The CMA remedies, turned into a work programme

Fifteen practices is the line, and the three-month rule is not uniform

Draft Article 2 defines a Large Veterinary Business as one with 15 or more first opinion practices and/or out-of-hours centres, and a Small Veterinary Business as one with fewer than 15. There is no revenue test and no headcount test. It is a count of premises.

Since 76% of veterinary businesses own just one first opinion practice, and the next largest business after the six groups owns 38, essentially every independent practice in the country is Small. The CMA's news release says that for most of the remedies smaller businesses get three months longer than larger ones — and that is true for most, but repeating it as a general rule will mislead you on the three that matter.

Read that table for the exceptions rather than the pattern. On the prescription fee cap the gap is six months against twelve, so an independent gets double the lead time, not three months more. On ownership information and on the entire complaints package — the process, the logs and mediation — there is no gap at all. Both obligations bite at six months for everyone, which makes the complaints work the earliest hard deadline most independent practices face.

Draft Article 3(1) adds a small mechanical point worth knowing: the obligations bite from the next working day after the stipulated date, and Article 3 is where the compliance table lives.

The remedies that change what happens in the consulting room

Written estimates — draft Article 11

A written estimate of the cost of the recommended treatment pathway is required wherever that cost is reasonably likely to be £500 or more including VAT. Draft Article 2 calls that the Initial Monetary Threshold and, unlike the prescription fee figures, £500 is not bracketed — it is a settled number in the draft. The estimate must then be updated in writing whenever the cost is likely to increase by 20% or £500, whichever is lower. Emergencies are the only exception.

Take the arithmetic seriously, because the lower-of test bites in the opposite direction to intuition. On a £600 estimate, 20% is £120 and £500 is £500, so the trigger is £120. On a £4,000 estimate, 20% is £800 and the trigger is £500. The smaller the estimate, the tighter the tolerance — which makes this a system requirement rather than a policy one. Something has to prompt a clinician mid-case, and that something is your practice management system, not a laminated card.

Itemised bills — draft Article 12

Bills must identify the components of the veterinary services provided: individual medicinal products, the goods and services supplied, and charges for outside services. If your invoices currently show a single line for a procedure with drugs absorbed into it, that changes.

Written prescriptions — draft Articles 14, 15, 16 and 18

Four separate obligations sit on written prescriptions. Article 14 requires you to make pet owners aware that a written prescription is available. Article 15 requires you to provide one — as a hard copy by the end of the consultation, or digitally within 48 hours. Article 16 requires a standard flyer to be given where an animal is on ongoing medication. And Article 18 caps what you may charge for the prescription itself.

On the cap: the final report set a maximum of £21 including VAT for the first medicine prescribed within a consultation and £12.50 including VAT for each additional medicine in the same consultation, with annual inflation adjustment. Neither figure is yet the legal figure. Draft Article 2 puts both inside square brackets, to be adjusted for inflation between 24 March 2026 and the latest monthly CPI figure available before the Order is made. So the binding number will be higher than £21, and how much higher is not knowable today. The cap applies to all veterinary businesses providing first opinion services, including out-of-hours premises.

For context on the size of the change: the final report records current prescription charges starting at around £10 at the lowest, and says significant numbers of first opinion practices charge over £30, some considerably more. A practice at £35 is looking at a cut of well over a third on that line, plus the volume effect of Articles 14 to 16 actively telling clients the option exists.

Own-brand disclosure — draft Article 17

Where a practice dispenses its own-brand medication, that has to be disclosed. Straightforward to implement, and awkward for anyone whose pricing has relied on the client not knowing.

Out-of-hours contracts change on the day the Order is made

Everything above gives you months. This does not. Draft Article 19(4) and 19(5)(a) to (b) take effect the day the Order is made: notice periods in outsourced out-of-hours contracts are capped at twelve months, and termination fees are restricted. Article 19(5)(c) then requires out-of-hours providers to inform practices, three months in for everyone.

This exists because the CMA found an adverse effect on competition in two markets, not one. The second was the supply of outsourced out-of-hours provision to first opinion practices across the UK — and long notice periods with punitive exit fees were part of why that market did not work. Two of the six large groups, CVS and IVC, own dedicated out-of-hours businesses.

So the practical action for a practice principal is short and it is available today: find your out-of-hours agreement, read what it says about notice and about termination fees, and know whether you are inside a term that will be cut down or one that already complies. If you have been quietly unhappy with the arrangement, the terms you are held to are about to change in your favour, and knowing that before you have the conversation is worth something.

The remedies that were considered and rejected

This is as useful as the list of what was imposed, because it tells you what is not coming and stops you planning for it. Paragraphs 134 to 141 of the final report record that the CMA is not pursuing:

• Divestments. In terms: it is not pursuing divestments of businesses or parts of businesses.
• A cap on corporate ownership. The CMA did not consider it effective or proportionate to reduce or cap the level of practice ownership by large veterinary groups.
• General price control. The written prescription fee is the sole exception. Consultation fees, treatment prices and medicine mark-ups are not capped.
• A profit cap. Measures to cap the profitability of businesses were judged disproportionate.
• Forced divestment of online pharmacies, referral centres, crematoria or laboratories.

Two other pieces of lighter-touch treatment are worth knowing. The smallest businesses — which the final report at paragraph 130 says constitute 70% of all veterinary businesses — are not required to provide an annual attestation to the RCVS, though they must still meet the requirements of the Order. And the CMA's guidance states the remedies will not apply to organisations providing small animal veterinary services on a not-for-profit basis, on the reasoning that they do not compete with commercial veterinary businesses. That exclusion appears in the guidance rather than on the face of the draft Order text, which is worth holding lightly until the Order is made.

What it will cost to run

The RCVS takes on compliance monitoring, funded by a new levy on veterinary businesses scaled to the number of first opinion practices you own. On the CMA's current estimate that is no more than £150 to £250 per practice for the RCVS's initial set-up costs and £450 to £550 a year per practice for its ongoing costs. The levy detail sat in a separate Funding Order consultation, which closed on 30 July 2026.

Against that, budget the real cost, which is not the levy. It is the time to build and maintain four price lists, to configure your practice management system for estimate thresholds and itemised billing, and to run a complaint process with a log and an eight-week response standard. That is a process project with an accounting consequence, and the accounting consequence is what we work on.

Where to go next

The full guide to the CMA remedies goes through the draft Order article by article. The practice pricing guide is about setting a price you can publish. If your interest in this is what it does to the value of the business, selling a veterinary practice covers the consolidation numbers and what drives a practice's value sets out what a buyer examines.

And if you are a locum rather than a principal, the short answer is that the Order does not apply to you personally — it applies to veterinary businesses. Locum vet accounts covers what does.