that host or use reviews should have effective systems to prevent misleading content and should act promptly when problems are identified. They should also bear in mind that commissioning reviews can take many forms and isn’t limited to paying consumers for them, for example unlawful conduct could include a business requesting members of staff to write reviews about its products or services. ## AI products and services We are actively monitoring how AI products are marketed and used, working with consumer groups and businesses to identify how benefits can be harnessed as well as emerging risks. Our guidance on using AI agents explains how existing consumer law applies to agentic AI. In July we also opened an investigation examining concerns about how Microsoft presented information to consumers about changes to Microsoft 365 Personal and Family subscriptions, including the addition of new, AI-related features such as Copilot. ### Our expectation: Providers and businesses deploying AI must be responsible and accountable to consumers. New technology does not change their responsibility to comply with consumer law. ## Subscription contracts A new subscription contracts regime will come into force in January to ensure customers are better informed and make it easier for people to cancel plans they no longer want. Ahead of this, the government will be publishing secondary legislation and further guidance. In the early months of the regime, the CMA’s focus will be on supporting businesses to get this right to help drive the best outcomes for consumers. However, businesses should not assume that our support for compliance means enforcement of the rules is being delayed. Conduct during this period may still be considered as part of enforcement action. In line with our approach to consumer protection, we will use our powers proportionately by focusing enforcement on more egregious conduct, particularly in areas where businesses should already be clear about their obligations under the existing law. We will consider genuine efforts to comply with the new subscription rules when deciding whether to intervene. ### Our expectation: Businesses will be working to bring themselves into compliance with the new subscription contracts rules as quickly as possible. ## Summing up Over the last 6 months, we have continued to build on the strong foundations laid in the first year of the direct enforcement regime. The first half of this year has shown that our twin approach of helping businesses comply while showing the real consequences for those who don’t is continuing to deliver real benefits for consumers. You may also be interested in: * Direct consumer enforcement: one year on * Shop smart, bag a bargain – a consumer expert’s guide to online shopping * Price transparency is important, it affects everyone * Our new consumer enforcement regime

In 2023, the CMA fined 10 construction firms £60 million for colluding to rig the bidding processes for demolition and asbestos removal contracts worth £150 million. The evidence in the case included emails, text messages and handwritten notes - even a notebook with names of contractors next to compensation figures which firms owed one another for rigging bids in their favour. This was a case of brazen illegality, targeting sites which included the Met Police training college and Oxford University. But the case also illustrates a wider point: too often, the real victims of bid rigging are taxpayers, who could be paying up to 20% or more (according to the Organisation for Economic Co-operation and Development, OECD) for vital public services, infrastructure and national security. Desperately needed money, which goes directly from stretched departmental budgets into the pockets of colluding firms. Public procurement spend in the UK is in the region of £400 billion per year. No precise estimate of the impact of bid rigging is possible – the activity, after all, happens in secret and evidence suggests detected cases could be the tip of the iceberg. But the CMA believes the cost to the taxpayer might be between £1 billion and £3.5 billion. The reality is that features like the nature and frequency of tenders (amongst others) make public sector procurement a prime target for bid rigging. In fact, over half all the bid rigging cases the CMA has investigated have involved public sector tenders. Figures from international authorities show the UK is by no means an outlier. Nor is the cost purely financial. Evidence also points to reduced quality and innovation, sometimes with very real human consequences - from increases in road traffic accidents due to substandard infrastructure, to increased hospital mortality due to depleted budgets for essential medicines. Historically, detection has been challenging – with such high rewards, and serious consequences if caught, colluding firms have strong incentives to hide their activity. Whistleblowing plays an important role, but caches of incriminating text messages and emails don’t just fall into the laps of competition authorities every day. The good news is that a step change in detection is now possible, driven by advanced data science and AI. Around the world, governments and competition authorities (Spain, Portugal, Brazil, Korea, to name a few), are using data screening tools to hunt for suspicious patterns at scale. It is working. But it relies on one critical factor: access to the right data, at scale - including, crucially, losing tender bids. The CMA has invested substantially in this area over recent years, combining deep cartel enforcement expertise with advanced data science. The product of that investment is BRIT - our Bid Rigging Intelligence Tool, which offers cutting edge capabilities to analyse data at scale across the public sector to find suspicious patterns. BRIT can’t reach its true potential until it has access to the data needed for systematic screening at scale. Unlike in many countries, this data is not routinely collected or available in machine readable format here. We are running pilots with public bodies, including the Departments for Education, Work and Pensions and Justice. These pilots are already generating promising leads. Thus far, however, there has not been a cross-government commitment to create an accessible, large scale data set - in contrast to the experience in many other jurisdictions internationally. Today, I am in Parliament presenting CMA recommendations to reform public procurement, of which our proposals on bid rigging form a key part. Most importantly, we are calling on government to unlock bid rigging capability at scale through a more coordinated approach to data. This would bring the UK in line with international counterparts and potentially save billions of pounds of taxpayer’s money.

**A year on from the launch of the CMA’s mergers charter, we’re sharing what’s working well and what would help it to work even better**. Last March, the Competition and Markets Authority (CMA) published its mergers charter. The charter outlines our commitment to 4 principles – pace, predictability, proportionality and process (the 4Ps) – in our merger reviews. The aim is straightforward: to reach the right decisions as quickly as possible, while minimising the burden on businesses. Delivering on that aim is very much a shared endeavour. It relies on commitment and cooperation from the CMA, businesses and advisers alike – so the charter also explains how we expect everyone to engage with the merger review process in practice. One year in, we have had very positive feedback about the new processes and practices we have introduced to deliver on our commitment to the 4Ps. In most cases, businesses and their advisers have engaged positively and constructively, which really helps the process run smoothly. Every so often, though, we still see approaches that make it harder to deliver the benefits the charter is designed to bring. To keep the charter practical and useful, here are a few reflections on behaviours that have helped us achieve our goal – and a few that can unintentionally slow things down. ## Pace We committed to conducting our reviews as efficiently as possible, in line with our KPIs of: * completing pre-notification within 40 working days * issuing clearance decisions in straightforward cases within 25 working days of starting the statutory phase 1 clock This expedited process has been well received. Merging businesses have appreciated the compressed overall timeline during a period of uncertainty and found the KPIs helpful to understand likely timings. We received some feedback that the process around the start of pre-notification can be time consuming, involving iterative information requests that are burdensome for businesses. We will continue to work to ensure that we are clear about our expectations regarding the information that needs to be provided to start pre-notification, with a view to streamlining this process. To make the most of these timelines, it really matters that the information and evidence we need for our review is provided in a complete and timely manner. In a small number of cases, we’ve found: * merging businesses or their advisers taking an extremely narrow approach to providing internal documents that is clearly inconsistent with our request * a very large number of internal documents, that should have been provided at the start of pre-notification, only being identified at a late stage * repeated delays in providing information and late-stage changes to information provided (including material updates being made through changes to footnotes) Where this happens, it can create avoidable delays in starting the pre-notification KPI, because the case team needs to follow up to obtain information required as part of the draft merger notice. And where we find that information has not been provided following the start of the pre-notification, this may mean that we will need to disapply the KPI or, in some circumstances, even reject the merger notice after starting the statutory clock (which happened in one case this year). ## Predictability We said we would operate predictably, including through providing regular updates to merging business in our reviews. We have introduced regular update calls to give merging businesses and their advisers feedback on progress made in pre-notification and the issues under consideration. These calls have been welcomed. We have been told that, on some occasions, businesses have found it challenging to predict the theories of harm that the CMA will focus on. We will continue to address this through direct engagement with merging businesses and their advisers during our reviews, alongside wider updates (for example, to our published guidance) where appropriate. In general, merging businesses and their advisers have been proactive in keeping the CMA updated on relevant developments, and have engaged with us directly and openly. That said, predictability works best where parties engage with us in a full and frank manner throughout. In a few instances, we have seen: * merging businesses change their position on the effectiveness of a remedy package after the CMA decided to accept in principle undertakings in lieu of a reference to phase 2 * merging businesses repeatedly changing their position on the necessity of derogation requests, including on ‘urgent’ requests This sort of behaviour can make it harder for the CMA to accurately – and in a timely way – assess issues directly relevant to its review. It can also lead to delays that are unhelpful both for the CMA and for merging parties. ## Proportionality We committed to acting proportionately, including through prioritising potential concerns for investigation and scoping of information requests. Merging businesses have welcomed case teams’ approach to streamlining the issues under investigation and sending targeted information requests. This notwithstanding, we have heard that information requests remain burdensome for businesses. It has been suggested that further opportunities for direct engagement between merging businesses and CMA case teams in relation to the scoping and implications of information requests would help to ensure requests are appropriately targeted. We absolutely welcome such engagement and will seek to make this clearer to merging businesses and their advisers during reviews and our wider outreach. In general, merging businesses and their advisers can be relied on to submit responses that are: * clear, complete and accurate * appropriately scoped to the main issues identified by the CMA As with some of the examples under ‘pace’ and ‘predictability’, there are occasions where submissions have later been revealed to be materially incomplete or inaccurate. When that happens, it can directly affect our ability to prioritise and streamline the issues under investigation. We have also had repeated, extensive confidentiality requests in relation to decisions for publication, including repeated requests to redact public information or CMA analysis that relates to non-confidential information. Where the CMA receives such requests, we may need to return the full document to have the parties redo the confidentiality claims with a short deadline as the initial claims cannot be relied on and we need to publish the document. We recognise this can result in costs to merging businesses who may need to pay advisers to repeat the confidentiality exercise a second time. ## Process We said we would engage directly with merging businesses and ensure that they have a clear understanding of the progress, timeline and focus of our review. Merging businesses have praised the more frequent and direct engagement with the CMA, including with senior staff at teach-ins. Merging businesses have told us that they would welcome more engagement of this nature, such as: * having a direct line of communication with the case team where that may be helpful to resolve an issue more quickly * more regular updates on the current statutory deadlines in cases where the clock is ‘stopped’ We will seek to make clearer that we are open to such discussions and provide more regular updates on deadlines in applicable cases. Generally, merging businesses have made a positive effort to ensure the right people attend teach-ins and meetings, enabling open and constructive engagement on important issues. Even so, in some instances the behaviour of merging businesses or their advisers has obstructed effective engagement. In particular, merging businesses being advised not to attend teach-ins or join update calls, leading them to feel as though access to the CMA is restricted (when in fact we encourage attendance, particularly at teach-ins, which are now expected on every case). This behaviour by a few advisers cuts directly across the CMA’s commitment to engage directly with business during its merger reviews. ## Looking ahead Overall, we see the first year of the charter as a success. For example: * the 40 working day pre-notification KPI has been met in all cases in which it has applied (in 2 cases the merging businesses ‘opted out’ and in one case it was disapplied) * the 25 working day KPI for issuing clearance decisions in straightforward cases has been met in all such cases This would not be possible without the commitment and cooperation of the CMA case teams, businesses and their advisers. To keep delivering against our goal, businesses and their advisers must continue to familiarise themselves with the expectations set out for them in the charter – and make every effort to meet them. ## Engaging with us during an investigation – more advice More resources for merging businesses are available on GOV.UK. ### Engaging the decision maker ### Meeting with the CMA ### Sending submissions

A year ago, the Competition and Markets Authority (CMA) launched its new direct enforcement regime under the Digital Markets, Competition and Consumers Act 2024 (DMCC Act). It’s been a busy 12 months, so now feels like a good moment to reflect on what we’ve delivered against the commitments set out in our approach document, and to look ahead at what’s coming next. ## What the numbers tell us Numbers give an insight into the scale of work happening behind the scenes – a helpful starting point for understanding progress so far. From April 2025 to April 2026, we have: * opened investigations into 14 businesses and settled with 2 * ordered that a total of £760,000 be refunded to consumers, and imposed fines totalling £4.7 million * issued 157 advisory and warning letters * sent 46 information notices Before the new rules came into force, we published guidance on how we’ll use the regime, how to comply with the law on consumer reviews, and unfair commercial practices. We’ve since published and updated 10 other pieces of guidance to help businesses comply – including new guidance on price transparency and draft revised guidance on unfair terms in consumer contracts. But ultimately, what matters most is the difference we make: * giving consumers the confidence to shop online, with clear and accurate pricing and the means to exercise their rights if things go wrong * creating a level playing field where fair-dealing businesses can thrive ## Our purpose and approach The CMA’s purpose is to promote competition, protect consumers and support growth and household prosperity. This is no small task – particularly at a time when people are feeling cost of living pressures, with price rises caused by the conflict in the Middle East starting to bite. That’s why we’ve focused on using our enforcement powers strategically – making sure that businesses’ behaviour genuinely complies with consumer protection rules. From the outset, our approach has been twofold: 1. providing clear, practical guidance to help the majority of businesses who want to do the right thing, and 2. taking targeted enforcement action where we identify egregious breaches A year on, this approach is well established. ## Focusing our efforts Our public enforcement action has targeted 3 areas, as set out in our approach document: drip pricing, fake reviews, and online choice architecture (OCA). With each, we deliberately cast a wide net – and the results speak for themselves. ### Drip pricing This week we announced that the AA Driving School and BSM Driving School, who are both owned by the Automobile Association Developments Limited (the AA), admitted liability for drip pricing and agreed to refund over £760,000 to affected learner drivers. The AA was also fined £4.2 million. This settlement is a major milestone in our work to enforce against illegal and harmful drip pricing practices. ### Fake reviews We carried out a sweep of review publishers and issued advisory letters to 54 firms to improve their compliance with the law. 90% of the businesses we contacted then took action to improve their policies and in March we opened investigations into 5 companies to establish whether consumer laws on misleading reviews have been broken. By looking into key stages in the online reviews ecosystem – such as how reviews are obtained, moderated and displayed, through to the star ratings presented – we’re investigating multiple practices that can shape what people see when they search, shop or book online. ### Online choice architecture Many of the businesses we wrote to in November moved swiftly to stop adding extra products or services by default. We’re continuing to investigate default optional charges and false ‘time limited’ offers. And we’re talking to the wider community of regulators – through the Digital Regulation Cooperation Forum and International Consumer Protection and Enforcement Network, for example – about how AI could affect online choice architecture in future. ## Tackling other harmful behaviour Beyond those areas, we’re considering standalone cases that address the conduct of a specific business, where we have intelligence of potential infringement. For example, our investigation into Adobe will examine whether its early cancellation fees are unfair and misleading. Expect more of these standalone cases in the next year. ## Responding to wider changes Our strategy matters, but so does remaining agile. It was crucial to respond quickly to the concerns we heard from consumers about heating oil. We’ve welcomed some businesses publicly confirming that they would honour agreed prices, even as wholesale prices increased. This gave consumers the immediate comfort that they could rely on the contract terms they agreed and wouldn’t be left to bear the risk alone. Combining our markets and consumer enforcement roles, our heating oil market study will examine whether consumers need to be better protected against possible future shocks. ## Engaging with businesses across the UK Supporting businesses has been central to our strategy, with over 2000 attendees at our events and seminars over the first year. We’ve engaged directly with businesses at the FSB Coventry Business Bootcamp, started a programme of events with regional law firms to share compliance advice, and promoted our Clear Pricing campaign – featuring Alexander Armstrong – which gives businesses a simple, 3-step checklist for transparent pricing. We’re looking forward to building on this momentum at the FSB Manchester Business Bootcamp on 15 May and through more local law firm events. ## What to expect in year 2 In our second year, we’ll continue to focus on areas of essential spend where consumers feel the pinch most, as well as practices that are widespread and cause significant harm. My message to businesses is to prioritise compliance in the following areas: * **price transparency** : don’t use hidden, ‘dripped’ or unlawful partitioned pricing and discount claims must be true, accurate and not misleading * **fake reviews** : have robust policies in place so reviews give consumers an honest picture – and make sure your employees are implementing them * **terms in contracts with consumers** : review your terms carefully (especially any that impose exit fees) against our updated guidance which we will finalise in Autumn by the latest * **subscription contracts** : new rules are expected to come into force in Spring 2027 with guidance from DBT – businesses must get ready to comply * **how you’re using AI, including agents** : our recent advice offers practical tips on using agentic AI responsibly And if you see other businesses breaking the rules? Report it to us. ## Summing up I’m proud of what we’ve achieved so far, and excited about what’s ahead. Helping businesses comply while showing the real consequences for those who don’t – that twin approach is already delivering better outcomes for consumers. And we’re just getting started.

