The Competition and Markets Authority says vet businesses will be held to account by an independent regulator for the first time. The monitoring plan published alongside the new rules says it will only check a practice when somebody complains.
Estimated reading time: 7 minutes
In short. The Competition and Markets Authority published the Veterinary Services Market Investigation Order 2026 on 22 September, requiring vet practices to publish price lists, cap prescription fees at £21 and give written estimates above £500, after finding average prices up 63% between 2016 and 2023 in a market worth over £6.7 billion a year [3]. The CMA's chair says the remedies mean that "for the first time, LVGs will be held to account by an independent regulator" [3]. That regulator, the Royal College of Veterinary Surgeons, submitted its own monitoring proposal as part of the same package, and its own words say "there will only be reactive monitoring in response to information received and not routine monitoring of practices" [6]. The flagship remedy letting pet owners compare practices has no fixed date either: it depends on the RCVS completing an internal step nobody has to date, with a floor of 22 September 2027 [5]. Three documented mistakes: four stars.
Pet owners spent over £6.7 billion on veterinary and other services in 2024, an average of around £390 per pet-owning household, and average prices rose 63% between 2016 and 2023, far outstripping general inflation [3]. Six large veterinary groups, formed largely by buying up independent practices, now own 60% of vet practices in the UK, and the CMA found that in at least three of five cases, a large group's acquisition of an independent practice was followed by higher prices at that practice [3]. The CMA's own estimate puts the resulting customer detriment at around £1 billion over five years [3]. Around 45,000 pet owners contacted the CMA with concerns during the investigation, most of them about high prices, especially for medicines [3].
The Veterinary Services Market Investigation Order 2026 and the Royal College of Veterinary Surgeons Undertakings 2026, both made under the Enterprise Act 2002 following the CMA's market investigation into veterinary services for household pets [2] and its 24 March 2026 final decision, were published together on GOV.UK on 22 September [1]. The Order requires practices to publish price lists and a parasiticide price list, give written estimates for treatments over £500, itemise bills, cap standard prescription fees at £21, tell owners that medicines may be cheaper online, disclose who owns the practice, and give clearer complaints and mediation routes [4]. Section 167 of the Enterprise Act makes compliance a legal duty, enforceable by the CMA through civil proceedings, and sections 167A and 167B let the CMA impose fixed and daily penalties for breaches without reasonable excuse [4]. None of that is in dispute. The question this teardown tests is whether the compliance machinery built to enforce it matches the scale of the market the CMA itself documented.
"Held to account for the first time," checked only when someone complains
The CMA's chair, introducing the final decision, is explicit about what the remedies are meant to change: "it will be clear to pet owners which vet practices are part of large groups, which are charging higher prices and, for the first time, LVGs will be held to account by an independent regulator" [3]. That regulator is the RCVS, and its role is set out in a monitoring proposal submitted to the CMA and referenced directly in its own undertakings [7].
That proposal describes a system built on two inputs: attestations submitted by the businesses themselves, and spot-checks triggered when someone flags a problem. Paragraph 16 lists where those flags come from: the RCVS's own registration team noticing a missing attestation or fee, its complaints-handling teams, and its routine practice-standards assessments [6]. Paragraph 17 states the consequence in one sentence: "Under this model, there will only be reactive monitoring in response to information received and not routine monitoring of practices" [6]. A practice that files its attestations on time and draws no complaint is not independently checked at all.
The proposal also narrows what the RCVS is expected to decide. Enforcement itself sits with the CMA, not the RCVS, and the RCVS "will be required to refer all potential cases of non-compliance to the CMA," which the document reads as the CMA "not expecting RCVS to apply any judgment about what constitutes a breach" [6]. Even the process for measuring how well any of this is working is unresolved at launch: "the CMA and RCVS will work together to develop an agreed reporting process once the monitoring regime is established and levels/areas of non-compliance are better understood," the same document says, adding only that the CMA has asked for weekly meetings "at least initially" [6]. The reporting method that will show whether the six large groups the CMA singled out are actually complying is a promise to work it out later, not a specification published with the Order.
A comparison website with no date to exist
The other headline remedy is the ability to compare practices directly. The CMA's own summary lists it first among the changes pet owners should expect: "Empowering owners to compare practices by requiring comprehensive price lists, supporting a comparison site and making it clear who owns their practice" [3]. The mechanism is Article 10 of the Order, which requires every practice to submit its basic information, practice information, price list and pet care plan details to the RCVS for publication on the "Find a Vet" platform [5].
The Order's own compliance-date table sets every other remedy against a fixed calendar date: practice information and price lists by 22 December 2026 for large groups, ownership information by 22 March 2027, written estimates by 22 June 2027. Article 10 is the exception. Its compliance date is "3 months from the date on which the RCVS has fully complied with paragraph 4.1 of the Substantive RCVS Undertakings, or 22 September 2027, whichever is later" [5]. Paragraph 4.1 of the undertakings is the obligation it depends on: the RCVS must "set up and maintain a web form" for practices to submit their data, and must tell practices once it has done so, "within 10 days of its doing so" [7]. No date is attached to paragraph 4.1 itself. The comparison site pet owners were told would let them shop around therefore has a floor eighteen months after the CMA's final decision, and no ceiling at all if the RCVS's own web form slips.
