The Competition and Markets Authority's announcement on 18 November 2025 that it is taking enforcement action against 8 different companies for their pricing strategies (see our separate article here) represents far more than a regulatory enforcement action, it embodies the strategic transformation outlined in the CMA's 2026-2029 strategy. By launching its first investigations under the Digital Markets, Competition and Consumers Act 2024 (DMCCA), targeting 8 companies whilst issuing advisory letters to 100 businesses, the regulator is demonstrating how it intends to fulfil its redefined purpose: to promote competition and protect consumers with a goal of driving economic growth and improving household prosperity.
The CMA's 2026-2029 strategy arrives "at a critical moment for the UK economy" and "must be grounded in a real-world context." The government have stated that their primary mission is stimulating economic growth to raise living standards, unlock better public services, and set the UK on a path to stability and prosperity. The CMA are aiming their strategy to position competition and consumer protection regimes as enablers of the government's growth mission, ultimately giving consumers confidence to engage in markets and adopt new products and services.
The strategy's seeks to position the promotion of competition and protecting consumers as more than regulatory functions, but economic growth levers. By promoting competition, the CMA hopes to spur innovation, investment, and productivity whilst keeping prices low and quality high. By protecting consumers, the regulator intends to boost consumer confidence to encourage economic growth. The November enforcement action against online pricing practices is one example of how they intend to achieve this through action.
Five strategic objectives
The CMA has laid out five strategic objectives to guide its work to 2029.
Promoting effective competition
This commits the CMA to remain "a strong advocate for, and independent enforcer of, effective competition across the UK economy – removing blockers to competition whilst also stepping up action to enable legitimate, pro-growth business collaboration."
The strategy addresses digital markets specifically, committing to implement the UK's new digital markets competition regime with a "purposeful and pragmatic approach" that supports an environment where companies of all sizes can flourish.
Championing consumers
The second objective – directly relevant to the November enforcement action – commits the CMA to "protect people from harm and help businesses do the right thing by their customers."
The CMA lists three specific goals: (1) putting money back in people's pockets to improve household prosperity; (2) taking particular care to prevent harm in areas of essential spend and at moments of vulnerability; and (3) ensuring people can participate confidently and actively in the economy, building the consumer confidence foundational for growth.
The November investigations into drip pricing, misleading time-limited offers, and automatic opt-ins across secondary ticketing, driving schools, fitness, and homeware sectors tie in with these goals. By targeting practices that undermine price transparency and exploit consumer psychology, the CMA aims to protect household budgets and build market confidence.
The strategy emphasises that "for the vast majority of well-intentioned businesses, the most effective route to compliance with consumer protection law is through guidance and advice." The two-tier approach – eight investigations alongside 100 advisory letters – is consistent with this philosophy and suggests that the CMA will not immediately be looking to wield its new powers to fine businesses for breach of consumer law.
Helping government deploy pro-competition interventions
The third objective represents an evolution in the CMA's role. The regulator commits to "step up our role as an enabler of competition, providing expert advice and recommendations to government with a particular focus on public procurement and regulatory barriers."
The CMA intends to position itself as "as much an enabler of competition as an enforcer." Through this advisory role, the regulator will help governments and public bodies deploy pro-competitive interventions. Priority areas include public procurement, removing anti-competitive regulation, and permitting greater access to critical data.
Fostering a UK regulatory landscape that attracts investment
This commits the CMA to "continue to implement our 4Ps approach (Pace, Predictability, Proportionality and Process), ensuring the competition and consumer protection regimes contribute to the UK's reputation as a great place to do business and invest."
The 4Ps framework represents a significant transformation programme since the CMA's establishment.
- Pace means making good decisions as quickly as possible. The CMA has introduced new KPIs to reduce pre-notification periods and streamline merger reviews.
- Predictability provides clarity on approach and expected outcomes. Whilst individual investigation outcomes cannot always be predicted, the CMA commits to providing maximum upfront certainty about processes, approaches, and guiding principles.
- Proportionality ensures actions are balanced and targeted, minimising costs wherever possible. Before launching new markets work, the CMA will consider potential costs for businesses alongside anticipated benefits.
- Process transforms stakeholder engagement. The CMA has established a Growth and Investment Council bringing together industry bodies and is launching a Consumer Forum to keep consumer perspectives central.
The November enforcement action could be seen to demonstrate these principles in practice. Rather than investigating all 400 businesses reviewed, the CMA targeted eight egregious cases whilst giving 100 others the opportunity to achieve compliance through advisory letters.
Prioritising UK interests
This commits the CMA to "focus relentlessly on delivering tangible benefits for the UK's economy, its citizens and businesses."
The strategy states that the CMA's primary responsibility is the UK. The regulator aims to prioritise markets and issues delivering greatest positive impact for the UK's economy, citizens, and businesses.
The CMA will support growth and competitiveness in strategically significant sectors, unlocking opportunities for investment, innovation, and scaling of UK businesses. It will prioritise issues where it is best placed to act, considering whether international counterparts' actions may address concerns and avoiding unnecessary duplication.
Delivering the strategy: operational transformation
Achieving these objectives requires fundamental operational changes. The CMA set out how they intend to achieve the strategic objectives.
- Agility: making maximum use of the full range of available actions: formal investigations, informal reviews, settlement resolution, litigation, guidance, advocacy, and policy advice. The approach taken will depend on how to best deliver impact quickly and proportionately.
- Productivity: depends on attracting and retaining talented people. The CMA is investing in skills development, tech-enabled tools, digital transformation, and harnessing AI to enhance productivity.
- Impact measurement: is receiving a step-change. The CMA's statistics show that it currently delivers in excess of its target to provide £10 of benefit for every £1 of taxpayer money spent, it is expanding its 'Impact Assessment' methodology to capture its evolving portfolio, including indirect effects and deterrence.
New KPIs will track impact (direct and indirect), speed and efficiency, and stakeholder experiences and perceptions through regular surveys.
Strategic context: government vision
The government's Strategic Steer to the CMA, whilst respecting the regulator's statutory independence, provides important transparency over policy priorities. Key expectations include supporting growth and investment, focusing on markets and harms impacting UK-based consumers and businesses, supporting growth in Industrial Strategy sectors, providing evidence and policy advice to government, prioritising tools that drive efficiency in public services, promoting consumer trust whilst deterring poor corporate practices, and enhancing the UK's attractiveness for international investment.
A new chapter in consumer protection
The November 2025 enforcement action against online pricing practices is not an isolated regulatory intervention, it could be seen as the opening chapter in the CMA's strategic vision for 2026-2029. By wielding its new DMCCA powers to investigate 8 companies whilst supporting 100 others towards compliance, the regulator is looking to demonstrate how it will balance robust enforcement against egregious conduct with support for well-intentioned businesses.
As Sarah Cardell emphasised, "This is just the start of our work." The CMA's 2026-2029 strategy positions consumer protection not as a regulatory burden but as an economic growth enabler to create the conditions for businesses to thrive.