Algorithms and AI are increasingly shaping the world around us, influencing a wide range of decisions and market outcomes –⁠ from the prices we pay for goods and services, to the choices available in markets. The Competition and Markets Authority (CMA) is the UK’s main competition and consumer protection authority. We have a whole-economy remit: we promote competition and protect consumers with a clear end goal to drive economic growth and improve household prosperity. We have examined algorithms and AI over many years, assessing their implications for competition and consumers. This includes early work on pricing algorithms and more recent work on frontier foundation models, as well as ongoing work and thinking on agentic AI.1 This technology can give rise to significant benefits but also important risks, including the potential for new forms of collusion. Businesses must take proactive steps to mitigate the risk of breaking consumer or competition law, making sure they understand the technology on which they rely to inform or shape commercial and operational decisions. Competition agencies can also harness this powerful technology internally to drive a step change in the efficiency and effectiveness of their work, including in screening markets for potential issues. The CMA has invested heavily in our technical capabilities, including our ability to use AI and agentic systems to detect breaches of consumer and competition law at an unprecedented pace and scale. ## Rise of algorithmic pricing Algorithmic pricing is not a new phenomenon. Algorithms have been used for decades in sectors such as airline pricing, hospitality, and retail. The CMA’s early research in this area, including a study of pricing algorithms (2018) and broader report (2021), highlighted how integral algorithmic systems had already become to many businesses’ operations. However, the prevalence and sophistication of algorithms have grown markedly in recent years, fuelled by increasingly granular, large-scale data, availability of computing power, and methodological developments. The emergence of large language models (LLM) has given businesses greater access to powerful, low-cost predictive technology that can inform or automate many important decisions, including price setting. Our more recent work has explored these developments and their potential implications. ## Benefits of algorithmic pricing ### Efficiency, speed and lower costs Algorithms can process complex datasets much faster than humans, allowing businesses to adjust their prices in real-time for optimised outcomes. By automating pricing decisions and reducing human error, businesses can lower their costs and barriers to entry, potentially leading to greater competition. ### Personalised pricing Algorithms may allow businesses to tailor prices to individual customers or segments, increasing their profits while also expanding market access and affordability for some consumers. ### Increased market efficiency By making prices more responsive to changes in demand and supply – including supply chain disruptions – algorithmic pricing may make markets more efficient. ## Risks and challenges of algorithmic pricing ### Dynamic pricing Algorithmic pricing can creates risks related to dynamic pricing, where prices move rapidly in response to changing market conditions. In such circumstances, there is potential for vulnerable consumers to lose out, for consumers to feel blindsided by sudden changes – particularly if they are under unfair pressure to make snap decisions – and ultimately for a loss of consumer trust and confidence. The CMA has discussed dynamic pricing recently and set out advice for businesses to help them use innovative pricing models in a fair and transparent way. ### Algorithmic collusion Algorithmic pricing could also lead to coordinated outcomes and higher prices – often referred to as ‘algorithmic collusion’. The emergence of more powerful AI models may compound this risk in new and subtle ways. Ezrachi and Stucke2 conceptualised a set of scenarios in which algorithmic collusion may arise: #### Implementation of ‘classic’ collusion Rival businesses may explicitly agree to collude and then use algorithms to put into practice, monitor, and enforce the agreement. For example, in a 2016 CMA case, 2 online sellers of posters were found to have colluded by agreeing not to undercut each other on Amazon Marketplace and then giving effect to the agreement using pricing software. The use of a common algorithm can reduce the need for sellers to communicate on an ongoing basis, is more data driven and cost-effective for real-time coordination, and enables more sustainable collusion. As with more traditional forms of collusion, this conduct is unambiguously illegal. #### Hub-and-spoke collusion Colluding businesses may use the same algorithm or data hub to exchange competitively sensitive information indirectly – which might in some cases also include delegating pricing decisions to the hub or receiving from it recommendations (based on co-mingled data). Exchanges of information can reduce strategic uncertainty and sustain collusive outcomes, even without an explicit agreement to coordinate. The hub may allow businesses to increase prices above competitive levels, maximising collective profits. UK law recognises that indirect information exchange through third parties, such as algorithm providers, can constitute illegal, anti-competitive conduct. #### Predictable agent Businesses may use algorithms that react predictably to market events, potentially softening competition. Such algorithms may follow price leadership and punish deviations, achieving collusive outcomes without human communication or explicit agreement. In the UK, the Chapter I prohibition in the Competition Act 1998 is engaged to the extent the conduct amounts to an agreement or concerted practice between undertakings. However, the CMA may also be able to remedy competition issues caused by coordination through market investigations without having to establish whether the businesses involved have reached a common understanding or whether that understanding is tacit or explicit. #### Autonomous, complex AI systems It is possible that advanced AI systems given the objective to maximise profits may learn to reach coordinated outcomes, even without human intent to collude. ## Evidence: theory, experiments and case studies While research continues to develop in this area, with many open and interesting areas of debate, some studies have supported concern about algorithmic collusion, including: * theoretical contributions, experiments and simulations (by Salcedo3, Calvano et al.4., Klein5, Asker et al.6, Harrington7, and Fish et al.8) * a few real-world, empirical studies (Assad et al.9 and Musolff10)11 While early research focused on reinforcement learning algorithms (Calvano et al.[4]), recent advances have allowed businesses to harness LLM with human-language interfaces and advanced capabilities. Through market simulations, Fish et al.[8] demonstrate that LLM-based agents used as pricing tools may be prone to colluding anonymously, with interesting sensitivity to ‘prompts’. Meanwhile, Keppo et al.12 find that a greater number and diversity of agents can reduce the risk of collusion. Clearly, these are early days in a vibrant and still emerging field, with no overall consensus (Deng13), and much innovation and research yet to come. In the meantime, real cases seen already in some jurisdictions show there is already some regulatory interest and action in this area, and underline the need for businesses to understand the risks and their responsibilities in relation to algorithmic pricing. ## How businesses can mitigate the risks The risks described above do not imply that the use of algorithms or AI in pricing is inherently problematic, nor that all businesses face the same level of legal or competition risk. Much depends on market context, design choices, governance, and how technology is used in practice. With that in mind, this guidance only highlights steps businesses may consider taking in order to avoid breaking competition law (which has potentially serious consequences), and to reduce the likelihood of outcomes that reduce competition or harm consumers. ### Understand the law Make sure your business understands how competition law applies to algorithms, and provide staff with appropriate training. For example, the CMA has guidance on horizontal agreements. ### Do not share competitively sensitive information with your competitors Make sure you are not sharing confidential, competitively sensitive information with rivals, whether directly or indirectly (for example, through a pricing consultant or pricing software). Information is considered to be ‘competitively sensitive’ if it reduces competitive uncertainty in the market, and could influence the competitive strategy of other businesses. ### Do not let competitors’ confidential information influence your pricing Make sure that any pricing guidance or actions, generated by a pricing solution you use, are not influenced in any way by competitively sensitive information from rivals – even if you do not receive this information directly. ### Be careful when using the same algorithm as a competitor If you can reasonably expect that a pricing recommendation could be drawing on confidential information from a competitor (even if you have not been told this directly), you may still be breaking the law. Take extreme care when discussing pricing algorithms with your rivals. ### Scrutinise data and algorithms where needed In some cases, you may need to audit the input data and statistical approaches used, whether in-house or third-party. A traditional algorithmic audit might not be enough: consider linguistic stress testing prompts, and including explicit anti-collusion constraints (for example, if using pricing solutions that involve LLM). ### Report any concerns Report anti-competitive behaviour, including potentially illegal pricing algorithms, and consider applying for leniency where appropriate. Remember: there are serious consequences to being caught in anti-competitive behaviour. In the UK, businesses can be fined up to 10% of their annual turnover, and individuals can face fines, director disqualification, or even criminal conviction. Pricing consultants should also act responsibly. If you provide a pricing service, you could be held to account for breaking competition law, for example if you: * give pricing recommendations to rival businesses that are based on confidential information from each * facilitate the exchange of competitively sensitive information between rivals ## Our approach to detection and enforcement In some circumstances, algorithmic collusion can harm consumers through higher prices, less choice, and weaker incentives to innovate. The CMA’s approach to addressing the risks of algorithmic collusion is multifaceted and proportionate, reflecting both the potential harms and evolving evidence base. ### Raising awareness We continue to provide guidance, research, and accessible content for competitors and algorithm providers. ### Reporting and detection We have recently updated our leniency policy, which now makes leniency available for conduct such as exchanging competitively sensitive information through a shared algorithm. We offer a reward of up to £250,000 to anyone who tells the CMA about illegal cartel activity, including algorithmic collusion. ### Screening and investigation We have a strong range of covert and overt investigatory powers. Screening is also an important and growing focus. We have been developing our capabilities in this area, drawing on a range of techniques including machine learning, AI, and agentic systems, alongside more traditional tools. These capabilities support proactive screening and investigation, and are used as part of a wider evidential toolkit rather than as a substitute for legal and economic analysis. As part of this we are also actively screening for algorithmic collusion and have built technical expertise to investigate algorithmic systems, including their outcomes, user interactions, and competition implications. ## Our growing AI and technical capability The CMA’s work on algorithmic collusion and our wider cartel screening form part of a broader programme of technology horizon scanning and digital capability building. Areas like AI are complex and deeply technical, requiring regulators to stay on top of rapid developments. For example, recent research (Nikandrova and Parekh14) demonstrates that LLM-based agents can autonomously learn to adopt harmful exclusionary strategies. This is a further example of the need for businesses to understand the technology and be alive to novel risks and for agencies actively to monitor this emerging space. In the CMA’s case, ensuring that we think ahead on emergent risks also reflects our focus on identifying and addressing barriers to UK growth. A particularly thought-provoking area is agentic AI. Definitions vary but these include systems that can be instructed in natural language to achieve a goal, navigating some complexity in the environment, planning, and taking action as needed. The current reality may be modest, but interest has surged in recent years and this has become an area of active development and investment for businesses. There are many potential applications – for consumers and businesses – and potentially significant benefits as well as important considerations, including risks around pricing outcomes where businesses rely on AI agents to set prices fully autonomously for them. Agents could, in theory, learn to coordinate on outcomes akin to tacit coordination without explicit human instruction to do so. Experiments have shown LLM‑based agents in simulated environments converging to supra‑competitive pricing in repeated‑interaction settings (Fish et al.[8]). Another possibility explored in recent theory and experimental research is that AI agents learn to coordinate by communicating through steganographic techniques – methods of concealing information within another message or physical object. For example, it has been demonstrated that AI agents instructed not to share sensitive information directly can learn to conceal this within a seemingly innocuous message about the weather (Motwani et al.15). Ghaemi16 surveys these and related possibilities. The CMA’s programme of technology horizon scanning is continuing to monitor and unpack developments in AI including agentic systems, and embedding this insight across the breadth of our work. Likewise, businesses exploring these new technologies and operating in the UK should ensure that they understand potential risks and remain compliant with UK consumer and competition law. As part of our proactive work, we are also exploiting advanced technologies internally at the CMA to detect consumer and competition issues at unprecedented pace and scale. This work is iterative and complements, rather than replaces, established legal and economic analysis. It includes deploying new techniques in data analysis and AI to help detect bid rigging in public procurement – a significant area of risk and potentially substantial public savings. We are using agentic AI to identify potential infringements of consumer protection law across the economy to help us better understand consumers’ experience and target our enforcement activity where it will have the greatest impact. We recently opened investigations into 8 businesses, our first with new direct consumer enforcement powers, and sent advisory letters to 100 others. These actions will make a real difference for UK households and foster consumer trust and confidence, and thus contribute to economic growth. > "UK businesses exploring these new technologies should ensure that they understand potential risks" Since 2019, the CMA has made significant investments in building dedicated in-house capability. An interdisciplinary directorate – Data, Technology and Insight (DTI) – now brings together: * data scientists * engineers * technologists * behavioural scientists * eDiscovery and digital forensics specialists, and more Experts in strategic, business and financial analysis are now part of this mix too – it is essential to understand not only the technology but also how businesses operate in the real world and we have been deepening our capabilities for understanding businesses’ strategies and business models, including in relation to AI. DTI’s integrated team of technical experts work alongside economists, lawyers, and other specialists, helping ensure that the CMA can meet the challenges of increasingly complex investigations. Agencies do not operate in a vacuum, and engaging with stakeholders – including consumers, businesses, investors, academics, and other regulators – is crucial to the quality of the CMA’s work and impact. We proactively share insights and techniques, both: * in the UK, for example through the Digital Regulation Cooperation Forum * internationally, for example at the OECD, United Nations Conference on Trade and Development, G7 and through the International Competition Network’s Technologist Group, which the CMA currently chairs ## Conclusion The evolving digital economy presents both opportunities and challenges. Algorithmic pricing and AI can deliver significant benefits for businesses and consumers, but can also raise risks of collusion and harm. Businesses are advised to ensure they understand the law, and mitigate risks that may be posed by algorithmic pricing (including the newer and more subtle risks posed by LLM and agentic AI). For their part, agencies must: * remain vigilant * invest in technical capability where possible * foster strong collaboration with peers and stakeholders * ensure that innovation is balanced with robust competition safeguards The CMA’s own programme of work in this space is ongoing and geared to proactive technically-informed support and guidance for businesses, with robust enforcement where needed to protect consumers and competition and ensure markets remain fair, dynamic, and innovative. 1. For more of our work on pricing algorithms, read: Algorithms: How they can reduce competition and harm consumers (2021), Pricing algorithms and competition law: what you need to know (2024), and Why clear and accurate pricing matters – and how businesses can get it right (2025). For more on AI foundation models, read our update paper (2024). ↩︎ 2. Ezrachi, A., and Stucke, M. E. (2016). ’Virtual Competition: The Promise and Perils of the Algorithm-Driven Economy’. Harvard University Press. Ezrachi, A., and Stucke, M. E. (2017). ‘Artificial Intelligence & Collusion: When Computers Inhibit Competition’. University of Illinois Law Review, 1775. ↩︎ 3. Salcedo, B (2015). ‘Pricing Algorithms and Tacit Collusion’. Working paper. ↩︎ 4. Calvano, E., Calzolari, G., Denicolò, V., & Pastorello, S. (2020). ‘Artificial Intelligence, Algorithmic Pricing, and Collusion’. American Economic Review, 110(10), 3267–97. ↩︎ 5. Klein, T. (2021). ‘Autonomous Algorithmic Collusion: Q-Learning Under Sequential Pricing’. RAND Journal of Economics 52, 538 to 558. ↩︎ 6. Asker, J., C. Fershtman, and A. Pakes (2023). ‘The impact of artificial intelligence design on pricing’, Journal of Economics and Management Strategy, 33(2):276–304. ↩︎ 7. Harrington, J. E. (2018). ‘Developing Competition Law for Collusion by Autonomous Artificial Agents’. Journal of Competition Law & Economics. Harrington J. E. (2025). ‘Hub-and-Spoke Collusion with a Third-Party Pricing Algorithm’. ↩︎ 8. Fish, S., Y. A. Gonczarowski, and R. I. Shorrer (2025). ‘Algorithmic Collusion by Large Language Models’. arXiv preprint. ↩︎ 9. Assad, S., R. Clark, D. Ershov, and L. Xu (2024). ‘Algorithmic pricing and competition: Empirical evidence from the German retail gasoline market’. Journal of Political Economy, 132(3): 723 to 771. ↩︎ 10. Musolff. L. (2025). ‘Algorithmic Pricing, Price Wars and Tacit Collusion: Evidence from E-Commerce’. ↩︎ 11. The OECD has also done some work in this area. OECD (2017). ‘Algorithms and Collusion’, Roundtable on Algorithms and Collusion, DAF/COMP(2017)4. Also OECD (2023). ‘Algorithmic competition’, OECD competition policy roundtable background note. ↩︎ 12. Keppo, J., Li, Y., Tsoukalas, G., and Yuan, N. (2026). 'On the Fragility of AI Agent Collusion'. ↩︎ 13. Deng, A. (2024). ‘What do we know about algorithmic collusion now? New insights from the latest academic research’. Mimeo. ↩︎ 14. Nikandrova, A. and Parekh, A. (2025). ‘Algorithmic Exclusion by Large Language Models’. ↩︎ 15. Motwani, S. R., M. Baranchuk, M. Strohmeier, V. Bolina, P. H. S. Torr, L. Hammond, and C. S. d. Witt (2024). ‘Secret Collusion among Generative AI Agents’. Mimeo. ↩︎ 16. Ghaemi, M. S. (2025). ‘A survey of collusion risk in LLM-powered multi-agent systems’. In Socially Responsible and Trustworthy Foundation Models at NeurIPS 2025. ↩︎ *[LLM]: large language model

