The Competition and Markets Authority (“CMA”) has published its Annual Plan for 2025-2026.

Subtitled “promoting competition and protecting consumers to drive growth, opportunity, and prosperity”, the Plan echoes a number of recent statements by the CMA signalling its commitment to support the Government’s primary mission of delivering economic growth. It also mirrors in many respects the recent commitments made by the CMA in response to the Government’s draft ‘Strategic Steer’ (commented upon here).

The recently-announced ‘4P framework’ (pace, predictability, proportionality, and process) also features heavily in the Plan, appearing in many of the sections on which the Plan focusses.

1. Market Reviews, Studies and Investigations

The CMA states that it will continue its programme of work on consumer-facing markets, with a particular focus on areas that “could have a multiplier effect on growth” and can support the Government’s Industrial Strategy. Examples provided included work on housebuilding, electric vehicle charging infrastructure, access to data, and technology adoption.

The Plan states that the CMA is currently reviewing the way it conducts its markets work in line with the 4Ps Framework and will provide an update in this regard later in the spring.

2. Competition Enforcement

The CMA commits itself to “continue to resolutely deter restrictive, exclusionary and exploitative anti-competitive practices” in the year ahead, with a particular focus on public procurement. The Plan explains that public procurement can be “severely compromised by anti-competitive behaviour, such as bid-rigging” and promises to build on its work in this area (backed by harsher punishments in the recently-enacted Procurement Act) to “increase the detection of unlawful conduct, potentially unlocking considerable productivity gains and public sector savings for the benefit of UK taxpayers”.

The Plan also states that the CMA will provide further guidance on how UK businesses can “collaborate to drive greater productivity and innovation, particularly in the UK government’s priority Industrial Strategy sectors and in critical areas of need for the UK economy, such as skills”.

3. Merger Control

The Plan reiterates many of the commitments that featured in the recently-published Mergers Charter (which we commented upon here). The 4P Framework will be at the heart of the CMA’s approach to mergers: with regards to ‘pace’, the CMA commits to minimise the end-to-end length of merger investigations, driving the period of time to complete the pre-notification phase from 65 working days to 40, and reducing the target for straightforward phase 1 cases from 35 working days to 20. On ‘predictability’, the CMA will update its guidance on the legal tests of ‘material influence’ and ‘share of supply’ to provide greater certainty for businesses. As for ‘proportionality’, the CMA points to a recent review of its approach to remedies (which we commented upon here) as well as work on how it will “take a proportionate approach to looking at global deals…carefully exploring how far (under existing law) we might more clearly distinguish between deals with a distinct and direct UK impact, versus those where it may be more appropriate to watch closely whether action by other authorities could resolve UK concerns”. Finally, on the matter of ‘process’, the CMA promises to “break down barriers to more direct engagement (both outside of and during investigations) including through a targeted outreach programme for businesses and investors; more senior meetings early in the review process; and a suite of accessible, engaging, business-friendly materials”.

4. Consumer Protection

On 6 April, most of the consumer protection regime in under the Digital Markets, Competition and Consumers Act 2024 (DMCC Act) came into force. The CMA points to the regime as bolstering its ability to “tackle misleading sales practices and unfair terms, and help to ensure that all fair-dealing businesses can compete on a level playing field”.

This month, the CMA will publish final guidance and an ‘Approach’ document for its new consumer protection powers, setting out its enforcement priorities for the next year.

5. Digital Markets

The new digital markets competition regime under the DMCC Act has also come into force this year, and the CMA sets out how it will employ the 4P Framework to ensure that it uses the regime “flexibly, proportionately and collaboratively to unlock opportunities for growth across the UK digital economy and the wider economy”.

To read the Plan in full, click here.