Your prices are about to stop being a conversation at the front desk and start being a document on your website, priced across five weight bands, with your pet care plan broken into its component parts. That changes how you should set them, not just how you display them.
Guide · Updated August 2026
The CMA found that, of the first opinion practice websites it reviewed, 84% carried no pricing information at all. Its remedies close that off. Once the Order is in place and the relevant run-in has passed, a veterinary business must publish a comprehensive standard price list, a parasiticide price list, full pet care plan information and practice information — and must give a written estimate wherever the recommended treatment is reasonably likely to cost £500 or more including VAT, backed by an itemised bill at the end.
None of that is in force yet. The final report is dated 24 March 2026, the CMA must make its Order by 23 September 2026, and the obligations land three to twelve months after that depending on the remedy and whether the business has 15 or more first opinion practices. The full sequence is in our CMA remedies guide. What follows is about the pricing work itself, which takes considerably longer than the publication.
Draft Article 7 requires the standard price list to be priced by weight band:
| Band | Weight |
|---|---|
| Cat or small dog | Under 10kg |
| Medium dog | 10kg to 25kg |
| Large dog | Over 25kg to 40kg |
| Extra-large | Over 40kg to 60kg |
| Giant | Over 60kg |
The list has to cover consultations, preventative care, prescriptions and dispensing, surgical procedures, treatments, diagnostics and laboratory tests, and end-of-life care. Multiply that scope by five bands and you have a document with several hundred cells in it, every one of which is a commitment.
Three practical consequences follow, and they are the reason to start early:
Draft Article 8 requires 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. Where 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.
That link is the whole point of the remedy, and it should shape how the list is built. The CMA found that pet owners could save £200 to £300 a year on average by buying commonly prescribed medicines from an online pharmacy rather than from a first opinion practice, and that online pharmacy prices are 50% to 60% below practice prices for some products. Publishing your parasiticide prices next to a route to that comparison is a repricing decision, not a formatting one. The realistic responses are to compete on price where you can, to be explicit about what the in-practice price includes that a posted box does not, or to accept the volume shift and rebuild the margin elsewhere. Deciding which, before the list is published, is the work.
Draft Article 9 requires, for every plan:
This is the most commercially exposing of the four publication duties. A plan is normally sold on a headline saving. Once every component carries a published standalone price and the savings methodology is published with it, the saving becomes arithmetic anyone can check — and so does its absence.
Illustrative example — a plan under Article 9 disclosure. A plan at £22 a month is £264 a year (22 × 12).
Its components, at the practice's own standalone prices: annual vaccination £62; two health checks a year at £48 each, so £96; and twelve months of flea and worm cover at £15 a month, so £180. Standalone total: 62 + 96 + 180 = £338.
The saving is 338 − 264 = £74 a year, which is 74 ÷ 338 = 21.9% of the standalone cost. That is the number the practice can publish, and the methodology behind it is simply the sum above.
Now change one thing. If the flea and worm element is repriced to £11 a month to compete with online pharmacies, the standalone total becomes 62 + 96 + 132 = £290, and the same £264 plan saves 290 − 264 = £26, or 9.0% (26 ÷ 290). The plan has not changed; the published saving has fallen by two thirds. That interaction between the parasiticide list and the plan disclosure is the thing to model before either is published. Figures are illustrative.
One open question deserves flagging rather than answering. We could not find HMRC guidance on the VAT treatment of pet care plans — whether a plan is a single standard-rated supply, a mixed supply, or contains an element that raises insurance premium tax questions. It is a real and material point given that plan components are about to be priced publicly, and it needs specific advice on your own plan terms rather than a general answer.
Draft Article 11 requires a written estimate of the cost of the recommended treatment pathway where it is reasonably likely to be £500 or more including VAT. That threshold is defined in Article 2 of the draft as the Initial Monetary Threshold and, unlike the prescription fee figures, it is not bracketed — so 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.
Illustrative example — where the update trigger actually falls. The trigger is the lower of 20% and £500, so the two tests swap over at the point where 20% equals £500 — that is, at an estimate of £2,500, because 2,500 × 20% = 500.