The UK’s digital markets competition regime is designed to promote competition to deliver improved outcomes for businesses and consumers. Since it came into force in January 2025, we’ve been working to put it into action in an effective, pragmatic way. We designated Apple and Google’s mobile platforms with strategic market status in October, and before that published a roadmap which set out clear, measurable proposals to promote competition and improve outcomes in this critical digital market. Since designation, both Apple and Google have engaged constructively with the CMA on a range of these areas and today we have announced immediate changes across many of the issues we identified as highest priority. The changes will give businesses greater transparency over how the apps they bring to market are reviewed and ranked, how their data is used and provide a new method for developers to request interoperable access to specific functionality within Apple’s iOS and iPadOS. As part of the commitments process, the CMA will closely monitor Apple and Google’s implementation of the changes and will report publicly on what it finds. The changes are part of an ongoing programme of work and updates on further measures are expected in the coming months. These include ensuring businesses can get fairer terms for distributing their apps to customers, and making sure innovative businesses like fintechs can access the tools they need to compete fairly with Apple’s digital wallet. ## **Why Apple and Google’s app store services matter** The UK has a vibrant app developer community, representing Europe’s largest app economy by revenue and app developer count. In total, the UK app economy generates an estimated 1.5% of the UK’s GDP and supports around 400,000 jobs here. App-led innovation has powered the success of strategically important sectors for the UK, like financial services and gaming. It is essential that this part of the digital economy works well. To reach users with Apple mobile devices, app developers have no choice but to distribute on Apple’s App Store. While other options are available, Google’s Play Store is by far the main distribution channel for app developers seeking to reach Android users. These app stores are therefore essential for app developers, and it is important they are treated fairly and have confidence and certainty they will be able to serve their customers and bring new innovations forward. This is especially important for key services like banking and payment apps and ensures UK consumers have access to a wide range of products and services on their mobile devices. ## **Our proposed measures** Apple and Google have worked with the CMA and offered commitments to immediately and effectively address our concerns relating to app store processes. The commitments are intended to provide app developers with confidence that they will be treated fairly by Apple and Google and are designed to boost the UK’s app economy. They include:​ * ​**app review:**  Ensuring app reviews are conducted in a fair, objective and transparent way and don’t discriminate against apps which compete with their own. Plus providing clear expectations for the time taken for app review, clear explanations when apps are rejected, prompt notification of changes to app review policies and guidelines, and mechanisms to complain and appeal decisions * **app ranking:**  Ensuring the ranking of apps is conducted in a fair, objective and transparent way and does not discriminate against apps which compete with their own or give their own apps an advantage. Plus prompt notification of changes to app ranking policies and guidelines, additional transparency around how apps are ranked, and channels to receive complaints * **use of data:**  Ensuring app developers data is not used to inform the development of their own apps, additional transparency around how access to app developer’s data is controlled and in relation to data separation mechanisms, products and services, and channels to receive complaints * **interoperability process:**  Commitment for Apple to provide a fair, objective and timely dedicated feedback channel for requests for interoperable access to functionality, to provide transparency around the criteria for considering such requests, provide developers with regular updates on their requests, and communicate when new interoperable access to functionality is rolled out ​To ensure compliance, the CMA will closely monitor Apple and Google’s implementation of the changes, reporting publicly on what we find. Metrics provided by Apple and Google will include those in relation to: * proportion of apps submitted for review, approved, rejected and appealed * time taken for app review * the number of complaints received and outcomes of these * interoperability requests received, outcomes and timeliness We will move quickly to bring forward conduct requirements, including considering whether more stringent measures are necessary, if these commitments are not adhered to or we find they are proving ineffective. For example, if we find Apple is routinely declining interoperability requests without good reason, this will inform our pipeline of wider work – and we could bring forward specific interoperability requirements. Non-compliance would also mean we would be unlikely to consider commitments as a similar approach in future for that SMS firm. ## **A  swift, pragmatic and effective approach** It is a unique strength of the UK’s digital markets competition regime that we can achieve improvements in conduct and market outcomes in a range of ways, from voluntary conduct by firms through to negotiated commitments backed up by monitoring and reporting, legally binding conduct requirements, pro-competition interventions and enforcement. Our goal is to deliver meaningful outcomes to UK consumers and businesses as swiftly and effectively as possible, taking into account the particular circumstances of the issue we are looking to address and building on the participative approach where possible. Commitments can deliver swift and uncontested market improvements but will not be appropriate in all circumstances. For example, we are unlikely to pursue commitments where there is significant divergence between us and a firm on what we are looking to achieve, where firms have little incentive to change their conduct, where compliance is difficult to determine, observe or monitor, where measures can be easily circumvented, or where an SMS firm’s historical conduct does not give us confidence it will work constructively with us. We consider there are good reasons to consider commitments in relation to these specific issues. Apple and Google already have processes in place to ensure fair, transparent and objective app review, app ranking and use of data. However, some of these processes and procedural safeguards are not sufficiently transparent and many stakeholders do not trust that these processes are being followed. This lack of trust in itself has implications – with app developers (and their investors), less willing to develop new propositions, particularly those competing with Apple and Google’s own, for fear of how they could be treated. In these circumstances, the focus of these commitments is on increased transparency and robust monitoring to give app developers confidence they will be treated fairly. Similarly in relation to Apple’s interoperability process, we heard concerns that it was unclear how developers could raise requests for interoperability with Apple or how they would be considered, and a lack of confidence that such requests would be treated fairly and objectively. The focus in these commitments is in making this process transparent and accessible for developers and ensuring their requests are fairly considered. ## **Our wider work and next steps** We welcome views on the proposed commitments and our approach by 3 March. Subject to stakeholder views, the commitments will take effect from 1 April 2026. Alongside this work on commitments, we are also pursuing a wide programme of work in relation to mobile platforms in 2026. In particular, we are expecting to continue engaging with Apple, Google and wider stakeholders and update on our work in relation to steering for both Apple and Google, and digital wallets for Apple in the first half of 2026. In 2026 we will also progress work in relation to Apple on browsers, and interoperable access to functionality for connected devices, as well as continuing to closely monitor developments in relation to mobile platforms, particularly the emergence and adoption of AI.

<figure class="wp-block-post-featured-image"><img fetchpriority="high" decoding="async" width="1620" height="1080" src="https://competitionandmarkets.blog.gov.uk/wp-content/uploads/sites/149/2026/02/Copy-of-Blog-template-2.png" class="attachment-post-thumbnail size-post-thumbnail wp-post-image" alt="Update on our approach to market interventions" style="object-fit:cover;" srcset="https://competitionandmarkets.blog.gov.uk/wp-content/uploads/sites/149/2026/02/Copy-of-Blog-template-2.png 1620w, https://competitionandmarkets.blog.gov.uk/wp-content/uploads/sites/149/2026/02/Copy-of-Blog-template-2-310x207.png 310w, https://competitionandmarkets.blog.gov.uk/wp-content/uploads/sites/149/2026/02/Copy-of-Blog-template-2-620x413.png 620w, https://competitionandmarkets.blog.gov.uk/wp-content/uploads/sites/149/2026/02/Copy-of-Blog-template-2-768x512.png 768w, https://competitionandmarkets.blog.gov.uk/wp-content/uploads/sites/149/2026/02/Copy-of-Blog-template-2-1536x1024.png 1536w" sizes="(max-width: 1620px) 100vw, 1620px" /></figure> <p>At the Competition and Markets Authority (CMA), we promote competition and protect consumers with a clear end goal – driving economic growth and improving household prosperity.</p> <p>Our market reviews, studies and investigations are 3 powerful tools here: they allow us to examine entire markets and find opportunities to make them work better for everyone.</p> <h3 class="wp-block-heading"><strong>Our journey through the 4Ps</strong></h3> <p>In July 2025, our Chief Executive Sarah Cardell explained why we are <a href="https://competitionandmarkets.blog.gov.uk/2025/07/24/transforming-our-approach-to-market-interventions/" target="_blank" rel="noreferrer noopener">transforming our approach to market interventions</a>. She highlighted the fundamental changes we have been making to ensure our work supports economic growth, reduces uncertainty for businesses and investors, and delivers better outcomes for everyone.</p> <p>Central to this is our <a href="https://competitionandmarkets.blog.gov.uk/2025/02/13/new-cma-proposals-to-drive-growth-investment-and-business-confidence/" target="_blank" rel="noreferrer noopener">new framework</a>, shaped by feedback from stakeholders and built around the 4Ps:</p> <ul class="wp-block-list"> <li><strong>pace</strong>&nbsp;– acting more swiftly to deliver timely outcomes</li> <li><strong>predictability</strong>&nbsp;– providing clarity on our processes and expectations</li> <li><strong>proportionality</strong>&nbsp;– ensuring our actions are balanced and targeted</li> <li><strong>process</strong>&nbsp;– improving how we engage with stakeholders throughout our work</li> </ul> <p>Alongside Sarah’s blog post we published our&nbsp;<a href="https://www.gov.uk/government/publications/cmas-approach-to-markets-work" target="_blank" rel="noreferrer noopener">updated approach to markets work</a>,&nbsp;which set out how we will apply the 4Ps through a project’s full life cycle and beyond.</p> <p>We have already started to embed our 4Ps approach in our ongoing work, such as our <a href="https://www.gov.uk/cma-cases/civil-engineering-market-study" target="_blank" rel="noreferrer noopener">civil engineering for road and rail market study</a>, which aims to improve outcomes in road and rail infrastructure – a sector that not only impacts consumers directly, but is also vital to driving economic growth.</p> <h3 class="wp-block-heading"><strong>New markets regime guidance</strong></h3> <p>Today we’ve taken another step to fully embed the 4Ps, by publishing <a href="https://www.gov.uk/government/publications/market-studies-and-market-investigations-supplemental-guidance-on-the-cmas-approach" target="_blank" rel="noreferrer noopener">new guidance on how we carry out our markets work</a>. This guidance consolidates our approach into 1 document, largely replacing all of our existing guidance documents. It will apply to all new market reviews, market studies and market investigations.</p> <p>In the new guidance, we have made a series of interconnected changes to deliver improvements consistent with the 4Ps. The changes include the following.</p> <ul class="wp-block-list"> <li>we will publish a <strong>project roadmap</strong> at the outset of each market review, study or investigation to provide a more predictable, transparent and open approach to how we intend to run each markets project</li> <li><strong>sector expertise and experience</strong> may be brought in to help us develop our understanding of the market at pace, allowing us to move more quickly to assessing and addressing concerns in the market</li> <li><strong>enhanced and earlier engagement with parties</strong> will support a participative approach to our markets work, provide parties with greater predictability on next steps and greater visibility on possible concerns at an earlier stage of markets work</li> <li>we will use <strong>‘sunset’ clauses</strong> as a default, meaning that the remedies we impose after a market investigation will fall away after a set period, unless the CMA judges that there is good reason for them to remain in place</li> </ul> <p>The guidance also gives:</p> <ul class="wp-block-list"> <li>more clarity on how we use <strong>remedy trials</strong> – these should benefit businesses and consumers by allowing us to test the way information remedies are implemented before they are fixed and very unlikely to change</li> <li>updated information about <strong>remedy reviews</strong>, which can reduce burdens on business where remedies are no longer needed – including on broad-based ‘strategic reviews’ like the <a href="https://www.gov.uk/government/news/cma-regulatory-review-aims-to-ease-the-burden-on-businesses" target="_blank" rel="noreferrer noopener">one we launched last month</a> that covers 33 market remedies </li> </ul> <h3 class="wp-block-heading">What stakeholders told us</h3> <p>We <a href="https://connect.cma.gov.uk/consultation-on-markets-regime-guidance" target="_blank" rel="noreferrer noopener">consulted on draft guidance</a> last year to get valuable feedback from stakeholders – thank you to everyone who responded.</p> <p>Many responses welcomed us adopting the 4Ps in our markets work, and supported us consolidating our guidance into 1 document. We were encouraged by comments that supported the aims of the guidance, and recognised the clarity we are looking to give. It was also noted our proposed changes reflected pragmatic, long-term thinking and a readiness to adapt our processes where necessary.</p> <p>Some responses suggested that we elaborate on certain areas and give specific examples. Listening to this feedback, we have added more detail where appropriate.</p> <h3 class="wp-block-heading"><strong>A new regime to come?</strong></h3> <p>While the legislation that governs our markets work provides statutory time limits, this still means a market study could last up to 12 months, followed by a market investigation of up to 18 or 24 months. We are clear that an end-to-end process lasting, in some cases, up to 3 years is not consistent with minimising unnecessary burdens and uncertainty on businesses in nearly all cases. We must seek to complete our work as quickly as possible.</p> <p>The UK government has launched a consultation on <a href="https://www.gov.uk/government/consultations/refining-our-competition-regime" target="_blank" rel="noreferrer noopener">proposed reforms to the competition regime</a>, including changes to our markets work. The proposals to change our markets regime include:</p> <ul class="wp-block-list"> <li>replacing the existing market study and market investigation model with a new single-phase market review tool</li> <li>measures to ensure market remedies remain necessary and proportionate</li> <li>a new decision-making model for the markets and mergers regimes, to enhance the CMA Board’s involvement and accountability while safeguarding CMA independence from government in its decision making</li> </ul> <p>The CMA welcomes these proposals, which build on our 4Ps programme, and would further enhance our work which helps secure well-functioning markets that serve the interests of the whole of the UK.</p> <p>There may need to be changes to our new markets regime guidance in future, if changes to the markets regime are enacted. However, we believe the core of the approach adopted in this guidance – reflecting as it does our commitment to delivering impact at pace while minimising burdens – is the right one and will endure.</p>

<figure class="wp-block-image size-large"><img fetchpriority="high" decoding="async" width="620" height="413" src="https://competitionandmarkets.blog.gov.uk/wp-content/uploads/sites/149/2026/01/Search-CRS-blog-620x413.png" alt="Improving the way Google delivers search services in the UK" class="wp-image-4268" srcset="https://competitionandmarkets.blog.gov.uk/wp-content/uploads/sites/149/2026/01/Search-CRS-blog-620x413.png 620w, https://competitionandmarkets.blog.gov.uk/wp-content/uploads/sites/149/2026/01/Search-CRS-blog-310x207.png 310w, https://competitionandmarkets.blog.gov.uk/wp-content/uploads/sites/149/2026/01/Search-CRS-blog-768x512.png 768w, https://competitionandmarkets.blog.gov.uk/wp-content/uploads/sites/149/2026/01/Search-CRS-blog-1536x1024.png 1536w, https://competitionandmarkets.blog.gov.uk/wp-content/uploads/sites/149/2026/01/Search-CRS-blog.png 1620w" sizes="(max-width: 620px) 100vw, 620px" /></figure> <p>The <a href="https://www.gov.uk/guidance/how-the-uks-digital-markets-competition-regime-works">digital markets competition regime </a>allows the CMA to design proportionate, targeted interventions to address specific issues. Our strategy is purposeful and pragmatic – rooted in real world context, leveraging the unique design of the UK regime to deliver tangible benefits for the UK economy. Throughout, the CMA is applying its <a href="https://competitionandmarkets.blog.gov.uk/2025/02/13/new-cma-proposals-to-drive-growth-investment-and-business-confidence/">‘4Ps’ - proportionality, pace, predictability and process</a> – to ensure we avoid hampering innovation or creating uncertainty for businesses and investors.</p> <p>Today we’re proposing a package of measures to improve how <a href="https://www.gov.uk/cma-cases/sms-investigation-into-googles-general-search-and-search-advertising-services">Google delivers search services in the UK</a>. Our goal is to support innovation and growth, ensure people benefit from a high-quality digital experience, deliver fairer outcomes for content publishers and help businesses and consumers make active, informed choices. This is an important milestone, as these are the first set of conduct requirements under the digital markets competition regime.</p> <h2 class="wp-block-heading">Why Google’s search services matter</h2> <p>Google handles more than 90% of general search queries in the UK. Millions of people rely on it as a gateway to the internet, and over 200,000 UK firms spent more than £10 billion on Google search advertising last year. Search is central to the economy and everyday life – and increasingly relies on AI-generated responses – so it is essential that competition works well.</p> <h2 class="wp-block-heading">Our proposed measures</h2> <p>In June 2025, we set out a <a href="https://www.gov.uk/cma-cases/sms-investigation-into-googles-general-search-and-search-advertising-services#roadmap-of-possible-measures-to-improve-competition-in-search">roadmap of potential measures</a>. We are now consulting on the detailed design of those we have prioritised, focusing on 4 areas:</p> <h3 class="wp-block-heading">1. Publisher content</h3> <p>We want publishers to have greater choice, transparency and attribution in how their content is used in Google’s AI features, such as AI Overviews. We propose that Google should:</p> <ul class="wp-block-list"> <li>give publishers a meaningful <strong>choice</strong> over how their content is used in AI-generated responses within and outside search</li> <li>be more <strong>transparent</strong> about how publisher content feeds into AI-generated responses in search, and how people use these features</li> <li>properly <strong>attribute</strong> publisher content in AI results and clearly explain how this works</li> </ul> <p>These measures will give publishers – including news and other content producers – stronger bargaining power and support the long-term sustainability of trusted information online. They will also help people verify sources in AI-generated results and build trust in what they see.</p> <h3 class="wp-block-heading">2. Fair ranking</h3> <p>We want Google’s approach to ranking search results – including AI-generated results – to be fair and transparent for businesses. Our proposals would require Google to:</p> <ul class="wp-block-list"> <li>rank organic results fairly by, for example, not favouring websites that advertise on Google or have entered into&nbsp;other commercial&nbsp; arrangements with Google</li> <li>provide more information on how it ranks results, including in AI Overviews and AI Mode</li> <li>strengthen complaints processes for ranking issues so that, where changes have significant impacts on UK businesses, Google will assess and explain steps it will take to minimise them</li> <li>these measures will give publishers confidence that Google ranks search results fairly and have greater ability to plan for changes that affect their business, which in turn should result in greater confidence to invest in their products and services</li> </ul> <h3 class="wp-block-heading"><strong>3. Choice screens</strong></h3> <p>We want it to be easier for people to choose and switch their search service. We propose that Google should:</p> <ul class="wp-block-list"> <li>display a choice screen on key access points including Android devices and the Chrome browser</li> <li>make it quick and simple for people to change their default search service at any time</li> </ul> <h3 class="wp-block-heading">4. Data portability</h3> <p>We want people and businesses to be able to make better use of their search data.</p> <p>We propose that Google should place its existing data portability tool on a legal footing. This will ensure that people can continue to transfer search data between services or use third-party tools alongside Google’s products.</p> <p>This measure will give certainty to innovative start-up and scale-up businesses so they can invest and innovate in new data-driven services. Businesses could also help people use their own search data to get discounts, rewards, useful insights, or other benefits.</p> <h2 class="wp-block-heading">What’s next?</h2> <p>We are <a href="https://connect.cma.gov.uk/google-search-conduct-requirements">inviting views on these proposed requirements</a> and, after reviewing responses, will confirm any measures to be imposed on Google.</p> <p>We also continue to assess the other measures in our <a href="https://www.gov.uk/cma-cases/sms-investigation-into-googles-general-search-and-search-advertising-services#roadmap-of-possible-measures-to-improve-competition-in-search">June 2025 roadmap</a>. Those not identified as early priorities remain deprioritised. In relation to publishers, we will wait for 12 months to see the impact of our initial measures before deciding whether to take further action in ensuring they receive fair and reasonable terms for their content. Other potential measures relate to action in other jurisdictions, including the US (where a final remedies judgment in an important case was made in December) and the EU (where, amongst other things, Google’s compliance with a requirement about self-preferencing is being investigated). We are assessing what these developments mean for the UK.</p> <p>Future decisions will be guided by the CMA’s <a href="https://www.gov.uk/government/publications/cma-prioritisation-principles">prioritisation principles</a> and <a href="https://www.gov.uk/government/publications/strategic-steer-to-the-competition-and-markets-authority/strategic-steer-to-the-competition-and-markets-authority">government’s Strategic Steer</a>.</p> <p></p>

