Growth, growth, growth: Competition & Markets Authority publishes annual plan

On 27 March 2025, the Competition & Markets Authority (CMA) published its 2025-2026 annual plan (the annual plan). The document looks and sounds markedly different from previous editions. The front page is decorated with blue arrows pointing upwards, and comes with the subtitle ‘Promoting Competition and Protecting Consumers to drive growth, opportunity and prosperity for the UK.’ The number of instances of the word ‘growth’ increases to 68 (compared to 10 in the 2024-2025 annual plan). These presentational changes may appear trivial, but they hint at what could be a profound shift in the way the regulator exercises its statutory function (ie to promote competition, both within and outside the UK, for the benefit of consumers). In her foreword to the annual plan, CMA CEO Sarah Cardell observes that: 

• “The external landscape in which the CMA operates has altered considerably in the last year. We have a new government, whose number one mission is economic growth, underpinned by higher levels of investment.” 
• “Whilst the CMA’s purpose remains constant, the work we do and, crucially, the way we go about it, must reflect this changed environment.” 

The CMA’s strategy for carrying out its functions in a way that encourages economic growth is to focus on the ‘4Ps’ – pace, predictability, proportionality and process, with process meaning more direct engagement with business. We unpacked the meaning of the 4Ps in this blog post: Competition law regulator responds to government growth edict.

The annual plan sets out the CMA’s progress to date implementing the 4Ps. So far this year, it has announced a package of reforms to the UK mergers regime, launched a review of its approach to merger remedies and published a new Merger’s Charter (see this Mills & Reeve blog post for more details: New Merger’s Charter and merger remedies review: should business leaders be toasting this news from the CMA?) More detail is expected later this month on how the CMA will apply the 4Ps to the exercise of  its new powers under the Digital Markets, Competition & Consumers Act. For more on this, see: 

• New year, new competition rules for digital markets in the UK
• Fireworks or a slow burn: How actively will the Competition and Markets Authority enforce new consumer laws?

The annual plan says that the CMA will: 

• “Support growth and international competitiveness in the eight key sectors of the Government’s Industrial Strategy.”
• “Continue our ongoing programme of consumer-facing markets work that helps put money back into people’s pockets” (eg its investigations into the markets for formula milk and veterinary services). 
• “Help the government identify and tackle bid-rigging in public procurement.”
• “Apply a sharper priority to markets work that could have a multiplier effect on growth.” 
• “[start] specifically reviewing and reporting on how our work has contributed to economic growth in our future Annual Report and Accounts.”

All very interesting, but how does this affect my organisation? 

Previous CMA annual reports, particularly in the years immediately after Brexit, focussed on the CMA’s role as a thought leader and standalone regulator on the world stage. More recent annual reports have focussed on the CMA’s role in protecting consumers against cost-of-living pressures. The pivot in the 2025 – 2026 annual report to a strong focus on growth, and building confidence amongst companies and investors, is marked. This suggests that organisations should expect to see a tangible and more “business friendly” difference to the work that the CMA prioritises, and the experience that organisations have when dealing with the CMA.

What types of work are likely to be prioritised? Where the CMA has a discretion when deciding whether to act (eg its markets and its enforcement work), it's likely that the CMA will prioritise interventions which align closely with the goal of driving growth and investment in the UK, whilst also upholding the CMA’s responsibility to promote competition and protect consumers. For example, in its market work, the CMA has indicated that this will mean a “sharper priority” to cases that could have a multiplier effect on growth and has signalled an intention to look for opportunities to unlock investments in critical infrastructure and identify areas where key horizontal enablers – such as access to data or technology adoption – can drive growth.   

As for how organisations interact with the CMA, the focus will be on embedding the 4Ps across the CMA’s programme of work. Indeed, the forward to the 2025-2026 annual report by Doug Gurr, the interim chair, notes that there's “work to be done, at pace, to make sure the experience feels genuinely different for our stakeholders across several core areas” and refers to “the meaningful changes needed for the CMA to become more efficient, to deepen our expertise and to continue strengthening our engagement”.  As and when the 4Ps are successfully implemented, organisations could therefore expect to see streamlined and proportionate processes, faster decisions and enhanced levels of engagement, all of which are likely to be welcome changes.   

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