Dutch vets under the ACM microscope: consolidation, emergency care and a push to ban commercial incentives

Main takeaways

• On 18 December 2025, the Dutch competition authority (ACM) published a draft market study on veterinary services for pets (in Dutch), flagging growing risks of higher prices and overprovision of veterinary care;
• The ACM links these risks to the alleged increasing commercialisation and chain ownership (although the draft report finds no evidence that this is a significant problem in the Netherlands), combined with consumer vulnerability, an alleged lack of transparency and pressure points in emergency care;
• The ACM’s recommendations go beyond soft guidance and seem to take an advance on the much desired new competition tool, as they include a proposed ban on revenue- and profit-related incentives, stronger transparency obligations and a call for expanded merger control tools.

What happened?

On 18 December 2025, the ACM released a draft report on the market for medical care for companion animals. The trigger for its market investigation had been a growing number of signals about high and unpredictable prices, limited transparency, and the rapid emergence of veterinary chains, often strung together by private equity investors.

Although formally presented as a market study, the report clearly looks ahead. The ACM questions whether the current framework offers sufficient protection to pet owners and sketches a package of measures that could significantly reshape the sector. The draft is open for consultation until 23 January 2026, with a sector meeting planned for 11 February 2026.

Initial reactions

Reactions have been mixed as the draft is more nuanced about the vet services sector than media headlines suggest: overall satisfaction remains high, choice is sufficient in most of the country, and the ACM does not claim to have established widespread Netherlands-specific financial incentive schemes directly steering treatment decisions (save for targeted mechanisms such as earn-outs). Others read the report as a call for clearer sector-wide guidelines, particularly to protect professional autonomy and improve transparency in emergency settings. Overall, the ACM’s narrative is largely risk-based (and ex ante), rather than finding regular or systematic misconduct.

The ACM’s diagnosis

The report points to a familiar combination: demand-side vulnerability coupled with supply-side consolidation.

Consumer vulnerability, especially in emergencies

Pet owners often lack the time, medical knowledge and emotional distance to compare treatment options and prices. This is particularly acute in emergency situations, where urgency severely limits choice. Proximity plays a major role in the selection of a veterinarian, and many owners do not actively consider alternatives. Limited price transparency further weakens competitive pressure.

Consolidation and commercial strategies

On the supply side, the ACM points at the increasing role of chains operating multiple practices across regions. According to the authority, chain ownership may be accompanied by commercial strategies such as internal referral steering, expansion of billable services, and centrally managed pricing or performance targets. The concern is that these strategies can reduce the professional autonomy of veterinarians and create incentives that are not fully aligned with the interests of the animal and its owner.

Interestingly, the draft report also states that, currently, there is no evidence that these practices occur in the Netherlands (except in specific merger situations, in which so-called ‘earn-out’ agreements were made). 

Price effects following acquisitions

The ACM refers to research into a limited number of acquisitions showing price increases after takeovers, particularly for veterinary medicines. These increases do not appear to be driven by higher volumes of care or more frequent visits, suggesting that revenue growth is primarily price-based rather than the result of expanded services.

Emergency care as a stress test

Out-of-hours emergency care receives particular attention. The ACM notes limited availability and the absence of a comprehensive, reliable national overview of emergency locations. This lack of transparency matters most precisely where consumer vulnerability is highest.

Lack of sector guidelines in comparison to human healthcare

The report repeatedly contrasts veterinary care with human healthcare, emphasising the absence of system-level safeguards such as sector-wide professional standards, insurer purchasing power or dedicated quality oversight. According to the ACM, the lack of sector guidelines increases the risk of over-treatment and excessive pricing.

What the ACM proposes

In substance, the ACM is not advocating a classic enforcement response (i.e. a single-firm infringement case), but a set of ex ante safeguards (“guidelines”) to reduce the risk that information asymmetry and consumer vulnerability result in higher prices and inappropriate treatment choices.

The ACM points to five main levers:

• Remove financial steering: prohibit turnover and profit-related incentives for veterinarians and staff, including incentives linked to volumes of care, medicine sales and intra-group referrals.
• Professional standards: encourage the sector to develop uniform professional treatment standards for common procedures, providing clearer benchmarks for “appropriate care” and strengthening the position of veterinarians vis-à-vis corporate owners.
• Closing the merger-control gap: expand the ACM’s ability to review small but potentially problematic acquisitions that fall below current turnover thresholds, particularly in areas with limited choice or high local concentration (addressing “roll-up” dynamics).
• Transparency obligations: strengthen requirements around price and transparency (treatment costs, alternatives, and referral relationships), including in emergency settings where switching and search are practically constrained.
• Ultima ratio: if these measures do not reduce the identified risks, the ACM explicitly points to price regulation as a potential last-resort instrument.

Why this is noteworthy

Beyond veterinary care, the draft report illustrates how the ACM can combine consumer vulnerability, local concentration and commercial incentives to justify stronger intervention in markets with limited traditional oversight. It also signals that consolidation strategies may increasingly be examined through a broader lens than classic cartel or abuse cases, with attention to incentive structures, transparency and cumulative effects of small acquisitions.

The consultation period of the draft report lapses on 26 January 2026, after which the ACM will finalize the report, which is expected to be published by March 2026.

It will be interesting to see whether the ACM will be able to address the alleged issues, as the draft report also concludes that there is, currently, no evidence that Dutch veterinarians are acting on price-based incentives only, nor hints at a risk relating to excessive pricing. Furthermore, one could doubt whether high pricing levels in the veterinarian sector can be resolved under EU competition law. Firstly, the cost structure of veterinary services remains insufficiently transparent, making meaningful price comparisons difficult. In particular, observed price increases may be driven by a range of factors unrelated to competitive distortions, including the prices and taxation of veterinary pharmaceuticals, species-specific medical requirements, pet owners’ willingness to opt for the highest standard of care, and the wage levels necessary to attract and retain highly qualified veterinary professionals. Secondly, the specific context of veterinary services must be taken into account. For example, strictly speaking, it is possible to just sedate pets and perform surgery on them. While this may be a less costly option, it may be deemed unethical by most veterinarians (and less preferable to pet owners) as they aim to provide the highest, animal-friendly level of care (e.g. by using gas-based anesthetic and anesthetic monitoring equipment). Another example relates to staffing: would both animal health care professionals and pet owners prefer a 24/7 presence of veterinarians and veterinarian assistants / para-veterinarians for taking care of the animals at night or over the weekend? or would they prefer a minimum level of care during those hours? The latter will probably save costs but may also constitute a less desirable option. 

Part of this problem is also caused by national legislation, which requires veterinarians to provide a high duty of care to ensure animal health and welfare - regardless of the costs. Under the Animals Act (Wet Dieren), animal health care professionals are subject to a duty of care. This is an open social standard, which is generally filled in by best sector practices and unwritten social norms. Hence, an open duty of care may come with a price. A price that a majority of pet owners seem willing to pay. The question therefore remains whether competition law is the best tool to address alleged market failings within this sector. 

Conclusion

Whether the ACM’s far-reaching recommendations ultimately translate into legislation or action remains to be seen. But the direction of travel is clear: veterinary care is being treated as a market where commercial incentives and local concentration can translate quickly into consumer harm, especially in emergency settings. For the sector, “business as usual” is no longer a given. More broadly, the report is a reminder that market studies can be the first step towards rules that materially reshape how competition is expected to work.

This article was written with assistance from Juliette Tiel Groenestege.

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