<figure class="wp-block-image size-large"><img fetchpriority="high" decoding="async" width="620" height="413" src="https://competitionandmarkets.blog.gov.uk/wp-content/uploads/sites/149/2026/01/Emma-Cochrane-620x413.png" alt="Emma Cochrane" class="wp-image-4283" srcset="https://competitionandmarkets.blog.gov.uk/wp-content/uploads/sites/149/2026/01/Emma-Cochrane-620x413.png 620w, https://competitionandmarkets.blog.gov.uk/wp-content/uploads/sites/149/2026/01/Emma-Cochrane-310x207.png 310w, https://competitionandmarkets.blog.gov.uk/wp-content/uploads/sites/149/2026/01/Emma-Cochrane-768x512.png 768w, https://competitionandmarkets.blog.gov.uk/wp-content/uploads/sites/149/2026/01/Emma-Cochrane-1536x1024.png 1536w, https://competitionandmarkets.blog.gov.uk/wp-content/uploads/sites/149/2026/01/Emma-Cochrane-2048x1365.png 2048w" sizes="(max-width: 620px) 100vw, 620px" /></figure> <hr class="wp-block-separator has-alpha-channel-opacity" /> <p>The government has <a href="https://www.gov.uk/government/news/pm-were-capping-ground-rents-at-250">set out plans to introduce a cap on existing ground rents to £250 a year</a>, changing to a peppercorn after 40 years, in another major step towards making sure all leaseholders get the fair deal they deserve.<br><br>These proposals should spell an end to rising ground rent fees and help people struggling with high ground rents – particularly when many are already grappling with costs elsewhere.<br><br>Since 2019, we have been tackling the sale and use of doubling ground rent terms, which saw people trapped in homes they couldn’t sell or mortgage, and their property rights at risk if they fell behind on payments.<br><br>Our investigation, involving leading housing developers and businesses who purchased freeholds from these firms, led to landmark changes which freed over 21,000 households from problematic leasehold issues.</p> <p>This included:</p> <ul class="wp-block-list"> <li>March 2024: <a href="https://www.gov.uk/government/news/cma-frees-hundreds-more-leaseholders-from-costly-contract-terms">8 freeholders agree to strike out doubling terms from their leaseholders’ contracts</a></li> <li>August 2022: <a href="https://www.gov.uk/government/news/thousands-more-leaseholders-to-get-money-back">9 businesses who purchased freeholds from Taylor Wimpey commit to remove problematic doubling terms</a>. Developers Crest Nicholson, Miller Homes, Redrow and Vistry agree to help remove doubling terms from leasehold contracts they sold on</li> <li>March 2022: <a href="https://www.gov.uk/government/news/thousands-more-leaseholders-freed-from-rising-ground-rents">15 businesses who bought freeholds from Countryside</a> remove doubling ground rent terms</li> <li>December 2021: <a href="https://www.gov.uk/government/news/cma-action-frees-leaseholders-from-costly-contract-terms">Taylor Wimpey removes doubling ground rent terms, and RPI-based terms</a> that were originally doublers, from all its contracts</li> <li>September 2021: <a href="https://www.gov.uk/government/news/leaseholders-freed-from-costly-contract-terms">Countryside Properties removes doubling ground rent terms</a> in relation to freeholds it owns</li> <li>June 2021: <a href="https://www.gov.uk/government/news/cma-secures-landmark-commitments-for-leaseholders">Persimmon offers leasehold house owners the opportunity to buy the freehold of their property at a discounted price</a> that better reflects what they expected when they originally bought their home</li> <li>June 2021: <a href="https://www.gov.uk/government/news/cma-secures-landmark-commitments-for-leaseholders">Aviva removes doubling ground rent terms</a> in relation to freeholds it bought</li> </ul> <p>While we were successful in helping thousands of leaseholders get out of doubling ground rent terms, problematic ground rents continue to be a major issue for homeowners across the country. Government intervention in this area is likely to be the only way to achieve an effective, long-lasting solution.<br><br>High ground rents can cause a wide range of problems, even where they don’t double. During our investigation, we saw no persuasive evidence that ground rent was either legally or commercially necessary, or that consumers received anything in return for paying these annual fees. But we also recognise that changes to ground rents have implications for freeholders.</p> <p>Ultimately, we believe it is right that the government has put forward proposals which seek to strike a balance between the interests of both leaseholders and freeholders.</p> <hr class="wp-block-separator has-alpha-channel-opacity" /> <p><a id="_msocom_1"></a></p>

In our 2023 road fuel market study we found that competition in the UK road fuel market was not working as well as it should be, and that, by making it easier for drivers to compare up-to-date prices, they could more easily find the cheapest prices in their area, and retailers would have to compete harder for their business. To achieve this, we recommended to government that it should introduce a statutory open-data fuel finder scheme, to give drivers access to live fuel prices at forecourts. The government accepted our recommendation and is implementing ‘Fuel Finder’. From early next year, drivers will benefit from access to near-real time pricing data through third-party apps, sat navs and other tools signed up to Fuel Finder. The government has given the Competition and Markets Authority (CMA) the role of enforcing compliance with Fuel Finder. We will decide whether the Fuel Finder requirements have been breached and if so, we will take action to tackle these breaches – this includes fines. We are committed to taking effective and proportionate enforcement action to enable consumers across the UK to shop with confidence and find the best deal for them, and to reinvigorate price competition in the UK road fuel market. In October, we consulted on draft guidance setting out how we would enforce compliance with Fuel Finder. We are now finalising the guidance for publication in December. In preparation for this, we are today providing an update to support businesses as they prepare to comply with the new regime. ## **Update on our consultation and next steps** In response to our consultation, we have received helpful and constructive feedback from a range of stakeholders. Recognising that the requirements are new and that the consequences of getting it wrong could be severe, businesses – large and small – have said that they would welcome greater clarity on how our enforcement processes will work, in particular: * when we will use our powers * what action we will take * how we will determine the level of any fines We intend to make this clearer in our guidance. ## **Enforcement priorities** Businesses have told us that they would also welcome clarity on our approach to enforcement. Most businesses work hard to serve their customers and do the right thing, but they may need help to understand their new legal obligations, particularly in the early days of the new regime. We also recognise that – especially for small businesses – following the rules will also have ongoing resource implications. However, it is also important for businesses that follow the rules that action is taken to ensure their competitors cannot gain an unfair advantage by failing to meet their obligations under the law. Recognising that the new provisions may require changes to systems and compliance functions, for at least 3 months from the date forecourts must be registered with Fuel Finder and must start reporting price changes (from 2 February 2026 until beginning May 2026), our focus will be on supporting businesses to comply with the new regime rather than enforcement action. Looking further ahead, once the regime is established, we expect to target enforcement action against the conduct which is most likely to undermine the effectiveness of Fuel Finder, and which is likely to be more harmful to consumers and competition. Our focus will therefore be on ensuring businesses register with Fuel Finder and that pricing information is accurately provided, rather than on amenities and facilities, which are unlikely to be priorities for enforcement except where significant harm has been identified. ## **Find out what else we’re doing to help motorists** The CMA also has a statutory monitoring function in relation to road fuel, and publishes regular reports on fuel prices, retail spreads and fuel margins. You can read more about the CMA’s monitoring role on our road fuel price data scheme page.

Black Friday is all about big savings, but beware – some ‘deals’ may not be as good as they seem. The CMA helps people, businesses and the UK economy by promoting competitive markets and tackling unfair behaviour. When you’re hunting for bargains this Black Friday, we have your back. We want you to feel confident that you: * know shopping around can help you find the best deal * are not misled into paying for something you don’t want, or wouldn’t choose if you had the full picture * can use your legal rights if things go wrong We’ve pulled together some quick, practical tips to help you shop smart, avoid being misled, and skip those post-sale regrets. You’ll also find direct links to the relevant parts of consumer law – perfect if you need to stand your ground or raise an issue. ## AI can help you hunt down deals, but take care AI can be brilliant for scouting out bargains fast, comparing prices across retailers and even checking price history to spot genuine savings. But AI isn’t foolproof. It can sometimes generate incorrect or misleading results, and can miss things like fake reviews. To get the most accurate results: * use clear and specific instructions – for example, ask it to factor in any extra costs, such as delivery or insurance, and to look at pricing trends * verify any recommendations by looking on the retailer’s website to make sure the AI tool hasn’t missed or misinterpreted something important ## Your consumer rights don’t disappear in a sale Under the Consumer Rights Act 2015, items bought in a sale must still be of a satisfactory quality (not broken or damaged), fit for purpose, and match the original description. If this isn’t the case, they can be returned for a refund, repair, or replacement. For more information about the law go to: * Section 9 of the Consumer Rights Act, which states that any goods you buy must be of a satisfactory quality * Section 10, which states that goods must be fit for purpose * Section 11, which states that goods must be as described ## If it’s faulty, get a refund If the item you buy turns out to be faulty, or doesn’t match how the seller described it, then you have 30 days to request a full refund – even if you bought the item on sale. If the fault appears after 30 days, the seller must offer a repair or replacement, and if that doesn’t work, you can still request a refund. Equivalent rules apply to services and digital products too – so if something’s wrong with your game, app or subscription, the seller should fix the problem or give you a refund. Remember that you have rights under the Consumer Rights Act 2015: * for your right to reject a faulty item, go to Section 20.4 of the Consumer Rights Act * for the time limits for rejecting a faulty item, go to Section 22.3 * for digital products, go to Section 42.2 Citizens Advice also has a handy guide to refund processes. ## Even in a sale, it pays to shop around It might sound obvious, but shopping around can make a big difference. Prices can vary significantly, even during major sales, so it’s worth checking several retailers to help get the best possible deal. Price comparison sites can help – but beware, some companies can pay to bump their products up the rankings, even if they aren’t the cheapest, so it’s worth doing your research. ## Don’t panic – take a moment before hitting ‘buy’ Take a moment to check when the sale actually ends – some may be very short, but others continue for several weeks beyond Black Friday. Claims like ‘Lots of people looking at this!’ or ‘Only a few left!’ should be taken with a pinch of salt – the item might not be about to sell out. We’ll continue to take action to crack down on practices like these where we have concerns they risk being misleading, but it’s still a good idea to have a wish list and budget to keep you on track and avoid being pressured into purchasing. > Some companies can pay to bump their products up the rankings, even if they aren’t the cheapest, so it’s worth doing your research ## Know your payment protections If you pay by credit card for items over £100, you have legal protection that means you can claim for a refund if the company goes bust or your item doesn’t arrive, or if there are certain other problems such as an item being faulty or not as described. For smaller purchases, chargeback can help recover your spends, but it’s not a legal right and usually doesn’t apply to app payments like PayPal or Klarna (which have their own limited protection schemes). Citizens Advice has a helpful guide to getting your money back if things go wrong – and see Section 75 of the Consumer Credit Act 1974 for what the law says. ## Scams spike during Black Friday, so stay alert Black Friday is prime time for scammers, but luckily, there are ways to protect yourself. Avoid clicking on links in unexpected emails or texts. Instead, go directly to the retailer’s website. Use tools like Get Safe Online to check if a website is legit. And beware of QR codes – they can hide malicious links that take you to phishing scams. Use a secure app on your phone to preview the link before clicking go. Importantly, if you think you’ve been scammed, don’t panic. Contact your bank or credit card provider: you may be entitled to a refund via chargeback or Section 75 protection (as explained above). Report the scam to Action Fraud as soon as possible. Action Fraud is the reporting centre for fraud and online scams in England, Wales and Northern Ireland. You can report online or call them on 0300 123 2040. If you’re in Scotland, report the crime to Police Scotland. ## If you change your mind, cancel the purchase You have 14 days after receipt to cancel online purchases if you change your mind, even if it isn’t faulty. The Consumer Contracts (Information, Cancellation and Additional Charges) Regulations 2013 give you a cooling-off period for online, phone or mail orders – but be aware, you could have to pay for the cost of the return. Read more about cancelling goods or services. > The CMA works with Citizens Advice and Trading Standards to tackle consumer issues that are widespread or particularly damaging ## If your delivery is late or missing, the seller (not the courier) is responsible Contacting the courier is a great first step, but if problems persist then speak to the seller. Under the Consumer Rights Act 2015, sellers must deliver goods within 30 days unless agreed otherwise – and they’re legally responsible if things go wrong. For more information about the law, go to Part 1, Chapter 2, Section 28.3b of the Consumer Rights Act 2015. ## If you spot something dodgy, report it Tell Citizens Advice about misleading discounts, dodgy claims, unsafe products, and problems resolving issues with a retailer. They can offer advice on what to do and advise on your rights. They can also pass serious cases over to Trading Standards, who have legal powers to investigate. The CMA works with both organisations to tackle consumer issues that are widespread or particularly damaging. We’re serious about cracking down on illegal practices that give false information to consumers, or risk misleading shoppers. With our new legal powers, we will be able to decide whether consumer protection laws have been broken, and to sanction businesses that fail to comply. We will also help businesses to comply with the law. ## Find more advice The CMA offers a lot more help for consumers, including guides to your rights in specific areas. For help with your problem, contact the relevant consumer advice organisation where you are. We also have guidance to help businesses comply with consumer law when selling goods and services, including on treating customers fairly and on giving refunds.

