CMA Annual Report and Accounts 2025 to 2026 · first published 9 July 2026
The Competition and Markets Authority (CMA) annual report for 2025–26 sets out what the regulator did and plans to do next. For small businesses, three things stand out. First, the CMA is actively working to make public procurement fairer and more open to smaller firms — it is advising government on how to use the UK's £400bn annual procurement spend as a tool to drive growth, and is running department-by-department pilots to detect and deter bid-rigging. Second, new consumer protection rules under the Digital Markets, Competition and Consumers Act (DMCCA) 2024 are now fully in force: hidden fees (drip pricing), fake reviews, and misleading online practices are being actively prosecuted — SMEs must ensure their sales and marketing comply. Third, new conduct requirements on Google Search (affecting how businesses rank and advertise) and on Apple/Google mobile platforms (affecting app developers) create both obligations and opportunities for small tech and digital businesses. The report also notes that overlapping accreditations and duplicative standards — which disproportionately burden SMEs — have been flagged for reform, particularly in civil engineering and construction.
WHO THIS APPLIES TO
THE ENKII VIEW
SMEs bidding for public contracts face a double opportunity: the CMA is pushing government to broaden procurement beyond pure value-for-money and use it as a market-shaping lever, which could open doors for innovative smaller suppliers. At the same time, the CMA's systematic bid-rigging screening (now being piloted department by department) means any cartel behaviour — even informal information-sharing — carries serious financial and reputational risk. SMEs selling online must urgently audit their pricing displays and review practices: the CMA's first DMCCA fines (£4.2m, plus mandatory refunds to 80,000 consumers) show the regulator is willing to act fast and hit smaller operators, not just large corporations.
1. Check your firm has zero tolerance for sharing commercially sensitive information (prices, sales volumes, capacity) with competitors — even informally at industry events or through trade bodies. The CMA's new systematic screening pilots mean bid-rigging is increasingly likely to be detected automatically.
SMEs bidding for public contracts, all sectors — The CMA is running 'department-by-department pilots' for systematic bid-rigging screening. The £100m housebuilder case shows enforcement can follow even where firms claim information-sharing was informal.
2. Monitor the CMA's civil engineering market study recommendations for changes to accreditation and standards requirements — and respond to any government consultations on procurement reform to make the case for simplification that benefits your firm.
SMEs in construction, civil engineering and infrastructure supplying public contracts — The CMA has explicitly recommended aligning 'overlapping, duplicative accreditations and streamline standards that impose unnecessary costs and deter SMEs and challengers' in civil engineering procurement.
3. Audit your online checkout and pricing flows now: every mandatory charge (booking fees, service fees, delivery) must be shown in the total price from the first page the customer sees — not added later. Update your website before you receive an advisory letter.
All SMEs selling online to UK consumers — The CMA's first DMCCA fine (£4.2m + mandatory refunds to 80,000 customers) was for adding a mandatory £3 booking fee late in the checkout. The investigation concluded in just 5 months from launch.
4. Remove any incentivised, purchased, or selectively filtered reviews from your website and third-party listings. If you have received a CMA advisory letter, act immediately — 90% of businesses changed behaviour after letters, avoiding escalation to a formal investigation.
All SMEs that use customer reviews in their marketing (online or offline) — The CMA opened investigations into 5 companies for misleading reviews and issued 159 advisory/warning letters in 2025–26, with fake reviews a named enforcement priority under the new DMCCA regime.
5. Read the CMA's new conduct requirements on Google Search ranking transparency — if Google's ranking criteria become clearer and more predictable, update your Search Engine Optimisation (SEO) strategy and advertising approach accordingly to take advantage of fairer rules.
SMEs using Google Search advertising or reliant on organic search traffic — New CMA conduct requirements require Google to provide 'clearer, more predictable and more transparent ranking systems that could give businesses greater scope to expand and invest.'
6. Follow the CMA's ongoing consultation on app distribution rules for iOS and Android — submit your views if new distribution or NFC (contactless payment) rules would benefit your app or fintech product. Register for updates on the Microsoft business software investigation if you use or compete with Microsoft cloud or productivity tools.
