No Order exists yet, and the compliance dates in the draft are still blank

The remedies from the CMA's veterinary market investigation are real, detailed and drafted. What does not yet exist is a single date on which your practice has to do any of it. Every compliance date in the draft Order is left open — the text reads, literally, "9 months [X June 2027]". The nine months is real. The date inside the brackets is not yet a date.

That reads like a reason to wait, and it is the opposite. You now know with a high degree of certainty what is coming and in what order. What you do not know is when the clock starts. Those two facts together point at a particular way of preparing, and at one obligation worth looking at this month whatever happens next.

What has actually happened

The CMA made a market investigation reference on 23 May 2024 under sections 131 and 133 of the Enterprise Act 2002, and appointed an inquiry group of five. A provisional decision followed on 15 October 2025, final comments closed on 30 January 2026, and the final report was published on 24 March 2026. That report ended the investigation. It found adverse effects on competition in two markets: the retail supply of veterinary services for household pets by first opinion practices, and the supply of outsourced out-of-hours provision to those practices.

The CMA then has six months to put an Order in place, which is where 23 September 2026 comes from. Paragraph 142 of the final report says so in terms: the next stage is to put an Order in place enacting the remedies and to accept Undertakings from the RCVS, and the CMA has six months to do it. That date is the CMA's own deadline for finishing the drafting. It is not a date on which anything is required of your practice.

The draft Veterinary Services Market Investigation Order 2026 was published for consultation on 21 July 2026, alongside draft Substantive Undertakings from the RCVS. Responses close on 20 August 2026 at 23:59. A separate draft Funding Order and draft Funding Undertakings went out on 30 June 2026 and closed on 30 July 2026.

What has not happened

No Order has been made. Article 1(2) of the draft provides that the Order comes into force the day after it is made, so until that day nothing in it binds anyone. Article 1(3) confirms that it will extend to England and Wales, Scotland and Northern Ireland — this is a UK-wide instrument, not an England-and-Wales one.

The CMA has also been explicit about what the current consultation is and is not. It is not consulting on the inquiry group's decisions in the final report. It is asking whether the drafting carries those decisions faithfully into legal language. So the substance is settled; the commencement dates and the exact wording are not.

The one obligation that starts on day one

Paragraph 143 of the final report sets out the structure plainly. The first of the remedies comes into force from the date the Order is in place, and the others are implemented "from three to 12 months from that date". Footnote 31 adds that those periods sit on top of the period of up to six months between the final decision and the Order — which is why nobody can honestly publish a calendar date today.

The first remedy is the out-of-hours one. Draft Article 19 restricts the terms on which outsourced out-of-hours provision is contracted: notice periods capped at a maximum of 12 months and termination fees restricted. Those provisions bite on the day the Order is made, with no lead-in and no distinction between a large and a small business. A related duty on out-of-hours providers to inform first opinion practices follows three months later.

This is the part with a consequence today, because it concerns contracts already signed. If your practice is tied into an out-of-hours arrangement with a notice period longer than 12 months, or with an exit fee, that arrangement sits squarely inside the first thing the Order does. Precisely how a restriction of that kind lands on an existing contract is a question for a lawyer with the contract in front of them. The planning point is simpler: it lands first, and it lands without a runway. A renewal conversation is better had with draft Article 19 open than after it.

Two staging points, not five, if you are a small veterinary business

The draft 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. On the CMA's own figures 76% of veterinary businesses have only one first opinion practice, so essentially every independent practice in the country is small for this purpose.

Article 3(1) sets the lead-in for each remedy in months, with obligations biting from the next working day after the stipulated dates. Expressed in months from the Order rather than in the square-bracketed blanks the draft carries, the shape is this.

Read down the two right-hand columns and the useful point falls out. A large group has five separate staging points to manage. A small business has effectively two: a six-month block and a twelve-month block. That is a much easier programme to run, and it is worth knowing before anyone buys a compliance product built around a large group's timetable.

One caution on a line that has been widely repeated. The CMA's news release says that for most of the remedies smaller businesses get three months longer, and that is true of most of them. It is not uniform. On the prescription fee cap the gap is six months against twelve, so six months longer rather than three. On ownership information and on the whole complaints package there is no gap at all.