Below £2,500 the percentage governs. On a £700 estimate, 20% is £140, which is lower than £500, so a rewritten estimate is due once the likely cost reaches £840.
Above £2,500 the £500 governs. On a £4,000 estimate, 20% is £800, so the lower figure is £500 and the rewrite is due at £4,500.
The practical effect is that low-value estimates need re-issuing on small movements. A £600 estimate has to be rewritten at £720, a £120 increase. Figures are illustrative; the thresholds are not.
Draft Article 12 then requires an itemised bill identifying the components of the services provided: individual medicinal products, individual goods and services, and charges for outside services. The two remedies work as a pair — an estimate the client can hold you to, and a bill that can be compared with it line by line. If your billing currently produces one line for a procedure, this is a practice management system project as much as a pricing one.
Four verified findings put your own pricing in context:
And one figure to handle carefully. The CMA estimated consumer detriment attributable to first opinion practices at around £1 billion over five years, with an alternative estimate of £600m to £700m of additional customer expenditure. Those are market-level estimates, built from large-group economic profits. They are not a finding about any individual practice's pricing, and they should not be read as one — not by a client, and not by a practice owner talking themselves into a discount.
What we do with this. We build the banded price list against your own profit and loss account, model the prescription fee and the parasiticide list before they are published, and decompose the pet care plan so the published saving is a number you chose. Then the estimate and billing changes get costed as the process work they are. That is our CMA compliance and pricing service, and it sits on top of the ordinary accounts and tax work rather than beside it. Nothing here is legal or regulatory advice.
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Under draft Article 7 of the CMA's Order, a comprehensive standard price list covering consultations, preventative care, prescriptions and dispensing, surgical procedures, treatments, diagnostics and laboratory tests, and end-of-life care. Every item has to be priced by five weight bands: cat or small dog under 10kg, medium dog 10 to 25kg, large dog over 25 to 40kg, extra-large over 40 to 60kg, and giant over 60kg. Three further publication duties sit alongside it: a parasiticide price list with a link to the VMD Register of Online Retailers, full pet care plan information, and practice information including your out-of-hours provider and staff qualifications.
Where the recommended treatment pathway is reasonably likely to cost £500 or more including VAT. That figure is the Initial Monetary Threshold defined in Article 2 of the CMA's draft Order and, unlike the prescription fee caps, it is not in square brackets, so it can be planned around. 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. Because the test takes the lower figure, the two limbs swap over at an estimate of £2,500: below that the 20% governs, and above it the £500 does.
It makes the saving checkable. Draft Article 9 requires you to publish the services in the plan and how often each is provided, the standalone price of each service, the savings methodology, the monthly and annual rates, and the cancellation terms. Once each component carries a published standalone price, anyone can add them up and compare the total with the plan price. That also links the plan to the parasiticide list: if you reprice flea and worm cover downward to compete with online pharmacies, the standalone total falls and the published saving on the plan falls with it. Both need modelling together before either is published.
No, and the distinction matters. The CMA estimated consumer detriment attributable to first opinion practices at around £1 billion over five years, with an alternative estimate of £600 million to £700 million of additional customer expenditure over five years. Those are market-level estimates built largely from the economic profits of the large veterinary groups. They are not a finding about any individual practice, and they cannot be read as one. What the CMA did find about individual pricing is narrower and more useful: average prices grew 63% between January 2016 and December 2023 against 32% for CPI, and 84% of the practice websites it reviewed published no prices at all.
Prices for commonly sold flea, tick and worming products, which draft Article 8 defines as products of which 100 units or more were sold in the previous twelve months. If fewer than ten of your products meet that threshold, you publish your top ten instead. The list must also carry a link to the VMD's Register of Online Retailers, which is the part with commercial consequences: the CMA found pet owners could save £200 to £300 a year buying commonly prescribed medicines from an online pharmacy, with online prices 50% to 60% below practice prices for some products. Decide your response to that comparison before the list is published.
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