Competition

CMA Enforcement Priorities 

Businesses are entering another pivotal year for UK competition law. The Competition and Markets Authority (CMA) will continue to exercise enhanced powers under the Digital Markets, Competition and Consumers Act 2024 (DMCCA), alongside updated merger control thresholds and a sharper enforcement strategy.

The last year has seen significant change for the CMA’s agenda, with there being a sea-change at the executive level and an increased focus on growth and being ‘business friendly’. The Government announced the ‘strategic steer’ for the CMA in May 2025, calling on the CMA to use its regulatory powers to encourage competition, with the hope of it leading to more innovation, choice, quality, security of supply, productivity, investment, and economic dynamism.

In tandem, the CMA released its ‘4Ps’ framework (pace, proportionality, predictability and process), highlighting an updated approach to reviewing digital mergers and firms under the DMCCA. These changes mean businesses in the UK need to be alive to the CMA’s priorities and take proactive action to anticipate any CMA interest in their M&A activity.

Looking to 2026 and beyond, the CMA’s 2026–2029 strategy and enforcement priorities signal an assertive and targeted enforcement approach. Specifically, the three-year strategy will focus on the following objectives:

Promoting effective competition

• Implementation of the 4Ps framework across all operations
• Ensuring competition enforcement and merger control foster dynamic markets and innovation
• Focus on the implementation of the digital markets regime and Strategic Market Status (SMS) designations to unlock growth and choice

Championing consumers

• Enhanced consumer protection through new powers to order redress and sanction non-compliance, in particular focusing on issues of ‘drip pricing’, misleading discounts, false urgency practices such as ‘countdown timers’ and fake reviews
• New controls on subscription contracts
• Updated guidance for businesses on unfair terms to aid compliance with consumer law
• Potential reforms to the secondary ticketing market

Helping government deploy pro-competition interventions

• Advice on public procurement and regulatory barriers
• Supporting the removal of anti-competitive regulations and enabling access to critical data
• Provision of independent advice on subsidies and the UK internal market

Fostering a UK regulatory landscape that attracts investment

• Creation of a predictable, proportionate environment to boost investor confidence
• Alignment with broader regulatory reforms and embedding the 4Ps approach

Prioritising UK interests

• Focus on markets and issues with the greatest impact on UK citizens and businesses
• Supporting strategically significant sectors and avoiding unnecessary duplication of global efforts

More broadly, the CMA will be considering the following aspects.

Digital markets oversight

The CMA will focus on firms with significant influence over digital ecosystems, particularly those designated with SMS (to date, both Apple and Google have been designated as having SMS by the CMA). Expect proactive investigations into conduct that restricts competition, such as self-preferencing, tying, and exploitative data practices. 

Businesses that rely heavily on this online digital infrastructure should consider whether any anti-competitive practices by these SMS entities impact their ability to compete. If so, there may be better recourse to remedies post-DMCCA implementation. 

Consumer protection integration

Enforcement will increasingly combine competition and consumer law, addressing practices that distort choice or mislead consumers. The CMA intends to use its new powers under the DMCCA to impose direct orders and financial penalties without court involvement. Most recently in November 2025, the CMA launched a number of investigations into firms which it believes may have breached consumer law protections, demonstrating the CMA’s intent to follow through on its enforcement promises. 

Merger scrutiny

The CMA will prioritise mergers in sectors where innovation is critical, such as technology and life sciences. Transactions that risk eliminating nascent competitors will face heightened review, even where they may fall below traditional turnover thresholds. The CMA will rigorously review sectors which have a clear impact on the UK’s growth to ensure innovation continues to thrive. 

The Government is also anticipated to introduce legislative reform proposals to provide more certainty on where mergers will be subject to investigation in the UK by addressing uncertainty with the existing ’share of supply’ test (which grants the CMA jurisdiction to review a transaction where merging parties hold a combined share of 25% or more) and the ‘material influence’ test (which enables the CMA to potentially review acquisitions of minority stakes). The CMA has historically applied both tests with considerable flexibility, often resulting in broad assertions of jurisdiction and more uncertainty for merging parties. The anticipated reforms are intended to support the Government’s objective of ensuring that the CMA’s decisions are, as promised, more “predictable and proportionate” for businesses and investors.

International cooperation

Cross-border enforcement will remain a priority, with the CMA strengthening ties with EU and global regulators to tackle multi-jurisdictional anti-competitive conduct.