Promoting competition and protecting consumers to drive growth and improve household prosperity
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A speech by Sarah Cardell, the CMA's Chief Executive, delivered at
the Chatham House Competition Policy Conference 2025 to launch the
CMA's 2026 to 2029 strategy. Introduction "12 months ago, I had the
privilege of addressing Chatham House in a speech which marked the
start of a year of change for the CMA. It is an honour to be
invited back to reflect on progress and share some thoughts on what
lies ahead. It has been a challenging year, but also an energising
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A speech by Sarah Cardell, the CMA's Chief Executive, delivered at the Chatham House Competition Policy Conference 2025 to launch the CMA's 2026 to 2029 strategy. Introduction "12 months ago, I had the privilege of addressing Chatham House in a speech which marked the start of a year of change for the CMA. It is an honour to be invited back to reflect on progress and share some thoughts on what lies ahead. It has been a challenging year, but also an energising one. And the challenge, of course, brings the reward – the opportunity to have a real impact on the health of the UK economy and the prosperity of households across the country. A year on, I think my assessment of the transformation we needed at the CMA has stood the test of time. And it has been delivered with more urgency and widespread adoption across the organisation than even I might have anticipated in November last year. As any CEO knows, there will always be external commentary on the right way forward for your organisation. But as they say, ‘Distractions are plentiful. Work is hard. And time is short'. So, my focus has been on delivering tangible benefits for the UK economy, grounded in the real-world context of our current operating environment. And, of course, actions speak louder than words. So, before we turn to the future, it is worth reflecting on the last 12 months of delivery. Starting with one of the big commitments I set out in my speech last year, we are fundamentally transforming how we work, through our 4Ps programme, which is already delivering over 75 changes across all areas of our work. That includes a step change in how we engage with stakeholders and parties to our investigations: 4 meetings of our Growth and Investment Council, multiple roundtables, upgraded outreach, earlier meetings with senior decision makers, and a clear relationship reset with the investment and business community. Turning to our case work… In mergers, we've introduced ambitious new KPIs to streamline and speed up the pre-notification and phase 1 process, as well as updating our approach to jurisdiction, remedies and global deals. In competition enforcement, we've imposed financial penalties of around £200 million, and secured more than £120 million in financial payments through commitments – putting money back, directly and promptly, into the NHS and the government's affordable housing programme. In markets, we have a key role to play in easing the cost of living for people in tough times and this year has been no exception. From infant formula and vets, to fuel prices and now with an eye on dentistry – we are relentlessly focused on bringing down prices and improving choice. And we've taken important consumer protection action, for example to change the way Ticketmaster operates. At the same time, as the policy landscape shifted toward a greater focus on industrial strategy, we launched our market study into civil engineering for road and rail infrastructure. And we've leveraged our microeconomics and public policy expertise to support government in critical areas like driving up investment and scaling UK businesses. Last, but certainly not least, we've implemented two major new regimes under the Digital Markets, Competition and Consumers Act (DMCCA). More on these later. This record of delivery speaks for itself – the CMA is as committed as ever to our core purpose: promoting competition and protecting consumers. For the rest of this speech, I want to focus on what lies ahead, because today we are launching a new three-year strategy for the CMA. Let me be clear. This is not a moment for handbrake turns. This strategy continues the journey of transformation we have been on over the last year. But today is an important moment, drawing together the themes of the past year and setting a clear trajectory for what is to come. Real world context If you take one thing away from today, let it be this: our 2026 to 2029 strategy is founded on reality, responsibility and results. Let me explain what that means. We all know this is a time of acute economic pressure for the UK. Households are feeling the strain. Firms are managing uncertainty, volatility, and rapid change. Business confidence and public trust in institutions is fragile. Amidst all this, the UK needs to restore critical infrastructure and public services. To bolster our economic security and resilience to global shocks. To navigate a volatile geopolitical environment. To build a country where opportunity and prosperity reach every corner. Any strategy worth its salt must be capable of surviving contact with these realities. But this, of course, is only one side of the coin. Because this is also a moment of enormous possibility. New technologies are expanding the bounds of human understanding and capability. Consumers have more information and choice at their fingertips than ever before. Businesses from around the world are ready to invest, innovate, and compete here. The entrepreneurial spirit that built this country is still here – if we can foster the conditions to unleash it. Reflecting this context, the UK government's priority is to stimulate economic growth – which is critical to raising living standards and unlocking better public services. Certain key enablers are foundational to the growth mission. Some sit outside the CMA's remit. But many are closely connected with the competition and consumer protection regimes, which form a core part of the UK's wider economic policy framework. And in the current policy landscape, this includes the growing interconnectedness of the UK's trade, industrial and competition policies. This, then, is the reality in which our strategy is squarely situated. An urgent need to stimulate growth but also – flowing from that – an opportunity to forge a fairer, more prosperous future for the UK. But I also said that our strategy is about responsibility and results. Because it is very clear to me, in this context, that the CMA must play our part in helping to build a more resilient and dynamic economy that works for people across the UK. And that responsibility underpins our strategy for the next 3 years. Let me come onto that now. Three-year strategy It should be no surprise that the fundamentals of our mandate – to promote competition and protect consumers – are unchanged. But we must fit the powers and resources we have to the outcomes the country needs. That is why our purpose over the next 3 years is to promote competition and protect consumers with a clear end goal in mind: to drive economic growth and improve household prosperity. But that is not where our responsibility