No More Paws for Concern? CMA's Provisional Decision Prescribes Major Reforms for UK Veterinary Sector
The Competition and Markets Authority (CMA) has published its Provisional Decision in its ongoing market investigation into veterinary services for household pets, proposing significant reforms to the £8 billion UK veterinary services sector. The investigation has identified what the authority characterises as systemic competition issues affecting how veterinary practices operate and how consumers access services.
The Provisional Decision sets out a range of proposed remedies aimed at addressing these identified concerns. The CMA is currently consulting on its findings, with stakeholders invited to submit responses by 12 November 2025. Following the consultation period, the authority is scheduled to issue its final decision in March 2026, with implementation of certain measures anticipated by the end of that year. The outcome could significantly reshape the regulatory framework and practice-client relationships across the sector.
Drawing on its working paper findings, the decision proposes no less than 21 separate recommendations, most notably
the publication of price lists
mandating written prescriptions
caps on prescription fees
expansion of a price comparison platform
calling for the prioritisation of legislative reform
With these proposals the CMA hopes to address what it identifies as consumer detriment of “at minimum around £1 billion over five years”. Notably the CMA paws-ed short of more extensive remedies such as ordering divestments or price controls on a wider range of veterinary services.
Background to the Investigation
The CMA launched its review of the sector in September 2023 and issued a Call For Information (CFI) as part of that, which brought in an unprecedent 56,000 responses. In May 2024, the CMA announced the launch of its full investigation into the market for the supply of veterinary services for household pets, which we commented on here.
In May 2025 the CMA published multiple working papers (see our previous update here) setting out its initial findings and emerging views of the state of the veterinary industry. The CMA’s remedies working paper set out wide-spanning proposals to address competition deficiencies, which have now been refined in its Provisional Decision.
Key Provisional Concerns
The Provisional Decision narrows down three key problems that the CMA hopes to remedy:
Lack of information: Vets are not providing pet owners with adequate information to compare practices, treatment options, or alternative medicine retailers such as online pharmacies.
Barriers to action: Pet owners face obstacles including uncertainty about online pharmacy quality and timeliness, high prescription fees, delays in obtaining written prescriptions, difficulties making complaints, and barriers preventing First Opinion Practices (FOPs) from switching Out of Hours (OOH) providers.
Outdated regulation: The regulatory regime is "outdated and wholly unfit for purpose", particularly because legislation currently applies only to veterinary professionals rather than the businesses employing them.
The Proposed Remedies Package
The CMA has proposed 21 recommendations in response, stopping short of some tougher measures initially considered in the remedies working paper.
Transparency remedies: Building on its working paper proposals, the CMA will require veterinary businesses to disclose practice ownership (i.e. identifying where FOPs are part of larger corporate groups) and comprehensive price lists covering consultations, vaccinations, prescription fees, neutering, dentistry, diagnostic tests, and cremation costs. This information would be collated on a comparison website, initially expanding the RCVS's Find a Vet website, with data made available to approved third parties who would like to provide comparison services to pet owners.
Treatment Information: The CMA will require veterinary businesses to offer a written estimate of the cost (including aftercare) of a treatment where it is reasonably foreseeable to cost £500 or more, including an itemised bill to help pet owners understand charges and compare them with previous estimates or prices.
Medicines remedies: The CMA will require vets to explicitly inform pet owners they can obtain a written prescription and that medicines are usually cheaper online. For pets with chronic conditions, pet owners must be given a written prescription to buy medicines online unless they have actively chosen to receive repeat medications from their FOP. Most significantly, the CMA will impose a maximum price for written prescriptions at £16, which is below the current market average of £20 but roughly equal to the average price charged by independent FOPs. Departing from its remedies working paper, the CMA has chosen not to impose interim medicines price controls, suggesting that the CMA considers the above measures will sufficiently open the market.
Regulatory reform: The CMA proposes that a new Veterinary Surgeons Act is urgently needed to give the RCVS the power to regulate veterinary businesses as well as individual vets and nurses, along with powers to enforce standards for businesses, protecting competition and consumers.
The CMA also tempered its proposals to measure the quality of clinical services, instead adopting a remedy from the retail banking market investigation – vet businesses will be required to offer customer feedback surveys at regular intervals, enabling pet owners to compare perceived service levels and costs between large corporate and independent providers.
What This Means for Businesses
Although a final order has not yet been issued, early preparation will be essential to ensure compliance and minimise disruption. The CMA has proposed a 3-month implementation period for larger veterinary businesses, with a 6-month period for smaller practices that may need more time.
Vet businesses may choose to consider:
In-practice pricing: Businesses should review internal pricing structures and prepare to display public price lists on their websites and the RCVS platform. Revenue models must be assessed to understand the impact of the £16 prescription cap and online pharmacy advertising, particularly for practices reliant on medicine revenues.
Billing: Practices not already offering itemised bills or large volumes of written prescriptions may need to upgrade billing practices and IT systems to support the new proposals.
Staff training: Staff will require training on offering written prescriptions and informing pet owners of online pharmacy alternatives. Businesses will also need updated policies and processes to ensure vets and vet nurses comply with RCVS codes of professional conduct on providing independent advice, and appropriate information about treatment options and prices.
Complaints handling: While most practices may have a complaints’ procedure in place, businesses will need to ensure this meets the CMA’s criteria including implementing customer satisfaction surveys at regular intervals.
Ownership disclosure: Corporate groups will need to ensure clear branding and disclosure of group ownership across all their practices, which may require changes to signage, websites, and marketing materials.
Looking Ahead
The CMA's Provisional Decision marks a potential turning point for the UK veterinary sector. With consultation closing on 12 November 2025 and a final decision due in March 2026, businesses have a narrow window to prepare for what could be the most significant regulatory overhaul the industry has seen.
Whilst the CMA stopped short of more drastic interventions, the proposed remedies—from mandatory price transparency to prescription fee caps—will fundamentally change how veterinary practices operate and compete. For businesses, early preparation is key: reviewing pricing structures, upgrading systems, and training staff now will ease the transition when final measures take effect.
If you need more information or further guidance in this area, please contact Dr Saskia King or Tenisha Cramer.
