What’s in store for the UK competition law landscape in 2026?

2025 was something of a turbulent year for the UK Competition and Markets Authority (CMA). It began with a change of leadership, when former Chair, Marcus Bokkerink, was replaced by Doug Gurr, formerly of Amazon UK. This coincided with a new strategic steer from the UK Government to the CMA, which urged the CMA to put their focus firmly on supporting the Government’s growth agenda.

These changes heralded a raft of proposals and reforms based around the CMA’s new “4Ps” framework, seeking to bring more “pace, predictability, proportionality and process” across all areas of the CMA’s work, to drive growth and business confidence (see our blog post on competition law regulator responds to government growth edict).

The year finished with a speech by Sarah Cardell, the CMA’s Chief Executive, launching the CMA’s 2026 to 2029 strategy to “continue the journey of transformation we have been on over the last year”.

So, what lies ahead for the UK competition law landscape in 2026? We’ve dusted off the crystal ball to put together some predictions. 

Continued focus on the 4Ps – but what will this mean in practice?

First, what’s not going to change. The CMA has said that its 2026-2029 strategy is “not a handbrake turn” and has been keen to stress that its statutory mandate to promote competition and protect consumers is unchanged. This is the case, notwithstanding that the end goal of driving economic growth and improving household prosperity has been added to the strategy to reflect the current economic and political context. So, we can expect to see continued focus on embedding the 4Ps framework that was introduced in 2025 across all areas of the CMA’s work.

For merger control, 2025 saw changes focussed on process and pace, with the introduction of a Mergers Charter which sets out clearly how the CMA expects to engage with merging parties; and ambitious KPIs of a 40 working day pre-notification period and clearance for unproblematic mergers after 25 working days. Finally, revised merger remedies guidance was published on 19 December 2025.

Looking ahead to 2026, all eyes will be on the CMA’s decision making to assess how well these changes are being delivered in practice, and whether this results in more business-friendly merger reviews. In particular, the revised remedies guidance indicates more openness on the part of the CMA to accepting behavioural remedies to address an identified substantial lessening of competition caused by a merger, including at Phase 1. This has the potential to rebalance the CMA’s historic preference for structural, divestment remedies.

However, while this move towards greater flexibility is welcome, it’s clear that this doesn’t mean that we can expect a green light for all behavioural remedy proposals. For example, the CMA’s press release on the recent referral of Getty’s proposed acquisition of Shutterstock to an in-depth Phase 2 investigation noted that the parties “offered a complex package of remedies at a late stage in the Phase 1 process”, and that following assessment, the CMA concluded these didn’t fully address its concerns.  

The CMA will continue to assess remedies proposals on the basis of the facts of each case and if merger parties potentially wish to propose a complex remedy to address any issues that may be found, it will be important to discuss this with the CMA at an early stage on a without prejudice basis.

More reform to come

Sticking with merger control, the CMA will also be launching a review of their approach to efficiencies in merger assessments in early 2026. This follows feedback from respondents to the remedies consultation that improvements could be made to the way in which the CMA considers efficiencies arguments as a defence to any substantial lessening of competition.  

In 2026, we also expect legislative proposals from the Government concerning the application of the “share of supply” test, which gives the CMA jurisdiction to review a merger where the parties together have a combined share of supply of 25% or more; and the “material influence” test, under which the CMA can review the acquisition of minority shareholdings when the acquirer also gains the ability to “materially influence” the commercial policy of the target (eg through voting rights or Board representation). Both of these tests can be applied flexibly by the CMA and historically this has led to an expansive approach to jurisdiction, which can cause uncertainty for merging parties. Addressing this is part of the Government’s aim to ensure that the CMA’s activities are (you guessed it) “predictable and proportionate” for business and investors.

Finally, a consultation is expected on proposed reforms to the CMA’s decision-making structure, by abolishing the current model of independent panel groups being appointed as decision makers in Phase 2 mergers and market investigations. This would be replaced with a committee of the CMA Board, comprised of Board non-executives, senior executives, and expert panel members. This would bring the structure into line with the new digital markets competition regime. The CMA considers that this reform would improve accountability and predictability, by ensuring that the CMA’s most strategic decisions are taken by those directly accountable to Parliament. However, the panel system has its defenders who appreciate the clear independence from CMA case teams and the “real world” business experience that panel members can bring to complex merger cases and market investigations. The consultation will be one to watch and those with experience of panel decisions (positive or negative) should look out for the opportunity to comment.

What about competition enforcement?

