This blog is written by the Corporate and Commercial team at Scott Bailey LLP | March 2026
The Competition and Markets Authority (CMA) has now concluded its market investigation into veterinary services and published a package of legally binding reforms. The final report, published on 24 March 2026, sets out measures that will fundamentally change how veterinary practices operate – with formal orders to come into force before 23 September 2026. These changes are likely to reshape how veterinary practices operate.
These are not background regulatory changes. They carry real compliance obligations, affect how practices deal with clients day to day, and will shape how buyers and sellers approach transactions. Practices that take steps now will be better placed when the formal orders arrive.
Scott Bailey LLP is a law firm based on the South Coast, advising veterinary practices, corporate groups and investors across England and Wales. We act on acquisitions and disposals of veterinary businesses, regulatory compliance, and commercial contracts, providing practical legal support tailored to the sector.
Key findings from the CMA investigation
The CMA’s investigation, which attracted over 56,000 responses from the public and sector, identified four core problems.
Lack of price transparency
Many clients cannot access clear, upfront information about treatment costs. This limits informed decision-making and reduces competitive pressure between practices. The CMA found that average veterinary prices rose by more than 60% between 2016 and 2023, outpacing inflation significantly.
Consolidation and corporate ownership
Large corporate groups now account for around 60% of veterinary practices, following a sustained wave of acquisitions. While consolidation is not inherently problematic, the CMA found consistent evidence that prices at some larger groups tend to be higher than at independent practices, and often rise following acquisitions.
Lack of consumer awareness
Clients are not always aware of the ownership structure of the practice they are using, or of alternative providers. This is particularly significant when accessing specialist or emergency services, where pet owners are under time and emotional pressure.
Medicines and prescriptions
The CMA found that over 70% of pet owners obtained long-term medication directly from their practice, even though many could save around £200 a year by purchasing elsewhere. Practices have not always made clients sufficiently aware of their right to obtain prescriptions elsewhere. A prescription fee cap of £21 has now been introduced.
For the full detail, the CMA’s final report and case page sets out the complete package of remedies and implementation timeline.
What changes are expected, and when?
The CMA has six months to issue a legally binding Order, meaning the formal requirements will be in place by 23 September 2026. Larger practices (those with 15 or more first opinion premises) will have three months to comply with most remedies once the Order is made. Smaller practices will generally have six months. The key changes fall into six categories:
- Pricing transparency: practices must publish comprehensive price lists for common services and provide written estimates for treatments expected to cost £500 or more, including aftercare costs, with itemised bills after treatment.
- Ownership disclosure: practices that are part of a larger corporate group must clearly disclose this, including through branding requirements.
- Prescription policies: the £21 prescription fee cap is now in place, and practices must actively inform clients of their right to obtain medicines elsewhere.
- Client feedback: practices will be required to offer regular client satisfaction surveys, enabling comparison of service levels between providers.
- Price comparison: a national price comparison tool will be developed, drawing on data from the RCVS Find a Vet service.
- Regulatory reform: the CMA has backed government proposals to replace the Veterinary Surgeons Act 1966 and bring veterinary businesses, not just individual practitioners, within the scope of regulation for the first time.
Non-compliance carries significant risk. Following recent DMCC Act reforms, businesses that breach a CMA Order can be fined up to 5% of global annual turnover.
Consumer terms of business for veterinary practices
One of the most important areas for practices to review is their consumer terms of business. The CMA’s focus on transparency and informed consent brings these documents into sharp focus, and many practices are relying on terms that have developed over time without being reviewed against current consumer law requirements.
Compliant terms of business should cover the following areas:
- Fee calculation: clearly explain how fees are calculated, including when estimates may change and what triggers additional charges.
- Consent to treatment: set out the process for obtaining consent, particularly where treatment costs may escalate.
- Prescription policy: clearly state the client’s right to obtain medication elsewhere, consistent with the CMA’s requirements and the new prescription fee cap.
- Unfair terms: review for any provisions that could be considered unfair under the Consumer Rights Act 2015.
- Incorporation: ensure terms are provided at the right time and in a way clients can easily understand. Terms buried in small print or provided after treatment starts are unlikely to be properly incorporated.
Outdated or unclear terms create regulatory risk, increase the likelihood of disputes and make fee recovery more difficult. They are also an area buyers will scrutinise closely in due diligence.
