On 24 March 2026, the Competition & Markets Authority (CMA) issued its Final Report in its Market Investigation into veterinary services for household pets in the UK. The CMA's conclusions about how well competition is functioning in the market will result in a number of important regulatory changes for providers of veterinary services in the UK.
In this article, we review the CMA's conclusions, explain the market remedies that it will implement, and consider the wider significance of this development. This article also provides some explanatory comments about the nature of the market investigatory framework.
Market Investigation
Following extensive engagement with market participants, the CMA has concluded that there are "adverse effects on competition" in the market (AECs, which are features that prevent, restrict or distort competition in a market) in two distinct respects:
- firstly, in relation to the retail supply of veterinary services for household pets by first opinion practices (FOPs); and
- secondly, in relation to the supply of outsourced out-of-hours (OOH) services provision to FOPs.
The CMA estimates that those AECs could give rise to consumer detriment of approximately £5 billion over five years. It has argued that market consolidation in the veterinary sector has resulted in reduced choice and higher prices for consumers. The CMA has identified six large veterinary groups (LVGs), which are said to own the majority (60%) of vet practices in the UK, impose higher prices and generate higher profits; the LVGs will be required to comply with some of the new regulatory requirements sooner than the non-LVG practices.
Regulatory intervention
The CMA will implement a wide-ranging package of remedies to address the AECs that it has identified.
Pricing practices for veterinary services
- Price estimates and bills - Vet practices will be required to provide a written estimate for treatments expected to cost £500 or more (except in emergency situations) and to provide itemised bills.
- Price lists - Vet practices will be required to publish a comprehensive price list for standard services, including consultations, common procedures and cremation options.
- Pet plans - Pet plans must specify detail on the cost of each component of the plan, and how advertised price savings are calculated.
- Cremation services - Prices must be offered for all cremation services offered, including for communal cremations (as a lower-cost option) in addition to individual cremations.
- Price comparison - The Royal College of Veterinary Surgeons (RCVS) will share price and ownership information made available to it through its 'Find a Vet' service with third-party comparison websites.
Prescriptions
- Fee caps - Written prescription fees will be capped at £21 for the first medicine, and £12.50 for any additional medicine.
- Written prescriptions & obtaining alternative medicine - Vet practices will be required to provide a written prescription promptly (paper prescriptions before the pet owner leaves the practice, or for online prescriptions within 48 hours). They will be required to inform customers when a clinically equivalent alternative is available and can be purchased at a third-party retailer.
Conduct unrelated to pricing practices
- Notice provisions for out-of-hours service providers - OOH providers will be prevented from implementing 'unreasonably' long notice periods and high exit fees, with the effect of restricting FOPs' ability to switch provider.
- Ownership transparency - Vet practices will be required to make it clear if they are part of a corporate group or if they are an independent business.
- Policies and procedures - Vet practices must implement written policies in relation to vets' duties to offer independent and impartial advice. Complaints systems must be implemented with the ability to engage in mediation if disputes are not resolved.
The CMA has also endorsed the UK Government's proposed legislative reforms to the Veterinary Surgeons Act 1966 which, if implemented, will affect the regulatory regime for vet practitioners throughout the UK.
Compliance considerations
The CMA's regulatory interventions will affect different veterinary practices differently, depending on the nature of the services they provide, their current commercial practices and their size (and whether they are part of an LVG). They will be implemented gradually between September 2026 and September 2027, starting with requirements in relation to OOH service providers.
Crucially, in several cases LVGs will be required to comply with the new requirements sooner than non-LVG practices. For example, the CMA expects that prescription price cap requirements will be in place for LVGs in March 2027, as opposed to September 2027 for other market participants.
With that in mind, it is essential that veterinary service providers start to prepare for compliance with the anticipated regulatory changes in early course.
Looking ahead: Market Study into Private Dental Services
The CMA has now formally launched its market study into the supply of private dental services in the UK. The scope of the market study is not yet confirmed. However, the action that the CMA has now proposed to take in the veterinary sector is an important signal of the intervention that the CMA may take if it considers that the market for private dental services is not working in the interests of consumers, particularly if the CMA initiates a market investigation at the conclusion of the market study.
For more information on the legal risks arising from the market study, and practical steps that private dental providers can take in the immediate and medium term, please see our article here.
In brief: market studies and market investigations
Under the Enterprise Act 2002, the CMA has the power to conduct market studies and market investigations.
Market studies and market investigations are essentially forward-looking regulatory mechanisms, through which the CMA can review how well competition is functioning in a particular market and, when it identifies concerns, intervene and regulate market conduct. The CMA has more extensive powers to intervene when it is undertaking a market investigation as opposed to a market study.
The purpose of a market investigation is to establish whether a feature of the market under review prevents, restricts or distorts competition such that it amounts to an AEC. The CMA has a duty to remedy or mitigate any AEC that it identifies, and it can do so through measures including the imposition of conduct requirements around price transparency or by implementing price controls in the market. The CMA is not, however, entitled to determine that competition law has been infringed following a market study or market investigation. As such, its conclusions do not give rise to the same risk of litigation as with investigations under the Competition Act 1998.
It is essential for participants in either a market study or a market investigation to understand how those procedures work and to seek specialist legal advice. It may be the case that market participants engage with the CMA on a voluntary basis, particularly with a view to informing the CMA's conclusions and influencing the remedies that it might potentially impose in response to an AEC, but the CMA also has significant powers to compel the production of evidence and failure to respond properly can give rise to civil or criminal sanctions.
If you would like to discuss the issues raised in this article, please contact your usual MFMac contact or a member of our Competition & Antitrust team.
