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The Dog That Barks: The UK’s CMA is proposing major reforms to Veterinary Businesses

By John Schmidt, Zeno J. Frediani & George Zografos on October 17, 2025
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Table of Contents

  • What are the key findings?
  • What are the proposed remedies?
  • What does this mean for veterinary and other businesses in the healthcare space?
  • What happens next?

Following a two year investigation, the UK’s Competition and Markets Authority (“CMA”) has issued its provisional findings in which it proposes to impose significant obligations on veterinary business.

Link to What are the key findings? What are the key findings?

  • The CMA’s core concerns centred around rising costs, limited transparency, and rapid consolidation. Average prices rose by 63% between 2016 and 2023, and over 60% of practices are presently owned by six large veterinary groups.
  • The CMA also found the applicable regulatory framework to be outdated and ineffective in overseeing veterinary businesses as it focuses on the regulation of individual practices rather than entities operating large veterinary businesses.

Link to What are the proposed remedies? What are the proposed remedies?

The remedies in the CMA’s notice of provisional findings are primarily geared towards the entities operating veterinary practices  and propose the following transparency requirements:

  • publication of comprehensive price lists for services, medication, and end-of-life treatments,
  • clearer, granulised cost estimates for treatments, with significant increases to be notified to pet owners on an ongoing basis,
  • price breakdowns for pet care plans,
  • mandatory disclosure of ownership, and
  • improved access to prescriptions.

Moreover, the CMA is seeking to impose minimum contractual or regulatory obligations to which veterinary practices need to adhere. In particular:

  • a price cap on prescriptions,
  • a requirement for practices to have policies that ensure that the vets and the nurses can provide independent advice and treatment options and that safeguard against potential conflicts of interest between the practice management and the most appropriate treatment options for the consumer,
  • obligations to facilitate consumers obtaining (cheaper) medicines online or from third parties,
  • prohibiting certain restrictive terms in contracts between first opinion practices and clinics that handle out-of-hours emergencies, and
  •  instituting complaints procedures and engaging in mediation to resolve complaints that have been escalated.

The CMA envisages the Royal College of Veterinary Surgeons (“RCVS”),  playing a central role in implementation including by enriching its national “Find a Vet” platform with “key practice information” that operators will be obligated to provide to it. The RCVS will also be required to conduct biennial satisfaction surveys comparing large veterinary groups to independent practices, and produce updated and fit-for-purpose guidance materials while also tracking and publishing complaints data. 

Finally, the CMA also recommends that relevant governments establish a new statutory regulatory framework to ensure effective oversight of veterinary businesses, promote competition, and better protect pet owners.

Link to What does this mean for veterinary and other businesses in the healthcare space? What does this mean for veterinary and other businesses in the healthcare space?

Once the remedies become final, veterinary practices will need to revise their practices, policies and documentation to comply with the remedies, with larger veterinary businesses generally being given shorter compliance timelines.

In its report,  the CMA has expressed particular concern over the consolidation of veterinary practices by large corporate groups and private equity investors. The CMA believes that such acquisitions have often led to higher prices without clear improvements in the quality of the practices’ offerings. This means that future acquisitions of vet practices may well face more detailed and possibly more critical CMA scrutiny.

Finally, it would not be surprising if other areas which are seeing significant consolidation and private equity investments such as care homes or pre-school nursing were to receive increased regulatory attention, be it under the CMA’s merger review or general powers.

Link to What happens next? What happens next?

The findings and proposed remedies are not yet final. The CMA is consulting on these and interested parties can submit responses via the consultation portal or by email to VetsMI@cma.gov.uk by 12 November 2025. The CMA’s final report is expected to be published in February/March 2026 ahead of the statutory deadline of 22 May 2026.

Photo of Zeno J. Frediani Zeno J. Frediani
Read more about Zeno J. FredianiEmail
  • Posted in:
    Antitrust, Competition and Trade
  • Blog:
    BioSlice Blog
  • Organization:
    Arnold & Porter Kaye Scholer LLP
  • Article: View Original Source

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