We also expect the 4Ps framework to impact the CMA’s approach to enforcement in 2026. We anticipate that they will work to narrow the focus of cases, both new and ongoing; and where possible, reach early case closure through commitments and settlement agreements with the parties, unless there is a strong public policy reason to conclude a case formally with fines, for example to achieve a clear deterrent effect.

The 2026-29 strategy makes clear that the CMA will “consciously prioritise markets and issues that deliver the greatest positive impact for the UK’s economy, citizens and businesses”. This is consistent with CMA speeches made throughout 2025 that indicate that the CMA will focus its enforcement action on priority areas. This includes the sectors identified in the Government’s Modern Industrial Strategy as priority sectors for growth: advanced manufacturing, clean energy, creative industries, defence, digital and technologies, financial services, life sciences, and professional and business services (the IS-8). Businesses in these sectors should expect scrutiny and take steps to ensure their competition compliance policies are up to date.

A greater focus on industrial strategy led to the launch of the civil engineering market study in 2025, looking at ways in which competition may not be working well in road and rail infrastructure projects. The final report on this is expected in April 2026 following consultation on the interim report which was issued on 17 December. A range of measures have provisionally been identified for improving outcomes in the sector, which are likely to take the form of recommendations to government.

The civil engineering interim report also identifies problems in procurement as an issue, and we expect the CMA to continue to focus its attention on public procurement in general in 2026. The most recent CMA Growth Council minutes also highlight procurement as a “significant barrier for scale ups and smaller businesses” and encourage the CMA to continue reviewing procurement practices and competition policy to ensure they support innovation and enable new entrants, again with a focus on IS-8 sectors such as defence and life sciences. The CMA has been open about its use of data analytics and AI tools to detect possible bid rigging in public procurement and we may see enforcement action in this area in 2026. Enforcement activity may also engage the new exclusion and debarment regime under the Procurement Act 2023, which came into force in February 2025. Under this regime, companies found to have infringed competition law may be added to a central register and excluded from all public procurement for up to 5 years.

Following on from its work on veterinary services for pets, where the CMA considers its intervention will bring down prices and improve consumer choice, they are likely to continue to focus on costly, consumer-facing sectors by turning its attention to private dentistry in 2026. The Government invited the CMA to conduct a market study into the private dental care market in November of 2025 and the CMA in response confirmed that it is carrying out initial exploratory work on this area.

We also expect that the CMA will keep up its focus on competition issues in labour markets in 2026, building on the “Competing for Talent” guidance which was published in September 2025 and the intensive programme of outreach the CMA has undertaken in this area. The CMA is concerned particularly with no-poach agreements, wage fixing and the sharing of competitively sensitive information relating to wages and terms of employment. Their current investigation into suspected reciprocal arrangements relating to hiring and recruitment of staff between businesses in the fragrances sector may reach a conclusion in 2026. This will add to the CMA’s decision to impose fines of over £4 million on sports broadcasters for unlawful information exchanges relating to pay.  Our experience is that there is still generally a low level of awareness amongst HR professionals of the impact of competition law on their activities, and this should be an area of focus for compliance training in 2026.

Can’t forget about digital...

The digital markets competition regime introduced by the Digital Markets, Competition and Consumers Act 2024 (DMCCA) introduced a new standalone competition regime for the largest digital players by allowing the CMA to “designate” a firm as having strategic market status, and once designated, to impose conduct requirements to ensure fair dealing with businesses using the relevant digital services and address any adverse effects on competition. Having designated Google in respect of its general search and advertising services, and separately for its Android mobile operating system, and Apple for its mobile platform, we’re expecting the first conduct requirements to be developed and imposed in 2026. This will give users of those services an opportunity to comment and provide feedback in the consultation processes.

And what about consumer issues?

The DMCCA also introduced an enhanced consumer protection regime in the UK in 2025. The CMA spent the year issuing guidance and engaging in outreach to businesses to help them prepare for and achieve compliance. 2026 will see a gear shift to enforcement activity. Eight investigations into drip pricing and pressure selling were opened in November 2025 and these may conclude in 2026.

Conclusions

We expect another busy year for the CMA in 2026 as they work toward delivery on the reforms that we saw through 2025.

Businesses may be able to gain from quicker, less burdensome merger review processes, although it is clear that achieving the more ambitious timeframes will require merger parties to work to tight deadlines and focus their submissions on key issues. Users of important digital services may also be able to benefit from possible conduct rules to be imposed on providers designated as having strategic market status.
However, businesses of all sizes, particularly those in IS-8 sectors, should ensure their houses are in order across their procurement activities, the ways in which they compete to recruit and retain talent, and the ways in which they advertise and price to consumers, as CMA enforcement in these areas is highly likely in 2026.