The Competition and Markets Authority (CMA) has today launched its market study into private dentistry in the UK, including preventative, clinically necessary and cosmetic dental treatments. The study will review whether this market is working well for consumers.
A market study in this sector has been anticipated for a number of months, following on from Rachel Reeves’ letter to the CMA in November 2025 inviting the CMA to conduct a market study focussing on the effectiveness of competition between providers, including at a local level, and the ability of consumers to make effective choices and obtain value for money.
In launching the market study today, the CMA notes that private dentistry accounts for a large and growing part of overall dental provision and with patients facing potentially high and rising costs for what is frequently an essential purchase, it is vital that the market works as well as it can for consumers.
It is also noteworthy that the CMA’s Statement of Scope (see below) indicates that the CMA intends to review the market holistically from both a competition law and consumer law standpoint.
What does the CMA intend to look at?
The CMA’s Statement of Scope indicates that the CMA intends to focus on:
- The interplay between publicly funded dentistry and related policy to the extent it may impact incentives and competition / consumer outcomes in the private dentistry market
- Consumer journey and choice, including how consumers access, assess and act on information to make informed choices; the availability of private dental services and ease of switching for consumers; and other key features of the consumer experience when engaging with private dental services, including dental payment plans / financing of dental treatments.
- How dentists compete to win and keep customers
- Whether dentists engage in any unfair practices or anti-competitive conduct or other conduct that may adversely affect consumers / competition
- The extent to which regulatory frameworks and their enforcement support good competition and consumer outcomes and whether consumers have ready access to appropriate complaint and redress mechanisms
- How prices have changes compared to inflation and the relative profitability of service providers and the different services they provide
What might be the possible outcomes?
The CMA adopts an evidence driven approach and will consider whether measures are required to improve outcomes for consumers after gathering data and conducting its analysis. However, the CMA envisages that potential outcomes from the market study may fall into the following categories:
- Making specific recommendations to governments or taking direct CMA action to improve competition / consumer outcomes
- Informing government policy making
- Highlighting areas at the periphery of the private market / CMA’s remit, where they may have bearing on consumer outcomes in the market. These might include issues connected with publicly funded dentistry (eg labour issues; funding through dental contracts) which have a bearing on the provision of private dental services.
The market study must be concluded by 4 March 2027, and the CMA has indicated it expects to use the full 12 months due to complexities of the sector. The CMA has also stated that it will adopt a proportionate approach in its interactions with business, in line with the CMA’s “4Ps framework” of pace, predictability, proportionality and process.
Interested parties now have an opportunity to comment on the Statement of Scope, with representations being requested by 2 April 2026. The CMA wishes to hear from a range of stakeholders, including dentistry professionals and businesses, ranging from corporate groups to independent practices, as well as consumers and consumer groups.
Other early opportunities for engagement with the CMA include a short survey for dental professionals (with a deadline of 19 March 2026) and a CMA webinar on 18 March 2026.
Engagement, evidence gathering and analysis will run from March to early September 2026, with consultation on emerging thinking and remedies expecting to occur in October – November 2026.
What should providers do now?
Our previous blog series set out key information for providers on what to expect during a market study and how to prepare. Now that a market study is underway, providers should consider:
- Setting up an internal project team to coordinate responses
- Mapping key data sources and internal documents, such as board papers, and checking how easily information can be extracted
- Formulating their strategy for engaging with the market study, including identifying where the scope of the study may present risks or opportunities for their organisation
- Identifying key points to make on the issues set out in the Statement of Scope
- Planning for operational impact, including resources pressures and any external support that is required
The Mills & Reeve Health & Care sector team, Competition team and Consumer Regulatory team combine deep sector knowledge and expertise in supporting clients with CMA regulatory processes, including market studies and market investigations. Do get in touch if you would like to discuss how the market study may impact on your organisation and how we can support you.
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