The Competition and Markets Authority's (CMA) leniency regime is a powerful tool in the fight against cartels. Since the publication of our previous leniency guidance 12 years ago, we have received nearly 250 leniency applications. Cases with leniency applicants have resulted in more than £355 million in financial penalties and the disqualification of 24 company directors. Following a public consultation, we have updated our leniency guidance to: * ensure incentives to apply for leniency continue to support the CMA’s enforcement objectives of deterring and taking action against harmful cartels * reflect current law – including the new debarment regime for cartelists introduced by the Procurement Act 2023 – as well as CMA’s current policy and practice * make it more accessible and user-friendly ## Cartel enforcement: a CMA priority Cartels are a particularly damaging form of anti-competitive activity, where rivals agree not to compete so they can gain an unfair advantage. This can lead to higher prices and deprive people of genuine choice, as well as reduce incentives for business efficiency, investment and innovation. The CMA is committed to tackling harmful cartels, so that fair-dealing businesses can innovate and thrive – boosting the economy – and individuals can be confident that they are getting great choices and fair deals. An effective leniency regime is a crucial part of our strategy to detect and enforce against cartels and it helps ensure that we reach robust outcomes in an efficient way. The leniency regime also helps deter cartels, by making it riskier to be involved in one. ## We proactively detect cartels While leniency will always play an important role in the fight against cartels, it is far from being the only way the CMA detects them. Indeed, over the years we have kept a fairly even balance between own-initiative cases and those that start with a leniency application. Our detection work includes, for example: * gathering intelligence from informants – powered by the offer of financial rewards of up to £250,000 * working with potential victims of cartels – particularly in the public sector, where we are applying our extensive in-house data science expertise to identify anomalies in bidding data and tackle bid-rigging in public procurement * seeking to develop intelligence in economic sectors that are particularly exposed to cartel risk – including in emerging forms such as algorithmic collusion That means we’re finding and stopping harmful cartels regardless of whether a cartelist decides to blow the whistle and apply for leniency – which is why it is important to come forward at the earliest opportunity. ## Being first to apply for leniency matters more than ever The changes we have introduced mean that being a Type A applicant (that is, the first to apply for leniency before the CMA has started to investigate) is the only way to get guaranteed immunity from: * penalties * director disqualification * criminal prosecution * public contract exclusion and debarment Uncovering cartel conduct and adopting a ‘wait and see’ approach by applying for leniency only after a CMA investigation has begun now carries greater risk for businesses. We have removed the availability of upfront immunity for Type B applicants (that is, those who are the first applicant but who have only come forward after we have started to investigate) and clarified that Type B discounts are unlikely to be above 75% (reflecting our practice to date). We have also removed automatic director disqualification protection for Type B and C applications (Type C applicants are those who apply after the first applicant). Such protection is now discretionary and will ensure that directors are only immunised from disqualification when this is in the public interest, thereby protecting the public by removing unfit directors. ## **Making our guidance clearer and processes better** We also wanted to ensure that the leniency guidance is as clear, accessible and user-friendly as possible. We have done this by: * changing the structure of the guidance to follow the natural chronology of a leniency application * refreshing our short guides, to provide both businesses and individuals with an overview of how the leniency policy works * introducing an online tool to make submitting an application quicker and easier – this will now be the default method for applications that would otherwise be made orally Another important update was to the definition of ‘cartel activity’, so that it reflects the latest case law and CMA guidance and practice, while being flexible enough to cover cartel conduct that may be considered to fall within the policy in the future. We have also provided more examples of the types of conduct for which leniency is available. This includes conduct in labour markets, algorithmic collusion and agreements to limit innovation – for example, in order to meet or exceed a sustainability goal. We also no longer require applicants to confess at the start – something that the business community very clearly told us could have discouraged applications. This is now only needed when signing the leniency agreement, usually just before we issue the statement of objections. If you are thinking of applying and would like more clarity on specific points, we are happy to provide confidential guidance. ## Act now If you suspect you, your business or a client you advise is involved in cartel activity: * read our updated guidance and short guides to cartels and leniency for business and individuals * seek confidential guidance from the CMA if needed * apply for leniency by calling 020 3738 6833

At the CMA, our mission is clear: to promote competition and protect consumers. One of the most powerful ways we do this is through our markets tools, which allow us to examine entire markets and identify opportunities to make them work better for consumers, businesses, and the wider economy. Over the past decade, we’ve used our market tools to: * pave the way for the open banking revolution * help government work out how to improve procurement for children’s home and fostering placements * help drivers get fairer prices at the petrol pump More recently, we’ve made recommendations to government on streamlining the planning system, strengthening consumer protections in housebuilding, and improving outcomes for parents in the infant formula market. ## Why we’re changing our approach As we move beyond our first decade of markets work, now is the right time to reflect on how we use these tools and how we can do so even more effectively. We’ve been making fundamental changes across the CMA to ensure our work supports economic growth, reduces uncertainty for businesses and investors, and delivers better outcomes for everyone. Central to this is our new framework, shaped by feedback from stakeholders, built around the ‘4Ps’: * **Pace**  – acting more swiftly to deliver timely outcomes * **Predictability**  – providing clarity on our processes and expectations * **Proportionality**  – ensuring our actions are balanced and targeted * **Process**  – improving how we engage with stakeholders throughout our work We’ve already started embedding this approach across the rest of the CMA’s work, including mergers, consumer protection and competition enforcement. In setting out how it will apply to our markets work, we are today completing the implementation of the 4Ps framework across the CMA’s major tools. This shift is timely. The UK government’s Regulation Action Plan and the strategic steer to the CMA, both published in May 2025, emphasise the role of regulators in supporting economic growth. Our work should build consumer trust, deter poor corporate practices, and prioritise interventions that boost productivity and growth. Our markets tools are uniquely positioned to help us deliver on this; they are discretionary, so we can focus on markets with the greatest potential to support growth – such as civil engineering for road and rail, into which we have just launched a market study. By improving how competition functions in these markets, we encourage firms to innovate, invest, and raise productivity – often without the need for direct legislative or regulatory intervention. However, we’re also mindful that our work can create uncertainty or impose burdens on businesses – especially if processes are lengthy or unclear, and so we’re committing to minimise these impacts. For example, while the legislation that sits behind our markets work provides statutory time limits, this still means a market study could last up to 12 months, followed by a market investigation of up to 18 or 24 months. We are clear that an end-to-end process lasting, in some cases, up to 3 years is not consistent with minimising unnecessary burdens and uncertainty on businesses in the vast majority of cases. We must seek to complete our work as quickly as possible while securing benefits for consumers, businesses and the wider economy. ## What's changing Our updated approach sets out how we’ll apply the 4Ps from the start of a project through to the full project life cycle and beyond. **Before launching new work** , we’ll provide greater clarity on our priorities, consider burdens to business of complying with any remedies as well as any impact on potential investment, and design our work to choose the lightest, fastest approach that still addresses the issues effectively. **During a project,** we’ll bring in sector expertise early, engage more directly with businesses, and hold ‘state of play’ meetings to reassess the costs and benefits of continuing our lines of inquiry. **At the conclusion of a project** , we’ll assess the costs of remedies more comprehensively, minimise compliance burdens, and put sunset clauses on remedies, removing them when they’re no longer needed. We’re already incorporating these principles into our live projects and will apply them in full to future work. Our goal is a markets regime that delivers real, lasting impact – supporting growth, building trust, and ensuring markets work better for everyone.

## **What’s happening today** Under the new digital markets competition regime, the Competition and Markets Authority (CMA) can take targeted, proportionate action to improve competition in critical digital markets. Today we’ve announced proposals to designate Apple and Google with strategic market status (SMS) in mobile platforms. To provide greater certainty for the market, we have also published roadmaps of potential actions we would take to deliver better outcomes for businesses, consumers and the UK economy. We are consulting on these provisional designations ahead of final decisions in October. Should Apple or Google be designated, we would expect to begin consulting on a first set of interventions from autumn 2025. ## **Why mobile platforms matter to the UK** Almost every adult in the UK has access to a mobile device (a smartphone or tablet) and almost all of these will have a ‘mobile platform’ provided by Apple or Google. Mobile platforms include an operating system; a store where people can download apps; and browser capability so people can access the internet on their mobile device. Currently, 90 to 100% of UK mobile devices run on Apple or Google’s mobile platform. Both Apple and Google also face limited competition on their browsers. Apple’s Safari browser has a 80 to 90% share on Apple’s mobile ecosystem, while Google’s Chrome has a 70 to 80% share of Android users. **As consumers** , these platforms help us search for information, make transactions, connect on social networks, watch videos, and play games. **For UK businesses** , apps are now an important (sometimes sole) route to reach customers – from transport and takeaways, to shopping, finance and fitness. **And for app and web developers** , these 2 platforms are essential gateways through which they must operate to offer their services. The UK has a vibrant app developer community, representing Europe’s largest app economy by revenue and app developer count. In total, the UK app economy generates an estimated 1.5% of the UK’s GDP and supports around 400,000 jobs here. As a result, the app economy is now an engine of UK growth, particularly in strategically important sectors like financial services and creative industries. Fintech stands out, with over half of all UK unicorns and more than £18 billion in inward investment over the past 3 years. Meanwhile, the gaming sector adds £6 billion in GVA, with its fastest-growing segment – mobile gaming – generating nearly £2 billion annually. It is essential that this part of the digital economy works well. To ensure UK consumers benefit from the latest innovations and a high-quality user experience, as well as more choice and lower prices. To power the success of businesses across the economy. And to unlock opportunities for all players in mobile platforms (large and small) to invest, innovate and grow – including UK businesses scaling to become globally competitive. ## **What we have heard so far through our investigations** Apple's and Google's mobile platforms hold an effective duopoly, but they have very different business models. Some of the key concerns across both firms include: * opaque, inconsistent and unpredictable app review processes can create uncertainty for developers, meaning delayed or failed launches. Data accessed during these reviews may also be used to benefit the firms’ own services * opaque app store search ranking criteria may favour apps owned by the firms, discouraging investment by third parties * up to 30% commission on in-app purchases, as well as restrictions on developers ‘steering’ users outside of the app store, for example to complete purchases, could make some business models unviable, reduce consumer choice, and chill innovation * ‘choice architecture’ (like default settings, pre-installation, prominence, prompts, and friction) may favour the firms’ own services, limiting competition and genuine choice for users * revenue-sharing agreements which dampen competition between Apple and Google In relation to Apple, developers can’t offer their apps through other stores or via direct download (‘sideloading’) or use their own payment systems. Other companies must base alternative browsers on Apple’s own browser engine software. Apple’s restrictions on app developers’ access to features and functionality within its operating system can affect a range of customer offerings – from digital wallets and AI services, to how well smartwatches, gaming headsets or health-tech tools connect with iPhones and iPads. This could disadvantage UK app developers and mean UK users miss out on innovations, as well as facing fewer choices and higher costs. While Google allows sideloading and alternative app stores, we have heard that friction and warning screens discourage it in practice. Google’s agreements with device manufacturers (like Samsung and Motorola) also influence which apps are pre-installed and set as defaults, giving its own services a head start and limiting visibility for rivals. ## **Action under the digital markets competition regime** To designate a firm with ‘SMS’, the CMA must demonstrate that it meets 2 legal tests: ‘substantial and entrenched market power’ and a ‘position of strategic significance’. We have provisionally found both Apple and Google to have met these tests in relation to mobile platforms. Action is ongoing around the world to address similar issues to those under investigation here. However, if designated, the unique design of the new regime allows the CMA to address specific UK impact through highly targeted, bespoke and flexible measures. Any action we take must be proportionate to tackle the harms and part of a participative process, including the largest firms, broader market participants, and consumer groups. ## **Roadmaps of possible measures to improve competition in mobile platforms** The CMA is also applying our ‘4Ps’ – proportionality, pace, predictability and process – here, to avoid hampering innovation or creating uncertainty which could chill investment. To support pace and predictability, we’re going further than the legislation requires by publishing a roadmap for each investigation. These lay out the phased approach to actions we might take during the first half of any designation period. Measures outlined in the roadmaps focus on the following areas. Given the important role of both Apple and Google in the distribution of apps a key early priority will focus on ensuring fair dealing for app developers in**app distribution.** * fair and transparent **app review** process, including fair use of data collected * fair and transparent **app store rankings** to give UK app developers certainty * allowing the ability to ‘steer’ users out of app stores, for example to make purchases, potentially driving innovation and financial savings for developers For Apple we will focus on **interoperability** to ensure app developers have access to the functionality they need to innovate and compete: * ensuring requests for interoperability from app developers are considered fairly and objectively * addressing restrictions on functionality to enable UK FinTechs to bring innovative digital wallets to market, as well as to enable connected devices such as smartwatches, gaming headsets or health-tech tools to seamlessly connect with smartphones For both Apple and Google we will focus on **consumer choice** and ensuring consumers have a genuine choice over the services they use on their devices and are not steered to Apple and Google’s own services. We will also explore the factors likely to be important for the development of **AI services** like voice assistants on mobile devices, to ensure a level playing field in this rapidly advancing sector. ## **Wider context** In a number of jurisdictions, such as the EU, the US, Japan, and Brazil, action is underway to drive more competition in mobile platforms. Consumers and businesses are already benefitting from this in other jurisdictions. For example, in the US developers can now steer users outside the Apple app store to complete purchases, leading to tangible improvements – like Spotify offering in-app links for audiobooks and Proton announcing that it is cutting prices for its privacy and encryption services by up to 30%. In the EU, consumers can now choose from a variety of digital wallets offering innovative benefits, like integrated cashback and consolidating purchase information. In line with the CMA’s prioritisation principles and the UK government’s strategic steer, we are carefully observing these developments around the world. Our goal is to ensure any action we take here delivers the best possible outcomes for the UK in the most proportionate way possible. We’re also working closely with other regulators in the UK, like the Financial Conduct Authority, to ensure action in areas like digital wallets is well-coordinated. ## **What next?** In line with our participative approach, we will continue to engage with a broad range of stakeholders as we consult on our proposed designation decisions between now and October. We’re also inviting views on the possible interventions in our roadmaps. If Google or Apple are designated, we would expect to begin consulting on priority interventions from autumn 2025. We expect to provide updated roadmaps in the first half of 2026, reflecting stakeholder views and relevant international developments.

**It is vital that shoppers can access clear and timely pricing information. Knowing what a product will cost is fundamental for them to make good purchasing decisions – working out which product is best for them, and where to buy it.   ** When businesses do not display their prices accurately or leave out essential pricing information that people need to know, it can make products appear cheaper than they are. That can lead to people spending more and undermine people’s trust in markets when they find out the real cost. It also harms fair dealing businesses, preventing them from competing on a level playing field. By promoting competition, and consumer confidence, price transparency benefits the wider UK economy too. We know most businesses want to compete on the merits of their product and give customers all the information they need. Our draft Price Transparency Guidance that we are publishing today, (and consulting on, over the summer), is designed to help businesses comply with the updated provisions on price transparency, that came into force with the Digital Markets Competition and Consumer Act 2024 (DMCCA). In this consultation, we want to hear from businesses on whether there is more that we can do to support them in complying with the law. **When consumers are confident, markets thrive.  ** The CMA has consistently made price transparency a priority. In recent years we have conducted investigations, taken enforcement action and issued guidance across a range of sectors and practices including: * groceries * fuel * online hotel bookings * car rental * green heating and insulation * dynamic pricing We are also in the process of taking enforcement action against Emma Sleep and Ticketmaster under the previous (court-based) regime. The CMA’s investigation into Emma Sleep includes concerns about the use of urgency claims and reference pricing, and the investigation into Ticketmaster includes concerns that consumers were not given clear and timely information about how the pricing of certain tickets would work. ## **Consulting on new guidance** The importance of price transparency is also why it was included in the recent DMCCA, which updated the unfair commercial practices (UCP) provisions in response to concerns about some business practices. The objective of the new law is to change how businesses present their prices, and the CMA recognises that many businesses will need to review and amend their pricing practices to ensure they fully comply with the UCP provisions. Indeed, the CMA has already seen examples of businesses proactively making changes to achieve compliance with the new rules – the CMA welcomes these changes. When we published our updated guidance on the revised UCP provisions (CMA207) we committed to consult further on the new price transparency requirements introduced by the DMCCA to help support businesses to improve their compliance with this new law. The draft guidance we have published today includes guidance on the new law, as well as references to relevant requirements imposed by other UCP provisions in relation to pricing (in particular the prohibitions on misleading actions and omissions) and previous CMA sector guidance (such as online hotel booking and car rental). As set out in the CMA’s approach to direct consumer protection we expect to focus our early enforcement action on the most egregious practices, including fees that are hidden until late in the purchase process because this harms consumers and fair dealing businesses, by hindering effective price competition. At the same time, we want to support businesses to comply with the law, be able to compete on the merits of their product and give their customers all the information they need. The draft guidance we have published today is a key step in this process. We encourage businesses to carefully consider their pricing practices over the next months to ensure they do not fall foul of the law. When businesses get it right, everyone benefits. ## **Share your views with us** **If you own, run, or work for a business that markets products or services to consumers then we want to hear from you.   ** We want to make our guidance as clear and user friendly as possible, with real life examples of how businesses can present their prices in a lawful way. We also recognise that what the new law requires may differ between some products, and in practice between different stages of the purchase process. We welcome feedback on other ways in which businesses might reasonably comply with the requirements introduced by the DMCC Act. ## **Get involved** We are running a series of events that you can **register for now**. * **9 July 2025 , 2pm** : webinar on the draft guidance * **early September:** online event to hear from businesses Industry bodies and trade associations can also** register their interest **for roundtables on the draft guidance on**17 and 24 July 2025**.

