The CMA veterinary remedies: what was decided, and when each one bites

Three dates, and only one of them means anything to your practice

Almost every piece of reporting on this investigation compresses three separate events into one deadline. Separating them is the whole job, because the difference decides what you should be doing now and what you should not.

• 24 March 2026 — the final report. The Competition and Markets Authority published its final decision on the market for veterinary services for household pets. The investigation ended there. No obligation started.
• 23 September 2026 — the deadline for the CMA to make its Order. The report gives the CMA six months to put a binding Order on businesses in place and to accept Undertakings from the RCVS. In its own words: it has six months to do this, so it must be completed by 23 September 2026. That is the CMA's deadline for finishing the drafting. Nothing in your practice has to be different on that day.
• Three to twelve months after the Order is made — when the remedies actually apply. The final report is explicit: the first remedy comes into force from the date the Order is in place, and the others are implemented from three to twelve months from that date.

As at the review date on this guide, no Order exists. The draft Veterinary Services Market Investigation Order 2026 was published for consultation on 21 July 2026 and that consultation closes on 20 August 2026. The CMA has said it is not consulting on the inquiry group's decisions in the final report — only on whether the drafting matches them. So the substance below is settled. The calendar is not.

How unsettled is the calendar? Every compliance date in the draft is written as a month count with an empty date beside it, literally in the form “9 months [X June 2027]”. The month names in the gov.uk guidance are indicative and assume the Order is made in September 2026. That is why every entry in the table below is expressed in months from the Order and not as a date. Article 1(2) of the draft says the Order comes into force the day after it is made, and Article 3(1) says obligations bite from the next working day after the stipulated dates.

The one obligation with no lead time: out-of-hours contracts

If you take anything practical from this guide, take this. Under draft Article 19(4) and 19(5)(a)–(b), the restrictions on out-of-hours contracts apply from the day the Order is made, for large and small businesses alike. Notice periods in those contracts are capped at a maximum of 12 months, and termination fees are restricted. Article 19(5)(c), which requires out-of-hours providers to inform the first opinion practices they serve, follows three months later for everyone.

Every other remedy has a run-in of at least three months. This one does not. If your practice is tied into an out-of-hours arrangement with a long notice period or an exit fee, the contract is worth reading before the Order is made rather than afterwards, because the terms you are looking at are the ones the Order will reach into. That is a commercial review as much as a legal one, and the cost of out-of-hours cover is usually one of the larger single lines in a small practice's overheads.

The full remedy table, in months from the Order

The CMA's news release says that for most of the remedies smaller veterinary businesses will have three months longer than larger ones. Read the table rather than the sentence, because it is not uniform and the exceptions are the expensive ones:

• on the prescription fee caps the gap is six months against twelve, not three against six;
• on ownership information there is no gap at all — six months for everyone;
• on the whole complaints package, Articles 21 to 23, there is no gap at all — six months for everyone;
• on out-of-hours notice periods there is no gap and no run-in.

The four publication duties

These are the remedies that turn your pricing into a document. The CMA's own baseline explains why it went this far: of the first opinion practice websites it reviewed, 84% had no pricing information at all.

Article 7 — the standard price list

A comprehensive list covering consultations, preventative care, prescriptions and dispensing, surgical procedures, treatments, diagnostics and laboratory tests, and end-of-life care. It has to be priced by five weight bands: cat or small dog under 10kg; medium dog 10–25kg; large dog over 25kg to 40kg; extra-large over 40kg to 60kg; and giant over 60kg. That structure is the part practices underestimate — a single consultation fee becomes five published figures, and every procedure on the list has to be capable of being quoted the same way.

Article 8 — the parasiticide price list

Prices for commonly sold flea, tick and worming products, where “commonly sold” means products of which 100 units or more were sold in the previous twelve months. If fewer than ten products meet that threshold, you publish your top ten instead. The list has to carry a link to the VMD's Register of Online Retailers, which is the part that makes it uncomfortable: you are publishing your price next to a route to a cheaper one. The RCVS said as much in its response of 24 March 2026, raising a concern about focusing solely on cost rather than on suitability, the environment and public health.

Article 9 — pet care plan information

For every plan you sell: the services included and how often each is provided, the standalone price of each of those services, the savings methodology, the monthly and annual rates, and the cancellation terms. This is the disclosure with the biggest commercial consequence, because once each component is priced publicly the plan's economics are visible to anyone who can subtract. Our guide to pricing a practice works through what that does to plan design.

Article 6 — practice information

Who provides your out-of-hours cover, the qualifications of your staff and their RCVS accreditations, and any Practice Standards Scheme awards the practice holds. Article 5, separately, requires ownership information on signage, at the premises, on websites and in communications — the remedy aimed at the finding that only a minority of large-group customers knew their practice was part of a group.

Estimates, bills and clinical freedom

Three obligations change the paperwork around a consultation.

Written estimates (Article 11). Where the recommended treatment pathway is reasonably likely to cost £500 or more including VAT, you must give a written estimate. That figure is defined in Article 2 of the draft as the Initial Monetary Threshold and it is not in square brackets, so unlike the prescription fee it can be relied on. The estimate must be updated in writing whenever the cost is likely to increase by 20% or £500, whichever is lower. Emergencies are the only exception.