The claims, tested
| The CMA's own words | What the evidence shows | Verdict |
|---|---|---|
| "For the first time, LVGs will be held to account by an independent regulator" [3] | The regulator's own accepted monitoring proposal: "there will only be reactive monitoring in response to information received and not routine monitoring of practices" [6] | Accountability depends on someone else reporting the problem first |
| "Empowering owners to compare practices by... supporting a comparison site" [3] | Article 10's compliance date is contingent on an RCVS step (undertakings paragraph 4.1) that itself carries no date, with a floor of 22 September 2027 [5] [7] | The comparison tool has no fixed date to exist |
| The RCVS will monitor compliance across five remedy categories [6] | The reporting process for measuring that compliance "will" be developed later, "once the monitoring regime is established" [6] | The method for judging whether the remedy is working is not yet defined |
The mistakes, counted
The regulator's own monitoring model is reactive, not routine (1). Paragraph 17 of the RCVS's accepted monitoring proposal states plainly that practices are checked only when an attestation is missing or a complaint arrives, not through independent, routine inspection.
The pet-owner comparison website has no fixed date to exist (2). Article 10's compliance date runs from an internal RCVS milestone that itself has no deadline, with a floor eighteen months after the CMA's final decision and no ceiling if that milestone slips.
The reporting process for judging compliance is still to be agreed (3). The monitoring proposal accepted alongside the Order says the CMA and RCVS will develop it "once the monitoring regime is established," after obligations have already started taking effect.
Credit where due
The Order itself is detailed and enforceable where it bites: real compliance dates for price lists, prescription fee caps and written estimates, a statutory duty to comply under section 167 of the Enterprise Act, and civil penalties the CMA can impose directly without going back to court for a fresh order [4]. The RCVS's monitoring proposal is not evasive about its own limits either; paragraph 17's admission that monitoring will be reactive is stated plainly, not buried, and the document sets out in detail how fee non-payment converts into a debt the RCVS can pursue in court [6]. The CMA has also given smaller independent practices longer to comply than the six large groups its own evidence concentrates on, a proportionate distinction the Order draws consistently across every Part [5].
Verdict
Four stars, from three documented mistakes. The CMA built a real, enforceable Order on top of an investigation that took evidence from tens of thousands of pet owners and vets, in a market it valued at £6.7 billion a year with prices rising far faster than inflation. What the same package does not yet have is a monitoring system that checks practices before something goes wrong, a comparison website with a date it has to exist, or an agreed way of measuring whether any of it is working. The rules on what a vet practice must publish are precise. The rules on how anyone will know whether they did are not.
Sources
- GOV.UK, "Veterinary Services Market Investigation Order 2026 and Veterinary Services Market Investigation Royal College of Veterinary Surgeons Undertakings 2026" (Competition and Markets Authority, published 22 September 2026, checked 23 September 2026). https://www.gov.uk/government/publications/veterinary-services-market-investigation-order-2026-and-veterinary-services-market-investigation-royal-college-of-veterinary-surgeons-undertakings-202
- GOV.UK, "Veterinary services for household pets" (CMA case page, checked 23 September 2026). https://www.gov.uk/cma-cases/veterinary-services-market-for-pets-review
- Competition and Markets Authority, "Summary of final report" (Veterinary services for household pets market investigation, 24 March 2026). https://assets.publishing.service.gov.uk/media/69c22ac8d588c92c483e4c01/Summary_of_final_report_24.3.26.pdf
- Competition and Markets Authority, "Explanatory note to the Order" (Veterinary Services Market Investigation Order 2026, PDF). https://assets.publishing.service.gov.uk/media/6ab14876d52ca1fccea560af/explanatory_note__2_.pdf
- Competition and Markets Authority, "Veterinary Services Market Investigation Order 2026" (PDF, made 22 September 2026). https://assets.publishing.service.gov.uk/media/6ab237c14c0f475de0a66b27/__Veterinary_Services_Market_Investigation_Order_2026__.pdf
- Royal College of Veterinary Surgeons, "RCVS submission of monitoring proposal for the compliance of veterinary businesses with the CMA substantive order" (PDF). https://assets.publishing.service.gov.uk/media/6ab14267d52ca1fccea560a8/rcvs_monitoring_proposal.pdf
- Competition and Markets Authority, "The Veterinary Services Market Investigation Royal College of Veterinary Surgeons Undertakings 2026" (PDF, 21 September 2026). https://assets.publishing.service.gov.uk/media/6ab156774c0f475de0a66b08/Veterinary_Services_Market_Investigation_Royal_College_of_Veterinary_Surgeons_Undertakings_2026.pdf