The CMA’s draft Annual Plan has been published and centres on promoting competition and protecting consumers with the aim of encouraging economic growth and improving household prosperity. This follows the UK government’s Strategic Steer to the CMA, which gives clarity about the policy priorities the CMA can help advance, while acknowledging its statutory independence.
The Annual Plan priorities build on the five core objectives in the CMA’s Strategy, which reflect a combination of continuity and change for the CMA.
The CMA’s 4Ps framework – pace, predictability, proportionality and process – remains a focus for the coming year with the aims of reducing the regulatory burden on business and of strengthening the business and investor confidence that is needed for economic growth.
Among other things, the CMA is looking at:
- Competition enforcement: Building on a strong track record of enforcement, including sizeable fines and director disqualifications, as well as millions of pounds secured through commitments. Continuing to target anti-competitive activity, including practices that prevent innovative firms from entering and scaling. Prioritising action on public procurement, including investing in detection tools (like AI and data analytics) to scan for bid-rigging. Enabling pro-growth collaboration in priority sectors. Deterring algorithmic price collusion.
- Digital markets competition regime: Progressing work on Search and Mobile. In Search, focusing on greater choice and control, including through choice screens and publisher controls. In Mobile, promoting greater competition, certainty and confidence for app developers and making sure that firms, such as digital wallet providers, have access to the functionality they need to innovate and compete. In considering any further SMS investigation launches, maintaining a focus on whether the CMA is best placed to act and ensuring ample opportunity for stakeholders to engage.
- Consumer protection: Promoting trust and confidence through robust consumer protection, so people can participate actively in the economy and businesses can compete on a level playing field. Progressing first investigations on price transparency and misleading online choice architecture. Maintaining a strategic approach to implementing the new consumer regime – prioritising areas of essential spend and egregious practices where the law is clear, while driving behavioural change in businesses and sectors using advisory letters and broader engagement.
In addition, the CMA has launched a review of its guidance on unfair terms in consumer contracts, which will be relevant for tech lawyers advising on online terms and conditions. The law on unfair contract terms has not changed since 2015, so businesses’ obligations remain unchanged. However, the CMA is updating the guidance to make it easier for businesses to understand unfair contract terms law and help them to comply; and to reflect other relevant developments, including direct consumer enforcement powers for the CMA under the Digital Markets, Competition and Consumer Act 2024. The consultation ends on 19 March 2026.