Search and Search Advertising are critical for UK consumers and businesses so it’s vital that effective competition delivers good outcomes. * * * ## **Overview** Google search accounts for more than 90% of all general search queries in the UK, with millions of people relying on it as a key gateway to the internet. It is also a critical route for UK businesses to reach customers - over 200,000 firms in the UK collectively spent more than £10 billion on Google search advertising last year. The new Digital Markets Competition Regime that came into force in January 2025 empowers the CMA to take targeted and proportionate action to improve competition in critical digital markets. As a first step, today we’re consulting on our proposed decision to designate Google with ‘strategic market status’ (‘SMS’) in search under the regime. Alongside this, we’ve set out the potential actions we would take to strengthen competition and deliver better outcomes – enabling more choice and control for consumers, and lower costs for businesses – should we decide to designate Google. These measures could help to unlock broader growth, investment and innovation in the UK tech sector and beyond. Specifically, today we are publishing a roadmap of how we would propose to prioritise these actions during the first half of any designation period. We will issue a final designation decision in October. Should Google be designated, we would expect to consult on a first set of interventions shortly afterwards. * * * ## **What we have heard through our investigation so far** Through our investigation thus far, we’ve heard widespread concerns, including: * Google’s index of billions of websites, its access to trillions of historical searches, and its ecosystem of information, are extremely hard for others to replicate. * Competition in search advertising is not working as effectively as it should. The amount spent by UK business entities for search advertising on Google last year was equivalent to more than £33,000 per advertiser. If competition was working well, we would expect these costs to be lower. * Google may not consistently provide fair search ranking and is able to rapidly (and with limited transparency over when or why) introduce changes to ranking and presentation of results which affect businesses’ ability to reach customers. * Google’s bargaining position can impact fair and reasonable terms for publishers, including fair payment terms for the use of their content. Insufficient controls about how their content is used in Google Search (including AI Overviews) also limits news publishers’ ability to monetise their content. * Google’s deals with companies like Apple and Samsung to be the default search engine on their devices can make it more difficult for competitors to reach customers. * Innovative businesses struggle to compete as people can't easily share their search data with firms developing innovative new services which could benefit them. These issues may harm UK businesses through higher costs and reduced innovation, as well as UK consumers through less choice and control. ## **What this means under the Digital Markets Competition Regime** The new regime can help unlock opportunities for innovation and growth, by promoting competition in digital markets while protecting UK consumers and businesses from unfair or harmful practices. It is built on a principle of proportionality, applying to firms with a sufficiently powerful position – or ‘**strategic market status** ’ (‘SMS’) – in particular digital activities in the UK. We have provisionally found that Google has met the legal tests required to designate it with SMS in relation to its general search and search advertising activities. These tests relate to: 1. Substantial and entrenched market power 2. A position of strategic significance We are now consulting on this provisional designation. If confirmed, the CMA would be able to introduce measures to address specific aspects of how Google operates these activities in the UK. ### **Roadmap of possible measures to improve competition in search** The UK regime is uniquely designed to be flexible and highly targeted, with a participative engagement process – involving all stakeholders, from the largest firms to challengers and consumer groups. The CMA is also embedding our ‘4Ps’ - Proportionality, Pace, Predictability and Process into our approach, to avoid any action we take hampering innovation or creating uncertainty which could chill investment. To support pace and predictability, alongside our SMS investigation we’re looking in parallel at potential actions we might take were Google to be designated. Specifically, to provide greater predictability for Google and other market participants, we’re going further than the legislation requires by publishing a Roadmap of how we propose to prioritise these actions during the first half of any designation period. The measures in the roadmap have two objectives. First, to ensure consumers and businesses are treated fairly and can have confidence in the way they interact with Google in search. Second, to promote competition and innovation through targeted actions, such as ensuring that all firms (including Google) can compete and innovate in new AI-based search interfaces. We have laid out a phased approach for any action we may take. #### Category 1 measures Category 1 measures include early priorities which we would expect to deliver some of the quickest benefits for UK businesses and consumers. These focus on greater choice and control, including through: * **choice screens:** ensuring people can easily choose and switch between search services (potentially including AI Assistants), by making default choice screens a legal requirement * **fair ranking principles:** ensuring Google’s ranking and presentation of search results is fair and non-discriminatory, with an effective process for raising and investigating issues * **publisher controls:** ensuring transparency, attribution and choice for publishers in how their content, collected for Search, is used in Google's AI services (including AI Overviews and Gemini AI Assistant) * **data portability:** helping innovative new businesses to bring products and services to market by ensuring people can transfer their data (such as search history) #### Category 2 measures Category 2 includes a set of more complex issues where we think there may be a case for action, but which require further consideration, and potential interventions may be more complex to develop. These include: * publisher concerns about the impact of Google’s bargaining position and whether they are receiving fair and reasonable terms * concerns about Google’s treatment of rival specialised search firms * concerns about transparency and control in relation to search advertising We’ve also taken the opportunity to indicate areas that we have **deprioritised (Category 3).** ### **Wider international context** The UK is a one of a number of jurisdictions around the world taking action to support businesses and consumers through open and innovative digital markets. We have identified a further set of possible actions (for example, restricting use of default agreements and providing access to underlying search data) which are currently the subject of live litigation between the US Department of Justice and Google. We will consider our approach in these areas in light of developments over the coming months. This is in line with the CMA’s prioritisation principles and the government’s recent strategic steer, which encourages the CMA to consider where we are best placed to act. We will update on our approach to these issues in early 2026. ## **How we are taking account of Generative AI** We have carefully considered how generative AI could affect Google’s position in search. Search is changing, with use of AI assistants growing but still dwarfed by that of Google search. Google is also well-positioned to respond to competitive threats from AI assistants and is now continuously incorporating generative AI features (such as AI Overviews) into existing search products, as well as developing its own AI assistant - Gemini. Reflecting this evolving landscape, the scope of our proposed SMS designation for search would include Google’s AI Overviews and other Generative AI search features. Based on how it is currently offered and used, we have provisionally decided that Gemini AI assistant should not be included as a product within this scope. We recognise the need for certainty, both for Google and for third parties. We will keep this under careful review – as provided for in the legislation – as usage of Gemini develops. ## **What next?** We will be consulting on the proposed SMS designation over the next month, ahead of a final decision deadline of 13 October. We welcome views from all parties on our accompanying Roadmap. We expect to consult on a first set of Category 1 actions shortly after any designation decision. We will publish an updated roadmap addressing our approach to the more complex issues we have identified in early 2026.

Market studies, investigations and reviews are an important part of how the Competition and Markets Authority (CMA) seeks to make markets work well for people, businesses and the UK economy. Today, we have announced our next piece of work, launching a market study into civil engineering in the road and rail sector. This is the first markets project that we have started since we: * set out our '4Ps' framework – pace, predictability, proportionality and process * received our new strategic steer from the government In this post, I set out how both have informed our decisions. The UK government has called on regulators and agencies, including the CMA, to play their part in delivering on its number one priority: economic growth. In particular, the strategic steer asks us to prioritise pro-growth and pro-investment interventions in areas where we have discretion over which cases to open. ## Applying the strategic steer to our markets work We have considered growth and investment: 1. in deciding which markets to focus on in our future work 2. in defining how we will carry out our markets work ### Deciding which markets to focus on The launch of this study shows that we are focusing some of our work on markets that are important to productivity and growth across the whole UK economy. Not only is civil engineering for road and rail a huge area of economic activity in itself; it’s also very important for the productivity of businesses across the wider economy. This market study has the potential to drive significant gains in productivity and growth in the economy. Alongside this renewed pro-growth focus for our markets work, the CMA will continue to examine markets that are not delivering what consumers need – as in our recent work on road fuel, infant formula and vet services. This will continue to be a crucial strand of our work. Going forward, we also expect to devote more of our resource on areas where improvements would have a big impact on productivity and growth. ### Deciding how we will carry out our markets work While our markets work can greatly benefit consumers, firms and the wider economy, we know that businesses also need stability and certainty in how they operate, and that this can support investment decisions. In particular: * the flexibility of the markets regime allows us to address a range of issues across the economy, but it has the potential to create uncertainty for businesses about when and how we will use it, how they are likely to be affected, and how they can best engage with the process * the thoroughness of the markets tool means that we can use it to get to the bottom of knotty issues in markets and develop effective remedies, but this can create lengthy processes * the power of the markets tool allows us to get hold of the information we need to understand and address issues in markets, but this can impose compliance burdens on businesses, especially those that are not normally subject to regulatory oversight Given these trade-offs, we need to make sure that where we carry out markets cases, we work hard to avoid imposing any unnecessary burdens on business – and maximise the net benefit of our work. ## Taking the 4Ps approach to our new market study To address these and similar concerns across its wider toolkit, the CMA has announced that it is making improvements to pace, predictability, proportionality and process (the ‘4Ps’) – ‘process’ meaning how we engage with important stakeholders, including businesses and investors. We will shortly be sharing a fuller update on how we are developing a 4Ps framework for our markets work. In the meantime, we have accelerated our thinking in the approach we will take to the civil engineering market study. In particular, we have: * set out our intention to finish this work in 10 months, well inside the 12-month statutory timetable * published a roadmap to be clearer to businesses about what we intend to do at each stage of the study, and how they can engage with us * set out as clearly as possible what issues we intend to focus on and what we expect the likely outcomes of this work to be – we will continue to update market participants as these develop through the study * committed to offer better opportunities for businesses and public authorities to engage with us directly throughout the study, rather than relying on engagement via intermediaries and written documents * tailored our participative approach so that we can hear from a full range of businesses through the civil engineering supply chains as well as public sector clients, allowing enough time for this in our timetable Next month, we will publish an approach document and revised markets guidance setting out clearly the principles that we will hold ourselves to. Given the variation in our markets projects, this will not mean a one-size-fits-all approach, but rather a statement of our core principles and objectives for operating the markets regime. In the meantime, I hope the way we carry out the civil engineering market study provides a good preview of what this will look like in practice. ## Share your views on the study's purpose and scope Send us your views on the purpose and proposed scope of the market study by responding to the questions in the statement of scope. The deadline is 17 July 2025.

## An update on our market investigation, following our consultation on potential remedies for vet businesses When we published our consultation on measures to address potential competition concerns in vet businesses, we expected a broad and robust set of responses – we have not been disappointed! We've received over 500 responses to our consultation, the vast majority of which were from individuals and independent vets, alongside responses from pet owners and consumer representatives. ## Understanding a complex market Providing vet services is not like selling mobile phones or insurance. This complex market requires careful consideration of animal welfare and public health alongside competition. Clinical judgements, professional expertise, and the relationships between vets and pet owners all play vital roles. This is precisely why we consult. It would be wholly irresponsible to produce remedies without subjecting the possibilities to vigorous debate and discussion by those who may be affected, which is what we will be doing over the coming weeks as part of our extended administrative timetable. ## What we are hearing so far We're still analysing responses, but our initial review has revealed a number of key points: ### What consumers are telling us Many consumer groups have told us that action is needed to address significant consumer detriment, including inadequate complaints and redress systems for when things go wrong. For example, Which? urged the CMA to ‘act boldly to tackle the high barriers to consumer engagement’ and told us: > "The evidence collected so far in the market investigation, the CMA’s preceding market review and our own research leave us with little doubt that a comprehensive package of interventions is needed in the veterinary services market to improve competition and to deliver better outcomes for consumers." ### What vets are telling us We've received mixed feedback from the vets sector. Many would welcome changes to the regulatory system, including ensuring that non-vet owners of practices are subject to appropriate regulatory scrutiny. There's recognition that regulation has real-life impact on both animal care quality and value for money for pet owners. Many vets acknowledge the importance of transparency – people incurring significant costs should know what they may end up paying, and be informed of available treatment options before committing. All whilst recognising that clinical practice can never be entirely predictable. We've also heard about 3 concerns: #### 1. Practicalities What are implementation risks? For example, can generic prescribing, common in human medicine, work effectively in veterinary practices? #### 2. Costs and proportionality Do benefits to pet owners outweigh additional costs to businesses, particularly for smaller practices? #### 3. Business model impacts What would happen to veterinary practices that rely on medicine mark-ups if more pet owners purchase medicines online? While it's too early to say what will be in our provisional findings, the many helpful and constructive submissions that we've received will be core to what we're considering. ## Key considerations ### 1. Context is crucial It is important to remember why we're considering these remedies in the first place. While people have a lot of trust in individual vets, there are concerns about vet businesses and we are considering evidence that may indicate: * price rises of 60% or more between 2016 and 2023 * medicines sold for 3 to 4 times the purchase cost * very limited price transparency * limited visibility on whether practices, referral centres and online pharmacies are part of large national groups * considerable dissatisfaction with the complaints system * veterinary businesses owned by non-vets not being subject to mandatory quality or professional regulation * budget-conscious pet owners not being given a sufficiently wide range of choices * a sector radically changed with large groups now controlling 60% of first opinion practices and many related businesses Our job remains to get to the bottom of these concerns, and address them where we can. ### 2. Impact on businesses Additional responsibilities, even when designed to address consumer concerns, have real consequences for businesses – not just in costs but in time and focus. 40% of first opinion practices are small or medium-sized businesses – some of them are very small indeed. My father ran a small business, I understand the pressures – no HR department, no compliance professionals, no finance department, it was all him. His time was precious, costs were tight. We made a point in our consultation to seek views on potential regulatory costs and burdens, and this is a key consideration to balance against wider benefits. ### 3. Informed consumer choice The relationship between pet owners and vets is not purely transactional – trust is key – and we have heard suggestions that giving consumers more information so that they can better assess the choices available to them might damage this relationship. But is it the case that there is a tension between better informed consumers and trusted relationships with vets? Some responses suggested that greater awareness of available choices might lead pet owners to make decisions detrimental to a particular business. For example, knowing that medicines can be purchased more cheaply online might encourage pet owners to buy there instead. On the other hand, where buying online could lead to savings on some medicines of up to 50% or more over many years, should consumers not be made aware of their options to make their own choices? And to make informed choices, pet owners need to know what the alternatives are. ## Moving forward constructively The issues we're addressing are widespread and strongly felt. Our inquiry did not create these concerns but was set up in part as a response to them. Our job is to assess problems and seek the most proportionate resolutions. Many veterinary professionals understand this. They recognise that resting on professional trust isn't enough when veterinary services as a business may not be functioning as well as they should. We particularly value those respondents who acknowledge the problems and suggest alternative solutions where they disagree with our proposed remedies. Through constructive dialogue, we'll find the right answers. ## Extending our admin timetable We have announced our decision to extend our administrative timetable so we can fully consider the responses we have received on our proposed remedies. The statutory extension is for 6 months but we aim to publish our provisional decision in September 2025, to hold the response hearings around the end of October 2025, and to publish a final decision by February 2026 rather than at the end of November 2025 as originally intended. This is not a decision we have taken lightly. We understand the value of providing greater certainty to the many stakeholders – not least the vets, nurses, receptionists and other hardworking frontline staff – affected by this work and delivering outcomes as quickly as possible is a key objective for the CMA. It is also important that those outcomes are measured, well-targeted and proportionate, and that the process gives a fair hearing to affected parties. In this case, given the volume and strength of feeling of comments from consumer groups and vets and the complexity of the issues we are considering it is vital that we take the time needed to address consumer harm and avoid unintended consequences for veterinary professionals and businesses. **Follow our ongoing investigation on theveterinary services for household pets page.**

Our universities are one of the UK’s greatest success stories – they produce world-class research, drive innovation across the economy and remain critical to equipping people with the skills they need to get on in life. Skills are, of course, crucial to economic growth and a successful industrial strategy, both of which we support. However, we know that many higher education providers are facing very challenging financial situations and that greater collaboration between universities could help support the sector. This is where competition law – and the Competition and Markets Authority (CMA) – can play a role. While some collaborations are more problematic under competition law, there are many areas where they are beneficial and pose no competition law risks. We can support collaborations that benefit the UK – for example, by making clear that we won’t prioritise enforcement as was the case in the development of cutting-edge cancer therapies, or by providing specific guidance like we do for businesses working together to achieve their environmental goals. We think the higher education sector could benefit in a similar way. So, we have been working with the sector and the government to understand concerns which may be preventing higher education providers from working together in ways that could be good for students or the economy. ## What makes a good collaboration Before we go into the types of beneficial collaboration that are unlikely to attract competition law scrutiny, here are some helpful points to consider if you’re thinking about pursuing a project jointly with another provider: * define the purpose of the collaboration, what it aims to achieve and what benefits it may bring about * articulate why the full benefits of collaboration could not be achieved by each higher education provider acting alone * consider what effect collaboration may have on competition – for example, what impact it may have on choice for students * make sure that any reduction in competition brought about by collaboration does not go beyond what is strictly necessary to achieve its beneficial goals * be careful to ensure that discussions do not stray into the sharing of competitively sensitive information such as confidential details about market strategy – we have clear guidance on this ## **Where higher education providers can collaborate** Some forms of collaborations that could be beneficial to the higher education sector are unlikely to give rise to competition law concerns. These could include: * **jointly purchasing certain good or services**. Universities could explore working together for procurement purposes in areas such as buying equipment or wellbeing services, which can help maximise savings and efficiencies * **sharing certain services and infrastructure**. Providers could consider sharing back-office functions, libraries, or sports facilities to reduce costs. They could even explore more transformative ventures like sharing a data centre for AI research * **working together to facilitate student and staff movement**. Providers can work together should they need to move students or staff from one provider to another – for example, if a course is closed * **discussing the possibility of merging with another provider**. Providers can engage in discussions about potential mergers – there is nothing stopping them from doing so. Read our guide if you're considering this * **participating in conversations with government, regulators, and public bodies**. Higher education providers can engage in conversations about improvements to policy and regulation to support the sector – for example, on delivering the right skills provision or on the focus of research efforts ## What's next Providers may also want to collaborate on course provision, such as jointly run courses. This type of collaboration may not be a problem – an example might be where there are many providers offering a course nationally and the course tends to attract students from across the country who will have other good options. However, because this is a more complex area, we are working to understand what collaborations may be under consideration and how these fit with the overall plans for higher education reform. The CMA is committed to supporting collaboration which could help the higher education sector and ensure they don’t fall foul of the law. We will keep you updated on our thinking as it develops, as we continue to engage higher education providers and the government on how we can best assist the sector – for example through providing bespoke advice or issuing further guidance. This will support work by the government, which expects to set out its plan for higher education reform by the summer. Higher education is one of many sectors we’re considering as we explore ways that we can help enable collaborations that support economic growth and the government’s industrial strategy. Our door is always open if you think that your industry could benefit in similar ways to those we have set out today.