Itemised bills (Article 12). The bill must identify the components of what was provided: individual medicinal products, individual goods and services, and charges for outside services. A single line reading “treatment” will not do it.

Clinical freedom policies (Article 13). A written policy ensuring that veterinary surgeons and veterinary nurses can act in accordance with their RCVS Codes of Professional Conduct. This is the remedy that responds to the structural point the CMA made about regulation reaching the professional but not the business — covered in our RCVS compliance guide.

Prescriptions: the fee, the flyer, the own brand

Four separate remedies sit here, and only one of them is a price control.

Article 18 — the fee caps. The final report set a maximum for providing a written prescription at £21 including VAT for the first medication prescribed in a consultation, and £12.50 including VAT for each additional medicine in the same consultation, with annual inflation adjustment after that. Those are the final-report figures and they are not the binding numbers. In the draft Order both appear in square brackets, to be adjusted for inflation between the date of the final report and the latest monthly CPI figure available before the Order is made, and indexed annually thereafter. So the legal cap will be a little higher than £21, and nobody yet knows by how much. For context, the CMA found current charges start at around £10 and that significant numbers of practices charge over £30, some considerably more. Our prescription fee modeller lets you put your own volumes and your own charge against a figure you can change.

Article 15 — providing the prescription. A hard copy by the end of the consultation, or a digital prescription within 48 hours.

Articles 14 and 16 — awareness and the flyer. Pet owners must be made aware they can ask for a written prescription, and a standard flyer must be provided where an animal is put on ongoing medication.

Article 17 — own-brand disclosure. Where a practice dispenses its own-brand medication, it must say so.

End of life, and complaints

Article 20 — cremation. Options and prices must be set out, and a basic communal cremation option must be offered. In practice that means the crematorium arrangements and the margin on them become visible alongside everything else on the price list.

Articles 21 to 23 — the complaints package. Six months for every business, whatever its size:

• an in-house complaint process that acknowledges a complaint in writing within five working days and gives a full response within eight weeks;
• the process itself published, and the RCVS decision tree displayed;
• a complaint log kept;
• participation in mediation in good faith once the in-house process is exhausted. The RCVS is to contract an alternative dispute resolution provider, and the CMA anticipates that this will be the Veterinary Client Mediation Service.

Article 10 — Find a Vet. Practices must submit data to the RCVS for its Find a Vet service. This is the one deadline in the table that is not a straight month count: three months after the RCVS complies with paragraph 4.1 of its Undertakings, or twelve months from the Order, whichever falls later.

What the CMA decided not to do

This matters as much as the remedies, because a good deal of what practice owners feared did not happen. Paragraphs 134 to 141 of the final report rule out:

• divestments — the CMA states it is not pursuing divestments of businesses or parts of them;
• a cap on the level of corporate ownership — it did not consider that reducing or capping large-group ownership of practices would be effective or proportionate;
• general price control — the written prescription fee is the single exception;
• a profit cap — measures to cap the profitability of businesses were judged disproportionate;
• forced divestment of online pharmacies, referral centres, crematoria or laboratories.

Separately, the CMA created no new merger notification duty. UK merger notification remains voluntary. But paragraph 136 says in terms that the CMA will continue actively monitoring merger activity in the veterinary sector, and footnote 13 notes it may use share of full-time-equivalent vets in specific local areas, as it has in previous veterinary merger cases. If you are contemplating a sale in a concentrated town, that is the sentence to know about — our practice sale service starts from it.

What the regime costs, and who escapes part of it

The RCVS takes on compliance monitoring, funded by a new levy on veterinary businesses that depends on the number of first opinion practices you own. The CMA's own estimate, from its news release, 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.

Two carve-outs are worth knowing:

• The smallest businesses escape the annual attestation. Final report paragraph 130 says the CMA is not requiring the smallest businesses — which it puts at 70% of all veterinary businesses — to provide an annual attestation to the RCVS. They still have to meet the relevant requirements of the Order. This is a reporting exemption, not a compliance exemption, and the distinction is easy to misread in your favour.
• Charitable providers are out. The CMA's guidance says the remedies will not apply to charitable organisations providing small animal veterinary services, on the basis that they do not generally offer services available to all pet owners and so do not compete with commercial veterinary businesses. Note where that exclusion lives: it is in the published guidance rather than in the text of the draft Order, so a not-for-profit provider should watch the final Order for it.

What is worth doing while the Order is being written

• Read the out-of-hours contract. It is the only thing here with no run-in.
• Work out whether you are large or small. Fifteen or more first opinion practices and/or out-of-hours centres, counted across the business, not per site.
• Price the five weight bands now, on paper. Not to publish, but to find out what your consultation and procedure fees actually look like when they have to be stated as five numbers each.
• Model the prescription fee. Take your written prescription volume and your current charge, and see what a cap somewhere above £21 does to the annual figure.
• Decompose your pet care plans. If publishing the standalone price of each component changes the answer a client gets, better to know before Article 9 makes it public.
• Draft the complaints process and start the log. Six months, no size relief, and it costs almost nothing to have in place early.