On 15 May 2025, the UK government issued the final version of its "strategic steer" to the Competition and Markets Authority (CMA). The steer sends a clear message that the government expects the CMA to support and contribute to its growth agenda but also provides welcome reaffirmation that the CMA must continue to exercise its functions independently.
The steer applies to all aspects of the CMA’s activity over which it has discretion and includes high-level directions inviting the CMA to:
The steer sets out that the CMA should give appropriate consideration to "prioritising pro-growth and pro-investment interventions, focusing on markets and harms that particularly impact UK-based consumers and businesses, [and] supporting growth and international competitiveness in the Government’s industrial strategy’s eight key sectors."
In doing so, the CMA should consider actions taken by competition agencies in other jurisdictions and ensure parallel regulatory action is timely, coherent and avoids duplication. The CMA should also use the new Digital Markets, Competition and Consumers Act 2024 digital markets regime flexibly, proportionately and collaboratively. This includes taking particular care to collaborate with all interested parties to ensure growth and innovation benefits are prioritised and support the government in delivery of the AI opportunities action plan.
The steer also sets out that "the CMA should provide proactive and responsive engagement with businesses to enable them, in turn, to engage quickly and effectively with the CMA.’" This entails reviewing procedural guidance and practice to ensure accessibility and balance the need for public transparency with the market impact of regulatory activity. Additionally, the CMA should continue to develop a contemporary evidence base to demonstrate how competition delivers economic growth across the UK.
Finally, the steer sets out that the CMA should "continue to engage with government on key policy issues" and "work with government to identify areas where the CMA can, through the markets regime, or through wider advocacy, support the agenda of this government."
The CMA is expected to account for the steer in its work. To support this, the government will update the CMA’s framework agreement to include relevant reporting requirements and require regular feedback from stakeholders.
While it has long been settled practice that the UK government should be able to feed into and inform the CMA’s work, the steer clarifies that the CMA must independently exercise its statutory functions for the enforcement of competition and consumer law in the UK. Recent pronouncements and interventions by government (including publishing the draft strategic steer apparently timed to coordinate with a CMA blog post, see our update here) have given some commentators cause to query whether this signalled the start of a new, more interventionist period. In fact, there is no suggestion that the government will become directly involved in individual cases or that there will be any further hands-on direction or weakening of the UK’s independent merger control or antitrust regimes.
However, the steer’s focus on growth does mark a clear change in direction, compared to previous steers’ emphasis on a broader range of objectives. There is also a dialled back approach to the previous steers’ call for the CMA to function as a thought leader and global voice on competition and consumer issues.
The strategic steer provides further impetus for the CMA’s ongoing reshaping of its merger control regime, as well as the CMA’s other functions. Sarah Cardell, chief executive of the CMA, has already taken up this challenge by announcing various merger control improvements based around the "4Ps" framework she introduced last year – pace, predictability, proportionality, and process – with specific proposals for mergers. Click here for more information.
Looking to the future – priorities for intervention
The strategic steer, as well as the CMA’s annual plan, highlights the importance of driving efficiencies in the public sector. The CMA intends to build on its strong record of protecting the public purse by intensifying its work to stop bid-rigging in public procurement. In particular, it plans to invest in detection tools, including data analytics and AI, to identify suspicious activity.
While public procurement is a priority, the CMA also intends to focus its interventions in the short – medium term in the eight sectors that the UK government has identified in its industrial strategy green paper as presenting the greatest opportunity for output and productivity growth, namely advanced manufacturing, clean energy industries, creative industries, defence, digital and technologies, financial services, life sciences, and professional and business services. In particular, the CMA has indicated that wants to hear from businesses facing barriers to entry or expansion that competition law could help them solve, or where there is concrete evidence that competition law concerns are chilling beneficial collaborations.
Meanwhile, in Europe…
On 25 April 2025, the European Commission published its report on Competition Policy in 2024. The Report highlights the role of modernising and simplifying the competition rules to strengthen the Single Market and contribute to EU competitiveness. In particular, there is an emphasis on where businesses can make the most of Europe’s scale to develop strong and competitive industries to the benefit of European citizens. The Report also highlights how competition policy has helped supporting the green and digital transitions, in line with the Commission’s political priorities, while protecting and empowering consumers.
European Commission’s review of EU merger guidelines
Then, on 30 April 2025, Teresa Ribera, executive vice president (EVP) and commissioner in charge of competition policy, gave a speech in which she discussed the future of competition policy and Europe’s strategic autonomy.
She discussed, among other things, the Commission’s approach to merger control, highlighting that while the Commission wants European champions, it will not let players concentrate at the expense of competitive markets or consumers. In other words, the Commission wants competitiveness, which is not a race to the bottom, and to that end it will only support mergers that enhance Europe’s global position and truly contribute to innovation.
Like the CMA, the Commission is also considering its merger control regime. On 8 May 2025, they initiated a public consultation to gather feedback on its review of the EU merger guidelines. According to the Commission’s press release, "the review process will focus on how the Commission's assessment should give adequate weight to innovation, efficiency, resilience, the time horizons and investment intensity of competition in certain strategic sectors, sustainability, the changed defence and security environment and other acute transformational needs of our times." In addition, "the Commission has published seven focused papers, elaborating on a wide range of current challenges and on the legal and economic parameters used in its merger control assessment." The papers will be the basis for a continued targeted engagement with stakeholders including through dedicated events and workshops.
The merger guidelines review will cover both the horizontal and non-horizontal merger guidelines. The Commission notes that "since the introduction of both sets of guidelines, there have been several transformational changes in the economy, ranging from digitalisation and globalisation to decarbonisation, which can impact competitive dynamics in many markets" and "the current review of these guidelines will serve to update the assessment framework for mergers in light of these changes and new market realities, and also enable us to reflect the case practice and the case law of the Court of Justice of the European Union." This indicates a much broader focussed review than the procedural lens the CMA is applying.
Conclusion
There is some apparent divergence between the UK government’s strategic steer and the CMA’s direction of travel, and the Commission’s approach to competition policy. The UK is sharply focused on the overriding national priority of economic growth, whereas the Commission has taken a broader perspective, focusing on setting a course to keep up with the rapid evolution and structural imbalances of markets. In fact, although the Commission views competition policy as a critical tool to boost productivity, efficiency and innovation, the Competition Policy in 2024 Report does not specifically feature "economic growth" as one of its overarching themes.
However, despite these differences, there remain marked underlying similarities between the UK and EU competition policy approaches. Most notably, both the CMA and Commission recognise the need for comprehensive, predictable, and lasting merger control frameworks, which are not unduly burdensome, and which work for all types of mergers and all economic sectors. The EU’s primary mission of preserving a competitive internal single market may lead it to take a broader approach to its work compared to the CMA working in line with the strategic steer. It will be interesting to see if greater divergence emerges following their current review exercises.
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