Today I’m speaking to my fellow chairs at a summit of the UK major regulators. It’s a privilege to be part of the deep collective experience and commitment of that group – especially when the UK really needs its regulatory landscape to be a key national asset. The topic – what does good regulation look like, especially in a challenging and dynamic economic environment? Firstly, good regulation upholds the interests of UK consumers and businesses. We would be falling at the first hurdle if we didn’t get that right. That’s why I’ve been clear since joining the CMA that, though we must evolve, we’re sticking firmly to the fundamentals – protecting UK consumers and promoting competition. Recent work underscores that commitment – like our recommendations to government for improvements to the infant formula market, our Ticketmaster investigation, and the launch of our first two investigations under the new Digital Markets competition regime. > That’s why I’ve been clear since joining the CMA that, though we must evolve, we’re sticking firmly to the fundamentals – protecting UK consumers and promoting competition. Good regulation also supports critical, long-term policy goals, and the broader macro-economic environment in which they are formed. Most notably, the UK desperately needs economic growth. It’s the only way out of today’s world of high debt, record tax take and intense pressure on public expenditure. It’s our only route to prosperity for ordinary working families, with better public services, infrastructure and quality of life. That’s why it’s the government’s number one mission – and why all regulators must play their part in helping achieve it. I have said it before and will keep saying it: investment is critical. We can’t build our future with the lowest level of business investment in the G7. So, for the CMA, good regulation also means really challenging ourselves on how we can encourage this to the greatest extent, while staying true to our fundamentals. There’s a lot we can do for growth and investment through opening up markets to competition, as we did with Open Banking; levelling the playing-field for SMEs, like we did with online marketplaces; and strengthening consumer confidence as we start to implement the new consumer protection regime. But we can go further – by making meaningful changes to _how_ we carry out our work. Changes that matter to businesses, investors, and startups thinking about whether to choose the UK, over anywhere else in the world, as their home. We’re now actively implementing improvements across ‘4Ps’: the Pace of our end-to end-processes; the Predictability and Proportionality of our actions and decisions (including a sharper focus on UK versus global impact); and our Process, meaning the direct engagement we have with businesses and wider stakeholders. We’re already making considerable headway with this 4Ps framework across core areas of our work, including mergers, consumer protection and digital markets – really listening and responding to feedback as we go. > When it comes to good regulation, the UK’s new Digital Markets competition regime has the virtue of already exemplifying many aspects of these 4Ps. When it comes to good regulation, the UK’s new Digital Markets competition regime (opens in new tab) has the virtue of already exemplifying many aspects of these 4Ps. It’s designed to keep pace with fast-moving markets and technologies, while not trying to predict the future. It’s highly tailored, applying just to the largest firms and offering the opportunity for scalpel-like remedies, not an industry-wide sledgehammer. And it’s based on ongoing dialogue with firms and the wider ecosystem, collaborating on solutions which work in practice. It’s early days, but progress so far is already starting to show the benefits of a bespoke UK regime. By getting regulation right, all of us in the regulatory community can make a critical contribution to getting the UK economy growing and ultimately delivering a more prosperous future for everyone.

The Subsidy Advice Unit (SAU) is now well into its third year of operation after the UK’s subsidy control regime came into force in January 2023. As required by law, we are starting the process of reviewing the performance of the regime. This review aims to advise the UK Government – and other stakeholders – on whether the regime is working as intended, so that they can consider if any improvements should be made. We’re kicking off that process with a ‘call for inputs’ asking anyone with experience of the regime to tell us what they think of it. ## **Subsidies and the role of the SAU** Subsidies are given out by public authorities to support and pursue their policies – including to encourage economic growth by promoting innovation and investment. Our role in the SAU is to evaluate public authorities’ self-assessment of their adherence to certain legal principles, in relation to larger or more sensitive subsidies. The advisory reports we produce help public authorities comply with their legal obligations and give subsidies that have the minimum impact on competition and investment, so that organisations who do not receive subsidies can be confident that they are competing on a level playing field. At the time of writing, since the start of the regime in January 2023, we’ve worked at pace to publish over 80 reports from 38 public authorities including: * Whitehall departments * Devolved Governments * local and regional authorities * arms-length bodies (such as Arts Council England) The subsidies referred to us cover a wide range of sectors with energy, housing  and construction, and transport covered most frequently.  You can read our reports  on the Competition and Markets Authority cases and projects page. Source: SAU data, correct as of 15 April 2025 ## **What are we reviewing?** We are required by law to review the effectiveness of the UK subsidy control regime.  This covers all aspects including, but not limited to, guidance, the referral process, our own role in the SAU, the ability to challenge subsidies, as well as the thresholds and exemptions that apply. After consulting last year on what to include, we plan to review the effectiveness of the subsidy control regime by assessing how well it is meeting the objectives set out by the UK Parliament. These are: * empowering public authorities to design subsidies that deliver strong benefits for the UK taxpayer and deliver strategic interventions to support the UK’s economic growth and policy priorities * providing certainty and confidence to businesses investing in the UK * contributing to the UK’s international commitments on subsidy control We’ll also be looking at the impact of the regime on competition and investment in the UK. This means looking at the sorts of subsidies given (and not given) and their impact on prices, market shares, entry and exit, location, output, investment decisions and customer behaviour. ## **Why are your views so important for us?** You may be: *  a public authority who has given – or are thinking of giving – subsidies *  a beneficiary who has received a subsidy (for example a business or third sector organisation) * a competitor to a beneficiary * an investor * any other stakeholder with an interest in the regime To achieve a robust and representative evidence base, we need to understand how you experience the regime. The more views and evidence we can gather, the better we can reflect users’ experience and the more accurately we can communicate that in our final report. It’s important to say that our work here is not about enforcement, or seeing if particular subsidies comply with the law. Rather, we want to know how well the different elements of the regime are all working – and whether they could be improved. The more people that respond, and the more open you are in your responses, the better and more robust our final report will be. ## How to have your say We have published a Call for Inputs which gives you the opportunity to have your say and provide evidence about the effectiveness and the impact of the UK’s subsidy control regime and how it's being operated and take part in our roundtable events. * * * #### Closing date for responses: 24 June 2025 * * * We’ll also be engaging directly with stakeholders and gathering further evidence until late 2025, including through: * case studies * stakeholder interviews * roundtables * data analysis Our final report will be published as soon as is practicable after the end of the review period (31 March 2026). We look forward to engaging with you and hearing your views over the coming months.

Applications for our Delivery Graduate Scheme are open for October 2025! If you’re a university graduate (or expect to finish your studies before September), are interested in delivering better outcomes for consumers, and want to play an important role at the UK’s competition and consumer regulator, then the Competition and Markets Authority (CMA) could be the right place for you. ## **The Scheme** As a Case Officer on the Delivery Graduate Scheme at the CMA, you’ll gain hands-on experience of CMA casework. You’ll be posted to one of our multi-disciplinary project teams, working alongside legal, economic, financial and technical experts. Successful applicants will complete three, 12-month placements in different parts of the CMA, contributing to the delivery of high-quality outputs and assisting major investigations and projects. This could involve writing draft proposals for investigations, planning and executing dawn raids, analysing documents, liaising with external stakeholders, developing strategy, and assisting with project management. ### **Here's what some of our current graduates have to say about the scheme:** ## **Our training programme** During your time at the CMA, you’ll also get to advance your skills and knowledge through regular training. The programme will be spread over the 3 years of the scheme, and is designed to expand your knowledge of the CMA’s role, remit and work, and sharpen your drafting, presenting, and IT skills. CMA staff are able to apply for funding for external courses – ranging from academic qualifications to project management certifications – and you’ll also have access to regular seminars from academics and competition experts. After the completion of the scheme, we expect you’ll have the skills to consider applying for a role as a Principal Case Officer. ## **Application details** Applicants must be based in and eligible to work in the UK. Upon applying, you will have 3 tests to complete, comprising: * verbal reasoning * numerical reasoning * management judgement If you pass all of these tests, you will be presented with an application form where you’ll give examples of your experience. If you’re successful, you’ll be invited to attend an assessment centre and interview. ### Apply: Find out more and apply by 28 April 2025.

The pace of change in today’s digital economy is exciting and unrelenting. Business models are evolving, AI is reshaping markets, and investment strategies are shifting in response to global competition and technological disruption. At the Competition and Markets Authority (CMA), we recognise that understanding these market dynamics is critical – our job is to ensure that consumers get a fair deal, that businesses are free to thrive, and that markets work well. This means ensuring that competition, innovation, and investment can thrive in important areas like AI, so that the vast opportunities are unleashed and can drive positive outcomes right across the UK. That’s why we are expanding our capability in strategic business analytics, to bring a stronger business and investor lens into our work in new and impactful ways. This means taking a more sophisticated and forward-looking approach to understanding how firms operate, compete, and scale in fast-moving markets – especially in AI and digital ecosystems. A strong understanding of firms’ strategies and business models is essential to our work and as our CEO Sarah Cardell announced recently in a speech, deepening our capability in this area is one element of our wider build out of a world-leading strategic insight and analytics capability within a regulatory body. ## Be part of a world-leading strategic insight and analytics function Deepening business and strategic insight is part of a broader transformation within the CMA, which has already led to the creation of a new Executive Directorate for Data, Technology, and Insight (DTI). DTI brings together a cutting-edge mix of expertise across: * strategic analysis * financial analysis * data science and engineering * artificial intelligence and technology analysis * behavioural science * digital forensics Our AI Centre of Excellence is a dedicated hub within DTI that develops AI expertise, both for internal use and to inform our regulatory approach. ## What this means in practice The Strategic Business Analysis function plays a vital role in helping the CMA stay ahead of market developments. Some of the key areas of focus include: * understanding 'digital ecosystem' strategies – how firms structure and expand their influence across interdependent markets * business models in fast-moving areas like AI – the commercial realities of AI development, deployment, and monetisation * investment strategies and funding models – how firms raise capital, scale, and structure financial incentives across different stages of growth By embedding business and investor perspectives across our work, we can ensure that our regulatory decisions are rooted in commercial realities, enabling competition to drive sustainable growth, innovation, and consumer benefits. ## Join the conversation We are looking for people with experience in business, investment, and strategy to join us in shaping the next phase of this work. The ideal candidate will: * see growth, opportunity, and scope for real-world positive impact * think about full potential: what a company, an industry, or a market could become, and how that shapes competition, investment, and innovation * speak the language of business and investors – you understand business models, competitive advantage and capital flows * think about how businesses scale and what drives decision-making * bring structured thinking, pulling from a mix of analytical approaches: * ecosystem thinking – understanding trends, disruptive forces, competitive analysis, and systems dynamics * business and investment lens – analysing business models, strategies, sources of competitive advantage, incentives, funding models, and corporate playbooks * future-oriented analysis – exploring a company’s strategic options, industry scenarios, and key drivers of change * problem solving – using a hypothesis-driven approach to break down and tackle complex challenges You might be considering public service as a long-term career move or want to 'test the waters' while applying strategic business analysis skills to policy and competition, or you may want to contribute to public service and be willing to join us for a focused stint. We are looking for candidates who come from: * strategy consulting (current or former) * company in-house strategy teams * market analysis, investment banking, venture capital or private equity backgrounds * business schools, especially if you have prior experience in any of the above ## What you'll get from us in return You'll: * be part of a world-leading strategic insight and analytics function right from the start, contributing to priorities, policy, and direction of work with some of the world’s industry leaders * help ensure that the opportunities of technologies like AI are unlocked and maximised for UK consumers, businesses, and the wider economy We believe that the CMA is an excellent place to work and we offer a flexible and supportive environment that will help you thrive and achieve your personal work-life balance. We offer flexible working – either in the time you contribute to the CMA’s work (short term appointments are available) or in working patterns, including hybrid home/office working, part time arrangements, compressed hours, and job shares. Our colleagues are included, respected, and valued, using their strengths and diverse perspectives and experiences to contribute to our work and reflect the public we serve. We offer an average pension employer contribution of 27%, generous leave, family friendly policies, and learning and development. ## Be part of the future If this sounds like you – or someone in your network – then we’d love to hear from you. Here are links to some initial roles, decoded into consulting language: * SEO: current or former business analysts, Associate Consultants (AC), Senior Associate Consultants (SACs) * G7: current or former consultants/case team leaders * G6: current or former project leader, (engagement) managers or principals * G6 (short term/part time): current or former principals, partners **Join us in shaping the next chapter of competition, investment, and innovation in the UK economy.** Find out more about working for the CMA

It’s vital that shoppers can access clear pricing information. Knowing how much you’ll pay is fundamental to making good decisions – working out which product is best for you, and where to buy it. When firms don't display their prices accurately or leave out essential pricing information that people need to know, it can make products appear cheaper than they are. That can undermine people’s trust when they find out the real cost, and prevent businesses from competing on a level playing field. Access to clear and accurate pricing information is a priority for the CMA. Our work over several years – on the price of everything from a family holiday to a cycle of IVF treatment, from buying a mattress to writing a will – shows the CMA’s commitment to supporting businesses to comply with the law, and to act where we see bad practice. New and innovative pricing systems, including those using the latest technology such as AI, can offer real benefits to consumers, businesses and the wider economy. To ensure consumers maintain trust and confidence in how pricing works, businesses need to help people understand how they work. What determines the price they pay? How can prices change over time? If consumers understand how new pricing systems work, they can be confident that they are being treated fairly and are more likely to remain loyal which helps businesses to grow. ## Our recent work on pricing We've been busy over recent weeks on several projects related to pricing: ### Ticketmaster investigation The CMA has been investigating Ticketmaster, following concerns about the sale of tickets for the UK leg of the Oasis Live ‘25 concert tour. We reached an important milestone in that investigation today, sending Ticketmaster a ‘consultation letter’ setting out the CMA’s concerns and seeking changes to Ticketmaster’s processes. We have 2 main concerns. Firstly, we don't think customers were given clear and timely information about how the pricing of certain tickets would work. In particular, we don't think it was clear that there were 2 categories of standing tickets at different prices, with all of the cheaper standing tickets sold first before the more expensive standing tickets were released. As a result, many fans may have waited in a long queue without understanding what they would be paying and then having to decide quickly whether to pay a higher price than they expected. Secondly, we’re concerned that Ticketmaster labelled certain seated tickets as ‘platinum’ and sold them to fans for around 2.5 times the price of equivalent standard tickets, without sufficiently explaining that they didn't offer additional benefits and were often located in the same area of the stadium. We’re concerned that this may have misled fans into thinking they were getting better tickets when that wasn’t necessarily the case. ### Dynamic pricing We’re also looking at how ‘dynamic pricing’ is being used across different sectors of the economy. Dynamic pricing generally involves prices changing in a relatively short period of time because of changing market conditions, like a high level of consumer demand or a shortage of availability. In some cases that can involve complex algorithms, with prices changing frequently and at great speed. There is often considerable confusion about what dynamic pricing is and how it is used. For example, in our Ticketmaster investigation, many fans were under the impression that Ticketmaster used an algorithmic pricing model to adjust its prices in real time. However, we did not find evidence that was the case. Instead, Ticketmaster used a different pricing model where it released a number of standing tickets at a lower price and, once they sold out, released remaining standing tickets at a much higher price. We're examining how dynamic pricing is used by businesses, why they use it and what benefits it has, including whether it varies by sector – for example, business practice and consumer expectations may be different for holiday pricing as compared to tickets. We want to understand both the benefits and potential risks for consumers and competition. We have engaged with a number of businesses and consumer groups who have helped us develop a richer understanding of dynamic pricing. We'll publish our findings by the end of April. We’ll also be providing our findings to the government to help inform its consideration of the issues raised by dynamic pricing, including in the live events sector. ### Ticket resale We’ve responded this week to the government’s consultation on proposals to strengthen consumer protection in relation to ticket resale for live events. The consultation drew on previous CMA work highlighting that typical price mark-ups in the ticket resale market are around 50%, and that bulk buying of tickets by professional ticket touts can drive these inflated prices. The government wants to protect consumers from ‘excessive resale pricing’, and we’ve made clear in our response to the consultation that we support its proposal for a price cap on resold tickets to deliver that objective. Our response also sets out a number of considerations to help the government successfully implement such a price cap, including: * a model for efficient, targeted enforcement * the importance of ensuring ticket price information is accessible and verifiable * considering whether any additional fees charged by resale platforms may need to be controlled through legislation ## What businesses can do to help build consumer trust and confidence in their pricing systems Great businesses put their customers front and centre of what they do and they innovate to use pricing strategies that serve their customers and drive growth. The work we’ve described above highlights the importance of thinking through a customer journey. For example, what information do consumers need to make informed choices throughout the purchasing process, whatever pricing strategy a business uses? Businesses use dynamic pricing in lots of different ways, but here are some overarching steps businesses can take to help ensure compliance and build trust about their pricing in the areas I’ve described above: * do not create the impression that a specific price is fixed or guaranteed, if prices are actually changing * do ensure that any marketing of prices doesn’t become immediately out of date * do tell people if prices might change whilst they are in the process of buying, for example whilst they are in an online queue or clicking through to the end of the checkout process * do not put people under unfair pressure to make snap decisions where prices change quickly during the purchase process * do ensure that people are told what they will actually pay at the right points in the purchase process (for example in an ‘invitation to purchase’ or when they click ‘buy’). This should not then change ## Find out more You might be interested in: * new guidance on how the CMA will use its direct consumer enforcement powers under the Digital Markets, Competition and Consumers Act 2024 * our other guidance for businesses and consumers on their rights and responsibilities under consumer law