SME app developers on iOS or Android — CMA commitments from Apple and Google are now in effect giving developers 'greater certainty, functionality, and transparency.' A new SMS investigation into Microsoft's ecosystem is underway, with further interventions expected.
7. Read the CMA's free accessible guide on how to collaborate without breaking competition law before entering any joint bid, data-sharing arrangement, or industry initiative. For environmental or open banking collaborations, check the specific CMA guidance published in 2025–26.
SMEs considering collaborating with competitors (e.g. consortia bids, joint ventures, sustainability initiatives) — The CMA published 'an accessible guide on how to collaborate without breaking competition law' and sector-specific guidance on sustainability and open banking, and maintains an open-door policy for businesses with compliance questions.
8. Engage with the CMA's recommendations to government on road and rail procurement reform — attend industry consultations and respond to government calls for evidence, as the CMA is actively lobbying for procurement to become a 'lever for growth and innovation' that could create new contracting opportunities.
SMEs in civil engineering, road, rail and defence supply chains — The CMA is 'impressing on government the opportunity for systemic change' in road and rail procurement, and is also engaging government on defence procurement and national cloud procurement strategies.
9. Ensure your NHS pricing and any communications to clinicians about competitor products are fully compliant — the CMA secured a £23m NHS payment from Vifor Pharma for misleading safety communications and upheld a £99m fine against Advanz for excessive pricing.
SMEs in pharmaceuticals or life sciences supplying to the NHS or public sector — The CMA has a 'strong track record in tackling anti-competitive behaviour that harms UK taxpayers' in pharmaceuticals and is collaborating with the Medicines and Healthcare Products Regulatory Agency (MHRA) on pro-competitive regulation in life sciences.
Every rule below quotes the official document verbatim.
UK public procurement is worth nearly £400bn annually and the CMA sees it as the state's single largest tool to shape markets, with active recommendations to government on broadening it beyond traditional value-for-money trade-offs. (All public procurement, UK-wide)
“UK public procurement, worth nearly £400bn annually, is the state's single largest tool to shape markets. The CMA believes reforming public procurement (including broadening frameworks beyond traditional value-for money trade-offs) could represent a major opportunity drive growth, innovation and strategic resilience.”
The CMA is running department-by-department pilots to improve detection and systematic screening for bid-rigging in public procurement. (All suppliers to central government departments)
“tackle bid-rigging through improved detection and more systematic screening, including through department-by-department pilots”
The CMA has recommended streamlining overlapping and duplicative accreditations and standards in civil engineering that impose unnecessary costs and deter SMEs and challengers. (SMEs in construction and civil engineering supplying public contracts)
“we made recommendations through our civil engineering market study to align overlapping, duplicative accreditations and streamline standards that impose unnecessary costs and deter SMEs and challengers”
The CMA's civil engineering market study recommends reframing road and rail procurement as a lever for growth and innovation, with strong central coordination. (Suppliers to road and rail public contracts, UK-wide)
“our recommendations reflecting the need for strong central coordination, and a reframing of road and rail procurement as a lever for growth and innovation”
Under the DMCCA 2024 consumer protection regime, the CMA can now decide whether consumer protection laws have been infringed, order direct refunds to consumers, and impose fines — without going to court. (All businesses selling to UK consumers, all sectors, all sizes)
“the CMA now has an enhanced toolkit that includes being able to decide whether consumer protection laws have been infringed, order redress to affected consumers, and sanction businesses that fail to comply without going through the courts”
The CMA's first DMCCA investigation concluded in April 2026 (5 months from launch) resulting in a £4.2m fine and mandatory refunds averaging ~£9 each to more than 80,000 consumers for failure to show total upfront prices including a mandatory £3 booking fee. (All businesses selling online to UK consumers; drip pricing enforcement)
“On top of a £4.2m fine, the CMA leveraged new direct redress powers for the first time, ordering the AA to refund more than 80,000 learner drivers around £9 each on average.”