An illustrative sequence for a three-site independent

Take an independent with a main practice and two branches, no out-of-hours centre of its own, and an outsourced out-of-hours contract. Three first opinion practices, so a Small Veterinary Business. This is illustrative and deliberately expressed in months from the Order rather than in dates.

• Day one. The out-of-hours contract restrictions apply. Nothing else does.
• By month six. The transparency and governance block, all at once: ownership information on signage, premises, websites and communications; practice information including the out-of-hours provider and staff qualifications; the full standard price list; the parasiticide price list; pet care plan information; a written policy ensuring clinicians can act in line with the RCVS Codes; cremation options with a basic communal option offered and priced; and the complaints package — an in-house process, a complaint log, and mediation in good faith once that process is exhausted.
• By month twelve. Written estimates where the recommended treatment pathway is reasonably likely to cost £500 or more including VAT; itemised bills; the prescription fee cap; written prescriptions as hard copy by the end of the consultation or digitally within 48 hours; pet-owner awareness of the right to a written prescription; the standard flyer for ongoing medication; own-brand medication disclosure; and data to the RCVS for Find a Vet.

Two workstreams, then, and they are not the same kind of work. The month-six block is largely writing things down and publishing them, which a practice manager can own. The month-twelve block changes how a consultation ends and how a bill is produced, which touches the practice management system, the price list behind it, and what every clinician says in the last two minutes of an appointment. That is the harder half, and it carries the longer runway for a reason.

What certainty about the "what" is actually worth

Quite a lot, if you use it on the pieces that take months rather than weeks.

• The price list is the long job. Article 7 requires a comprehensive standard list covering consultations, preventative care, prescriptions and dispensing, operations, treatments, diagnostics and lab tests and end-of-life care, priced by weight band: cat or small dog under 10kg; medium dog 10-25kg; large dog over 25 to 40kg; extra-large over 40 to 60kg; giant over 60kg. Most practices do not currently hold their prices in that shape. Building it early is not a compliance risk — the CMA found that 84% of the practice websites it reviewed carried no pricing information at all, so this is a competitive move as much as a legal one.
• The estimate threshold is settled in the draft. Article 2 defines the Initial Monetary Threshold as £500 including VAT, and the CMA's guidance requires the estimate to be updated in writing whenever the cost is likely to rise by 20% or £500, whichever is lower. Emergencies are the only exception. That is a workflow you can design and test now.
• The complaints numbers are specific. Article 21 requires written acknowledgement within five working days, a full response within eight weeks, the process published, and the RCVS decision tree displayed. Article 22 requires a log. Article 23 requires good-faith mediation once the in-house process is exhausted, with the RCVS contracting an alternative dispute resolution provider, anticipated to be the Veterinary Client Mediation Service.
• The cost is estimable. On the CMA's own estimate the RCVS's new role will cost no more than £150 to £250 per practice in initial set-up and £450 to £550 annually per practice thereafter, recovered through a levy that depends on the number of first opinion practices you own. That sits alongside the £38 per premises annual Register of Veterinary Practice Premises fee, which is charged per site including branches.
• The smallest businesses escape one thing. Paragraph 130 of the final report confirms the CMA is not requiring the smallest businesses — which it puts at 70% of all veterinary businesses — to give an annual attestation to the RCVS. They still have to meet the requirements of the Order; they just do not have to certify it annually.

Where to start if you want to start

Look at the out-of-hours contract first, because it is the only thing with no lead-in. Then build the price list, because it is the longest job and the one with an immediate commercial upside. Then design the estimate and itemised-bill workflow, because those are the ones that change clinical behaviour rather than a website.

The full remedy-by-remedy detail is in our guide to the CMA remedies, and the pricing mechanics — weight bands, plan components, what a published list does to your margin — are in the practice pricing guide. If you want help turning the sequence into a plan on your own figures, that is what CMA compliance and pricing is for. The prescription fee cap has its own complication, which is that the figure is not yet the figure.