Today I gave a speech at techUK’s tech policy conference where I touched on the CMA’s new consumer enforcement regime ahead of our new powers coming into force on 6 April. The CMA’s new direct enforcement powers mean that the CMA will be able to decide whether key consumer protection laws have been breached without having to take businesses to court, and we will be able to take direct action to tackle these breaches including through fines and redress. At the beginning of April, alongside finalised guidance for the new regime, we will publish an approach document which will include more detail on our enforcement priorities for the first 12 months. It will also explain more fully how we plan to apply the ‘4Ps’ framework (our focus on pace, predictability, proportionality and process) to the new consumer protection regime. In the meantime, we are today providing an update ahead of those publications in particular to help guide businesses as they prepare to comply with the new regime. ## Update on our consultation and next steps In recent months, we have consulted extensively on guidance for the new regime, receiving helpful and constructive feedback from a range of stakeholders. We have heard loud and clear that businesses – large and small – want to do the right thing for their customers and many are working hard to ensure they comply. But for smaller businesses especially, the compliance burden must be proportionate. Taking that feedback on board, we will: * streamline the drafting of our guidance on unfair commercial practices considerably to make it as clear and accessible as possible, whilst retaining the case studies and examples which we know businesses and advisors find helpful * from April, kick off an extensive business outreach programme. This will build on the explainer event we held last summer with over 200 businesses and other organisations to help them understand the changes and start preparing for the new regime * publish a series of accessible and interactive business explainers for the key practices covered by the guidance Before 6 April, we'll publish: * an approach document: setting out how we will implement the Strategic Steer in our approach to consumer work, how we will implement the ‘4Ps’ in this area, and our enforcement priorities for the first 12 months of the new regime with a focus on the most egregious harms * unfair commercial practices guidance: a streamlined and simplified version of the draft on which we consulted which sets out detail on what practices are and aren’t compliant with the law – here we will carve out some aspects of drip pricing where we will re-consult * procedural guidance for the direct enforcement model (CMA200): setting out how a direct enforcement action will be run from start to finish and how we will interact with parties * consumer protection regime guidance (CMA58): setting out how the regime sits in the broader landscape and when we will exercise our direct enforcement powers Ahead of these publications, we want to provide further detail on 2 specific areas. ### Drip pricing We are taking a phased approach to our guidance on this – which was the issue we received the most substantive feedback on. * in April, we will provide a clear framework for compliance with aspects of the law which are already well understood and largely unchanged. By this I mean the prohibition of genuinely unexpected and untrailed mandatory charges added on at the end of a purchasing journey. These ‘dripped fees’ harm consumers and fair dealing businesses by hindering effective price competition which we know primarily happens on headline prices * for those aspects of the drip pricing guidance that have created more uncertainty (including fixed-term periodic contracts) we will run a further consultation on revised draft guidance in the summer, with a view to producing finalised guidance in this area in the autumn * in the meantime, we will only take enforcement action against drip pricing which clearly breaches the rules in line with the April guidance ### Fake reviews Fake reviews are a banned practice under the DMCCA. Although we can tackle fake reviews under our existing powers, we recognise that new provisions may require changes to systems and compliance programmes. We hear that businesses need time to bed these in, and so for the first 3 months of the new regime we will focus on supporting businesses with their compliance efforts rather than enforcement. ## Enforcement priorities The remaining law where our new direct enforcement powers can be used hasn’t changed materially. However, we recognise that the risks of getting it wrong are changing substantially. Businesses have told us they are preparing to comply and will be relying on the clarity and certainty provided by our final Guidance, as well as further detail on our early enforcement priorities to be published at commencement in April. Our early enforcement action following commencement is likely to focus on more egregious breaches. For example: * aggressive sales practices that prey on vulnerability * providing information to consumers that is objectively false * contract terms that are very obviously imbalanced and unfair * behaviour where the CMA has already put down a clear marker through its previous enforcement work * where the law tells us that a practice is always unfair At the same time, we will support the vast majority of well-intentioned businesses who want to do the right thing but may be unclear on exactly what is needed to ensure compliance, especially in areas where the law has been updated or there is less clear-cut precedent. We will also take into account where businesses have taken proactive steps to correct infringing conduct, in deciding the appropriate level of a penalty. ## **Delivering a robust, effective regime** Taken together, I am confident this approach will deliver robust protections for consumers, focusing on clearly illegal conduct that results in tangible harms. At the same time, it gives the business community the clarity to comply with new laws as quickly as possible - and the confidence that early enforcement action will be proportionate. This is, after all, in the interests of both businesses and consumers; when businesses get it right, consumers benefit.

On 24 February 2025, the Procurement Act 2023 came into force, driving greater efficiency, transparency, and fairness in public sector procurement. The Act introduces stronger rules on the exclusion of suppliers where they pose particular risks to public procurement. Changes include a new mandatory exclusion ground for suppliers involved in cartel activity and the introduction of a central debarment register. If you are a supplier tendering for public sector contracts or a contracting authority running tender procedures, this new regime is relevant to you. For more technical detail, visit the CMA’s overview. ## **What do 'exclusion' and 'debarment' mean?** * **exclusion** : where a supplier is not permitted to participate in a procurement, or be awarded a public contract, following an assessment of exclusion grounds by a contracting authority * **debarment** : where a supplier is placed on a central debarment list by a Minister of the Crown which prevents the supplier from participating in any procurements or being awarded public contracts for up to 5 years Suppliers who take part in illegal cartel activity such as bid-rigging, price fixing or market sharing risk being excluded from public procurement unless they can demonstrate that they have ‘self-cleaned’ so that the wrongdoing that led to the exclusion won’t happen again. More information on competition exclusion grounds and self-cleaning can be found on the CMA's overview page. Suppliers can be excluded if an exclusion ground applies to a ‘connected’ or ‘associated’ person. This includes directors, parent or subsidiary companies, and key sub-contractors. ## **Steps suppliers may take to avoid exclusion or debarment** For suppliers, the best way to avoid exclusion or debarment is to remain compliant with competition law. Read our compliance advice on our Cheating or Competing campaign page and share compliance materials throughout your business. However, if a supplier realises it has infringed competition law, there are steps it can take to make amends and avoid exclusion: **Admit wrongdoing and apply for leniency** The first supplier to report cartel activity to the CMA and be granted a 100% discount on fines will not be excluded or appear on the debarment list. As a result, there is now an increased incentive for suppliers involved in cartel activity to be the first to report wrongdoing to the CMA under its leniency policy. **‘Self-cleaning’** Suppliers will not be excluded if they can demonstrate that the circumstances giving rise to the exclusion ground are not continuing or are unlikely to occur again. This might include, for example: a supplier showing they have been granted leniency, or have admitted wrongdoing and agreed to pay a penalty under the CMA’s settlement procedure. ## **Steps for contracting authorities** The new regime applies to contracting authorities in England, Wales, and Northern Ireland, but not in Scotland. Contracting authorities must determine whether exclusions apply to potential suppliers including assessing if a supplier has ‘self-cleaned’. To help them with that assessment, contracting authorities can: * check the central debarment list which can be found on Procurement Review Unit before procurement exercises * check the CMA decisions register for infringement decisions * check for ongoing investigations in both the CMA case list and the list of cases undertaken in regulated sectors by UK Competition Network members ## **How the CMA can help** Authorities can contact the CMA at cma_procurementsupport@cma.gov.uk for information that may be relevant to exclusion and self-cleaning assessments. To reduce bid-rigging risk, the CMA has produced bid-rigging advice for public sector procurers. If you suspect bid-rigging or need a teach-in on bid-rigging red flags, contact cma_procurementsupport@cma.gov.uk. ## **How to report concerns to the CMA****** If you witness or suspect another business breaking the law: * call us on 020 3738 6888 * email us at cartelshotline@cma.gov.uk * never confront a supplier yourself If you’ve been involved: * come forward and you may get leniency * call us on 020 3738 6833 and we can provide confidential guidance * always seek independent legal advice ## **Resources** If you want to know more: * you can learn more about what the competition exclusions in the Procurement Act mean for contracting authorities and suppliers in the CMA’s overview * further information on the exclusion and debarment regime is set out in Cabinet Office Guidance: Exclusions and Cabinet Office Guidance: Debarment * the CMA will provide additional guidance on the interplay between the new procurement regime and the CMA’s leniency regime in the CMA’s consultation document and draft leniency guidance to be published shortly * Guidance from the Procurement Review Unit

Every 5 years, Ofwat (the water services regulation authority) decides how much money people should pay for water and sewerage services, and the level of service customers should receive. In making price control decisions, Ofwat needs to weigh up various matters. This includes the need to protect consumers’ interests while also ensuring water companies have enough money to deliver and invest in their services. Ofwat’s latest price review was published in December 2024. ## Ofwat’s price review and the CMA Companies that are unhappy with Ofwat’s price review can ask that the Competition and Markets Authority (CMA) reviews and ‘redetermines’ it: our role is to form our own conclusions on the price decisions for the individual companies that appeal, in accordance with the principles that apply to Ofwat, including its various statutory duties and the government’s Strategic Priority Statement. Once the process formally starts (once we receive a ‘reference’ from Ofwat), a panel of decision makers who are independent of the CMA board will be set up to review the price control and make its own decisions. The panel might agree with Ofwat’s decision, or think that the allowed price should be changed. You can find out more on Ofwat’s website. ## **Why does the CMA get involved with water decisions?** The CMA is required by law to review Ofwat’s price controls when Ofwat refers those price controls to the CMA following requests by water companies that wish to challenge them. The CMA’s review of Ofwat’s decisions around pricing is unrelated to the Independent Water Commission set up by the government. This commission is reviewing the water sector and how it is regulated, focusing on recommending changes which should take place beyond this price control. ## **What happens next?** The next step is for Ofwat to make references to the CMA. Once references are made, the independent inquiry group will be appointed, supported by a team of staff within the CMA. The CMA has 6 months from the date of the references to complete the redetermination, but if necessary this can be extended by up to another 6 months if Ofwat agrees to change the deadline it has set. ## **Follow this work** We’ll be publishing further information in the coming weeks, including a timetable for the review. This will be published on the CMA website.

A robust, independent competition regime should both drive growth and investment, and uphold consumer interests. This was at the heart of a speech I gave at Chatham House last November, and a view shared by our new Chair in his first published statement. It is also clearly expressed in the draft Strategic Steer for the CMA, to be published by government later today. The Steer sets out how free and fair competition, and robust consumer protection, can support innovation, productivity and investment. This is core to the CMA’s work and foundational to the value we deliver every day for UK consumers and businesses. But I have heard clearly from businesses and investors (both domestic and international) that 4 aspects of how the CMA carries out our work also really matter to perceptions of the UK as a great place to do business. These are: * pace * predictability * proportionality * process At Chatham House, I laid out my commitment to rapid, meaningful change based on these principles, starting with the mergers process – a particularly critical area for investment, including inward investment, to the UK. That is what I am delivering today: a package of carefully considered proposals for rapid change. To be successful, they rely not only on the CMA’s commitment to change, but also the willingness of businesses and advisors to engage constructively and co-operatively with what we are proposing. Taken together, I am confident they will deliver an approach that compares favourably with international peers, enhances business and investor confidence, and enables us to continue protecting effective competition for the benefit of UK businesses and consumers. It is open to government to go further, through legislative change, both by locking some of these changes into the statutory framework and making further legislative changes to embed our 4Ps approach. We will continue to work closely with government should it wish to do so. ## **Pace**–** reaching faster decisions on mergers, and minimising in-depth reviews** We know speed of decision making is vital to reduce uncertainty and costs for businesses. Given the vast majority of deals the CMA looks at ultimately end in clearance (either unconditionally or with remedies), we must move as quickly as possible to get to the right decisions. Our proposals will deliver these outcomes more quickly and help us minimise the end-to-end length of merger investigations. By June 2025 we will: * establish a new KPI to complete the pre-notification phase within 40 working days, against a current average of 65 * reduce the current target for straightforward Phase 1 cases from 35 working days to 25 These changes require a major streamlining of our approach, with earlier prioritisation of potential concerns, focused information-gathering, and shorter published decisions. With the cooperation of merging parties, I am confident they are achievable. ## **Predictability – clarifying the CMA’s remit** We hear consistently that predictability is key to investor confidence. Under the UK’s ‘voluntary’ system, parties may choose to notify a merger where they think it meets jurisdictional thresholds. But the CMA can also ‘call in’ deals, and UK law gives us an unusually broad jurisdiction by international standards. This can create uncertainty over whether we will review a particular deal or not. Two specific ‘tests’ we apply are relevant: 1. Material influence, which gives the CMA jurisdiction over acquisitions of certain interests in a business that fall short of de facto control. The threshold for this in the UK regime is low by international standards. 2. Share of supply, which gives the CMA jurisdiction over deals where they give rise to a certain share of supply of goods and services in the UK. ‘Share of supply’ is loosely defined in legislation, giving the CMA broad jurisdiction to review deals. To strengthen business certainty about which deals might attract the CMA’s attention, we will clarify and delineate our remit (as far as legally possible) by updating our guidance on how we interpret and apply these tests. We will issue the updated guidance for consultation in June. ## **Proportionality – getting to the right outcomes while minimising burden on business, and sharpening our focus on UK impact** Our objective is for as many of the deals as possible which raise competition concerns to be cleared with effective remedies, rather than be prohibited. Our process also needs to support us reaching the best remedial outcomes as quickly and efficiently as possible. So, in March we are launching a review of our approach to remedies, looking not just at process but also how we strike the right balance between different types of remedies. We will also consider the potential for deals to deliver pro-competitive investment benefits, as we saw recently with Vodafone/Three. I am confident this will help us to deliver on proportionality - so long as businesses and advisors engage with these objectives in good faith, only putting forward robust remedies proposals and well-evidenced claims around benefits. We also want to take a proportionate approach to looking at global deals, which we know is important to investor confidence. We will always uphold our duty to protect UK consumers and businesses. But we are now carefully exploring how far (under existing law) we might be able to more clearly distinguish between deals with a distinct and direct UK impact, versus those where it may be more appropriate to watch closely whether action by other authorities could resolve UK concerns. ## **Process – a step change in direct business engagement, underpinned by a new Mergers Charter** It is vital for investor confidence that all businesses feel listened to by the CMA; understand what we are doing and why; and recognise a sense of fairness and consistent treatment across all investigations. That’s why, in March, the CMA will publish a Mergers Charter. The charter will include our firm public commitment to pace, predictability, proportionality and process, as well as laying out what will be needed - from the CMA, businesses and advisors - to ensure the success of this new approach. Underpinning the Charter will be a number of meaningful actions to break down barriers to more direct engagement, both outside of and during investigations: a targeted outreach programme for businesses and investors; more senior meetings early in the review process; a suite of accessible, engaging, business-friendly materials and so on. Building on the success of our recently introduced Phase 2 reforms, I think we can now deliver a step change in more direct, open and constructive engagement with businesses and investors. ## **Moving forward** We are already working at pace to bring about a step change in the operation of the mergers regime over the coming months. But we will not stop there. I am committed to applying the 4Ps framework across all areas of the CMA’s work to deliver robust, independent competition and consumer protection regimes that have the confidence of businesses and investors, and help to support the government’s growth mission.