CMA Chair Pledges Stable Regulation, Faster Merger Reviews, and Targeted Enforcement in Keynote

Key Takeaways

• CMA Chair Doug Gurr used a keynote speech to reaffirm three commitments: a stable and predictable regulatory regime, continued process improvement through the "4Ps" (pace, predictability, proportionality, and process), and greater transparency.
• The speech is not new binding regulation.
• It signals that merger control, digital markets, and consumer protection enforcement will remain active but targeted, so compliance teams should align engagement and controls with these priorities.

Deep Dive

CMA Chair Doug Gurr used a keynote speech to reaffirm three commitments: a stable and predictable regulatory regime, continued process improvement through the "4Ps" (pace, predictability, proportionality, and process), and greater transparency. The speech is not new binding regulation. It signals that merger control, digital markets, and consumer protection enforcement will remain active but targeted, so compliance teams should align engagement and controls with these priorities.

Key points by regime:
- Mergers: The substantial lessening of competition test is unchanged. The CMA reviewed 32 cases last year (a historically low number): 24 cleared unconditionally, 5 cleared with remedies, 1 found not to qualify, and 2 prohibited. The mergers charter KPIs are reducing pre-notification periods and speeding up clearances. The CMA stated that any deal capable of being cleared should be, unconditionally or with effective remedies. It encourages parties to table evidence-based remedies early and to review its updated guidance on rivalry-enhancing efficiencies. Market definition remains a key issue, with openness to global markets in some cases.
- Digital markets: The CMA cited 3 strategic market status designations, changes to Google and Apple mobile ecosystems, a Google Search requirement letting publishers opt out of AI use of their content, voluntary cloud commitments from Amazon and Microsoft, and a new investigation into Microsoft's business software ecosystem. It will use both conduct requirements and commitments.
- Consumer protection: Since the new direct enforcement powers took effect, the CMA has opened investigations into 20 businesses, issued fines totaling millions of pounds, and secured hundreds of thousands of pounds in refunds. It recently launched 3 drip pricing investigations. Other areas of focus include ticketing, gyms, driving schools, online reviews, and air travel, with priority on essential spend and vulnerable consumers.
- Public procurement: Two reports were published last week on procurement in the national interest and on bid-rigging. UK government procurement is about GBP $400 Billion annually, and bid-rigging may cause overpayment of up to GBP $3.5 Billion a year. Expect heightened scrutiny of collusive tendering.

No compliance deadlines were set. Relevant reference points are the 2025 strategy, the July 2026 stakeholder survey (83% rated interactions as "good"), and annual reports that will track 4Ps progress. Compliance teams should:
- Review merger notification and pre-notification processes against the mergers charter KPIs, and prepare remedy proposals and efficiency arguments early.
- Assess drip pricing, fee transparency, review practices, and cancellation and refund processes against consumer law, especially in essential-spend sectors.
- Review bid-rigging controls, including procurement training, tender monitoring, and escalation and leniency protocols.
- Monitor SMS-related conduct requirements and commitments if the firm is a designated entity or a dependent business.
- Engage with the CMA through consultations and stakeholder forums.

Predictability does not mean leniency. The CMA states that outcomes are not guaranteed and that it will act against anti-competitive conduct and consumer law breaches. Likely exposure is greatest for consumer pricing practices, collusive bidding, and digital platform conduct. Merger risk is lower for transactions with no substantive overlaps, but parties with real concerns face rigorous, evidence-led review. Firms that proactively cooperate and remediate may benefit from faster resolution through commitments rather than formal proceedings.

Source: Competition and Markets Authority