Hidden or drip fees are estimated to lead consumers to spend up to £3.5bn more online each year than they intended, making this a top enforcement priority. (All online retailers and service providers selling to UK consumers)
“hidden or dripped fees that can lead consumers to spend up to £3.5bn more online each year than they intended”
90% of businesses changed their behaviour on fake reviews following CMA advisory letters, demonstrating the regulator's willingness to use lighter-touch tools before formal enforcement. (All businesses using online customer reviews, all sectors)
“90% of businesses changed their behaviour on fake reviews, for example, following advisory letters”
The CMA opened 14 new DMCCA consumer protection investigations and issued 159 advisory and warning letters in 2025–26. (All UK businesses subject to consumer protection law)
“opened investigations into 14 businesses and settled with 2; issued 159 advisory and warning letters, with rapid impact”
New CMA conduct requirements on Google Search include world-first publisher opt-out from AI content use and clearer, more predictable ranking systems — designed to give businesses greater scope to expand and invest. (UK businesses advertising on or publishing content indexed by Google Search)
“Our CRs focus on a fairer deal for content publishers, including a world first whereby publishers will be able to opt out of their content being used to power AI features in Google search, as well as clearer, more predictable and more transparent ranking systems that could give businesses greater scope to expand and invest.”
Google handles more than 90% of general search queries in the UK, with over 200,000 UK firms spending more than £10bn annually on Google search advertising. (UK businesses using Google Search advertising)
“over 200,000 UK firms spending more than £10 billion annually on Google search advertising”
CMA commitments secured from Apple and Google on mobile platforms give UK app developers greater certainty, functionality, and transparency. (UK app developers on iOS and Android platforms)
“we secured commitments from both firms, all now in effect, to give UK developers greater certainty, functionality, and transparency – supporting their confidence to bring new and innovative propositions to market”
The CMA secured a £100m combined payment from 7 major housebuilders for anti-competitive information sharing, the largest ever secured through CMA commitments. (Housebuilding and construction sector suppliers)
“The housebuilders agreed a combined £100 million payment – the largest ever secured by the CMA through commitments.”
Car manufacturers and industry bodies paid fines totalling more than £77m for competition law breaches relating to vehicle recycling and advertising. (Automotive sector businesses)
“car manufacturers and industry bodies reached a settlement with the CMA after admitting breaches of competition law relating to vehicle recycling and related advertising claims. This resulted in fines totalling more than £77m.”
The CMA published guidance enabling businesses to collaborate lawfully, including on higher education, competing for talent, and environmental sustainability, and signalled it does not currently intend to prioritise enforcement on commercial Variable Recurring Payments for open banking. (All UK businesses considering collaborative arrangements)
“publishing an accessible guide on how to collaborate without breaking competition law, as well as specific guidance on higher education, competing for talent, and environmental sustainability”
The CMA delivered direct consumer benefits averaging £3.3bn per year over the last 3 years, equivalent to almost £25 returned for every £1 of taxpayer spend on the CMA. (UK economy and consumers, all sectors)
“£3.3bn in direct consumer benefits, such as better prices and avoided consumer harms, on average each year over the last 3 years; Almost £25 in savings returned to consumers for every £1 spent by UK taxpayers on our operation over the last 3 years”
The new DMCCA 2024 consumer protection regime has been in force for its first full 12 months during 2025–26. (All UK businesses subject to consumer protection law)
“2025 to 2026 marked the first 12 months of the new DMCCA regime”
The CMA is consulting on measures to improve app distribution on iOS and Android, and on opening up competition in Near Field Communication (NFC) access underpinning contactless payments and digital wallets. (UK app developers and fintech businesses)
“the CMA is now consulting on measures to improve app distribution on both iOS and Android, and published an update on how we might open up competition in relation to Near Field Communication access (which underpins a smartphone's ability to make contactless transactions) and digital wallets.”
This briefing is enkii's interpretation of the official document — the official text always governs.
Source document © Crown copyright, reused under the Open Government Licence v3.0 via the GOV.UK Content API. enkii tracks every Procurement Policy Note and briefs changes the day they land — see all briefings.