2025 has marked a directional shift for the UK Competition and Markets Authority (CMA) in the way it approaches competition and consumer protection and enforcement in the UK. Three key documents published in 2025 – the Strategic steer to the Competition and Markets Authority, the CMA’s Annual Plan 2025-26, and the UK’s Modern Industrial Strategy – collectively guide the CMA towards a focus on economic growth, investment attraction and business engagement whilst maintaining robust competition enforcement.

Strategic steer: Growth at the heart of competition policy

The government’s Strategic steer to the CMA, published in May 2025, represents a significant policy direction. Published each Parliament, the Strategic steer sets out the government’s priorities for the CMA and outlines how it should carry out its work. The 2025 steer establishes economic growth as the government’s primary goal. It positions the CMA as a key driver for achieving that goal through effective competition and consumer protection enforcement. The CMA is specifically directed to deliver such expectations through:

• Prioritising pro-growth and pro-investment strategies: The CMA is instructed to focus on the eight “growth-driving” sectors of the economy (Advanced Manufacturing, Clean Energy Industries, Creative Industries, Defence, Digital and Technologies, Financial Services, Life Sciences, and Professional and Business Services) when deciding which market studies and investigations to commence and when determining remedies;
• International coordination: The CMA should collaborate with international competition authorities to ensure consistency and avoid crossover in regulating UK markets;
• Flexibility in the use of enhanced powers: The CMA is expected to leverage its new powers under the Digital Markets, Competition and Consumer Act (DMCCA) “flexibly, proportionately and collaboratively” to unlock growth opportunities, particularly in relation to AI;
• Proactive and transparent engagement: The CMA is encouraged to provide “proactive, transparent, timely, predictable and responsive engagement” with businesses, working collaboratively to minimise uncertainty; and
• Government collaboration: The CMA should engage with government on key policy issues, and its procedural guidance to ensure it is useful and accessible to businesses.

The Government, in turn, commits to a presumption of accepting the CMA’s recommendations under the markets tool unless there are “compelling policy reasons” not to. In such cases, a clear explanation will be provided. Notably, the government has committed to providing an official response to recommendations within 90 days.

Annual Plan 2025-26: The CMA’s proposed changes

The CMA’s Annual Plan, published in March 2025, details how the new strategic focus will be put into practice over the coming year[1], namely through its new “4Ps framework” – Pace, Predictability, Proportionality, and Process. Whilst echoing the objectives outlined in the Strategic steer, the Annual Plan includes the following key takeaways:

• Accelerating decision-making – Starting with merger control, the CMA is implementing new key performance indicators for faster pre-notification and Phase 1 merger case completion. This includes: 
  • by June 2025, the pre-notification phase being completed within 40 working days (down from the current average of 65 days);
  • by June 2025, the target for straightforward phase 1 cases being 25 working days (down from 35 days);
  • the CMA clarifying its remit through updating guidance on how the ‘material influence’ and ‘share of supply’ tests are interpreted and applied.
• Targeting high-impact markets – The CMA will apply a “sharper priority” to markets that could multiply growth effects, specifically looking at unlocking investment in critical infrastructure and growth in areas with horizontal enablers.
• Digital markets – With the first “strategic market status” investigation launched in January 2025, the CMA will continue to use this tool to harness the benefits of investment and innovation from the largest digital firms, while allowing businesses across the UK tech sector to succeed.
• Consumer protection – From April 2025, the CMA has the power to decide whether key consumer protection legislation has been breached without undertaking court action. This includes imposing fines of up to 10% of annual turnover. The CMA will initially focus on harms such as aggressive sales practices, objectively false information, and obviously imbalanced contract terms.

Industrial Strategy: Competition supporting strategic sectors

The UK’s Modern Industrial Strategy – a document issued by the government on 23 June 2025 - sets out a 10-year plan to foster growth and increase certainty around UK business investment. It provides crucial context for how competition policy will support broader economic objectives. The key takeaways include:

• An NSIA review – There will be a 12-week consultation on updating the definitions of the 17 sensitive sectors subject to mandatory notification under the National Security and Investment Act (NSIA). This aims to ensure that the protection of national security and investor certainty can work simultaneously. The guidance will continue to be updated and exemptions to the mandatory regime will be announced shortly.
• 8 growth sectors – The Industrial Strategy identifies 8 high growth sectors (Advanced Manufacturing, Clean Energy Industries, Creative Industries, Defence, Digital and Technologies, Financial Services, Life Sciences, and Professional and Business Services), the growth of which the CMA is directly encouraged to promote. The CMA is directed to lead a market study in the construction sector, with the aim of transforming public procurement behaviours and civil engineering approaches. Echoing the Strategic steer, the CMA is setting a clear expectation that it wil support the Government’s efforts to boost competition and innovation in the defence sector, while also working towards the improvements in the markets' regime as a whole.
• Subsidy control threshold changes – In the Summer of 2025, the threshold at which subsidies must be referred to the CMA for review will increase from £10million to £25 million. This allows for the CMA’s focus on the largest subsidies with the greatest potential impact.

The implications

The Government’s renewed interest and refreshed approach to the CMA is striking. The intention is that this strategic realignment creates both opportunities and responsibilities for UK businesses. The CMA's commitment to faster, more predictable processes aims to reduce regulatory uncertainty and ensure competition law serves both businesses and consumers effectively. The message is clear: UK competition policy is not simply about preventing harm – it’s a tool to actively promote growth, innovation and investment. For businesses operating in the UK, staying informed about the CMA’s objectives will be crucial for navigating the evolving regulatory landscape and ensuring compliance with the CMA’s new priorities and practices. More significantly, these developments may create enhanced opportunities for affected businesses to engage with the CMA more proactively and take advantage of the broader growth agenda that now shapes UK regulatory policy. How this balance will play out, particularly against the backdrop of the current political climate, will be fascinating to watch.

We will continue to monitor and analyse these developments closely. For more information, please contact Dr Saskia King, Tenisha Cramer and Flora McCarthy. 

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[1] Based on the draft Strategic Steer