Implications for veterinary practice owners
For independent practices and smaller groups, the reforms present both challenges and real opportunities.
Greater compliance requirements will require updates to processes, documentation and client communications. The prescription fee cap and pricing transparency requirements in particular will need to be embedded into day-to-day operations. However, increased transparency may also help well-run independent practices compete more effectively against larger operators — the CMA’s analysis suggests pricing at independents is generally lower.
Practice owners should be asking themselves, is our pricing clear, published and defensible? Do our client communications meet the expected standards, including on prescriptions? Are our terms of business compliant, up to date and consistently applied? How prepared are we for scrutiny in the context of a future sale or investment?
Practices with fewer than 15 first opinion premises will have slightly longer to comply once the formal Order is issued, but the direction of travel is clear. Getting ahead of the requirements now is considerably less disruptive than doing so under pressure.
Buying or selling a veterinary practice: legal considerations
The CMA’s findings are particularly relevant for transactions involving veterinary businesses.
Buyers are likely to carry out more detailed due diligence, focusing not only on financial performance but also on compliance, pricing structures and client-facing documentation. This adds a new layer to an already detailed process – covering everything from business structure and RCVS compliance through to employment arrangements and property. We have set out the key legal steps involved in buying a veterinary practice in the UK in a separate guide.
For sellers, well-drafted and compliant terms of business can strengthen your position and improve deal confidence. Conversely, gaps or inconsistencies – particularly around pricing transparency or prescription policies – may affect valuation or cause delays once a buyer is conducting due diligence. Preparing documentation in advance is always advisable. Our guide to selling your veterinary practice covers what to have in order before you go to market.
There may also be increased use of warranties and indemnities relating to regulatory compliance, as well as more detailed disclosure processes, as buyers seek assurance that practices are CMA-ready.
For acquisitions involving larger corporate groups, the CMA’s scrutiny of consolidation means transactions affecting local markets may face closer review. Early legal advice on transaction structure is particularly important in this environment.
Legal support for veterinary practices
At Scott Bailey LLP, we advise veterinary practices and veterinary businesses across England and Wales on a wide range of legal matters, including:
- Reviewing and updating consumer terms of business to ensure compliance with consumer law and alignment with CMA requirements.
- Buying and selling veterinary practices, from heads of terms through to completion.
- Corporate structuring, shareholders’ agreements and partnership arrangements.
- Regulatory compliance and commercial contracts.
Our approach is practical and commercially focused, helping clients manage risk while supporting their long-term objectives. If you are looking for advice or guidance for your veterinary practice or have questions relating to the recent reforms, reach out to our specialist veterinary business solicitors today.
Frequently asked questions
Yes. The CMA will issue a legally binding Order by 23 September 2026. Larger practices with 15 or more first opinion premises will have three months from that date to comply with most requirements. Smaller practices will have six months. Non-compliance can result in fines of up to 5% of global annual turnover.
The CMA’s 2026 veterinary reforms require practices to publish clear price lists, provide written estimates for treatments over £500, disclose ownership structures, cap prescription fees at £21 and give clients genuine choice over where they obtain medicines. A national price comparison tool is also being developed. Practices that are part of larger groups will face additional branding and disclosure requirements.
Yes. Clear and compliant terms of business are essential to ensure transparency on pricing, consent and treatment. They must explain how fees are calculated, set out the client’s prescription rights and avoid provisions that could be considered unfair under the Consumer Rights Act 2015. They must also be properly incorporated – provided at the right time and in a way clients can readily understand.
Acquisitions involving larger corporate groups may face closer scrutiny from the CMA, particularly where consolidation could affect local competition. Independent buyers and smaller groups are less likely to be affected by merger review, but all buyers will want to assess a target practice’s compliance with the new requirements as part of due diligence.
Speak to our veterinary law team
The CMA’s reforms signal a clear shift towards greater transparency and accountability in the veterinary sector. Practices that take steps now to review their pricing, client communications and terms of business will be better placed when the formal orders arrive.
If you would like to discuss reviewing your terms of business, preparing for the CMA reforms, or buying or selling a veterinary practice, our corporate and commercial solicitors would be pleased to help.
Scott Bailey LLP advises clients across England and Wales from our New Forest offices. Please get in touch to speak with one of our corporate and commercial solicitors.