ends. How we discharge that mandate must also adapt to the context I have described. So, we have to be bold and be prepared to do things differently. Rigorous, but not rigid. Decisive, but not dogmatic. Combining continuity with change. And always focused on outcomes, not orthodoxy. In short – we must be purposeful and pragmatic. Looking back 3 years from now, I hope this is how our approach will be characterised. CMA independence Before I unpack how we will achieve that, I'd like to touch on our independence. This has, of course, been a topic of some debate over the last year; and for those still looking backwards at the leadership changes in January, I will say – with absolute conviction –that there has been no reduction in the operational independence of the CMA since then. More broadly, I welcome discussion around this important aspect of how the CMA operates. But let's do that anchored in reality, and with a clear sense of what independence actually means for the CMA. The law establishes that we take certain decisions independently of government, based on an objective, evidence-based assessment. Merger decisions, for example, as well as more recently our digital markets Strategic Market Status (SMS) designation decisions. Our political independence when taking those decisions is unchanged. But that does not mean that the CMA operates in a political vacuum. We are a government department, albeit non-Ministerial. We are not the independent state of the CMA. And competition policy is a part of wider economic policy. So, beyond those statutory questions which we decide independently of government, it is right that we are informed by the policy context in which we operate. And that economic and geopolitical context for the UK has changed dramatically in recent years. What are the implications of this? First, our work operating the UK's competition and consumer protection regimes has a direct impact on the economy. That carries a responsibility to act in line with wider government economic policy and priorities, provided they are consistent with our statutory duties. And, with such a clear and urgent policy focus on stimulating growth to improve living standards, of course we are putting our resources behind that national endeavour. We welcomed the government's strategic steer for this reason, and you will see how we have sought to integrate it into our strategy. That might inform, for example, which markets we prioritise for review, or which areas of government policy we choose to support through our research and advice. Second, our focus on that wider policy context has naturally sharpened and become more prominent in recent times, as UK trade, industrial and competition policy have become increasingly interconnected. Many of the issues we tackle have a global dimension. It is both inevitable and appropriate that we consider this deeper interconnectedness – including the more volatile global trading environment – whilst ensuring it does not cut across our statutory duties. And it is properly for government to guide that policy interplay, rather than have the CMA autonomously decide it. It is also right, in this more interconnected environment, that political influence is exercised through the proper levers in a transparent way. Again, that is why the strategic steer issued by government is so important. In the context of a discussion about CMA independence, I'd like to say a word about the upcoming consultation on potential changes to update and streamline the decision-making model in our mergers and markets functions. The current model of decision making by independent panel groups in these areas dates back many decades and was carried over from the Competition Commission when the CMA was formed 12 years ago. It delivers robust and objective scrutiny of relevant evidence and draws from a wide range of professional and industry expertise. But it is an unusual system, where the CMA's Chief Executive, Chair and Board are prevented by statute from having a role in some of the organisation's most important decisions, whilst being accountable to Parliament for them. The proposals would update that approach, bringing it into line with the new digital markets competition regime. Specifically, individual markets and phase 2 merger decisions would be taken by a Board sub-committee - comprised of Board non-executives, senior executives and expert panel members. This would establish a clear line of accountability through both senior executives and the Board whilst retaining the benefit of a breadth of expertise. There will still be a separate phase 1 decision maker in mergers. And, as the government has set out, these proposals ‘will not alter the independence of CMA decision making from Ministers'. But accountability would be enhanced. As would our ability to deliver on the 4Ps. And this reflects our positive experience with the digital markets model so far. 5 core objectives of our strategy Turning now to the content of our strategy. We have 5 core objectives. Some of these will feel quite familiar; others are intended to signal shifts in important areas. A combination of continuity and change. First, we will remain a strong advocate for, and independent enforcer of, effective competition across the UK economy. We know this makes a difference for innovation, productivity and security of supply. For prices, choice and quality. But effective competition does not preclude business collaboration. So, within this first objective we will also step up our action to enable legitimate, pro-growth collaboration – which can help firms to scale, secure investment, make innovative breakthroughs, and bank productivity gains. Equally, the vast majority of mergers do not raise competition concerns, and every deal capable of being cleared unconditionally or with effective remedies should be. Our updated approach to merger remedies, and how we are embedding the 4Ps through the mergers process, reflects this. And we won't stop there. In the New Year we will launch a review of our approach to efficiencies in merger assessments. Our second objective is all about championing consumers. This is at the heart of everything we do. But here, we are talking specifically about putting money back in people's pockets, protecting them from harm and helping businesses do the right thing by their customers. All of which contribute directly to household prosperity, as well as strengthening consumer confidence which supports the conditions for economic growth. The enhanced consumer protection regime introduced under the DMCCAmarks a fundamental shift in how we uphold consumer rights in the UK. And we have taken a deliberately strategic approach to implementing it. A major focus for us in the early days has been to help businesses comply with the new rules, through guidance and pro-active engagement. This will remain critical going forward. In parallel, we have been building the evidence to launch major investigations in priority areas. You will have seen earlier this week the output from that work behind the scenes, as we launched a cross-economy crackdown on online sales practices including drip pricing and pressure selling, with investigations into eight businesses, over 100 advisory letters and fresh business guidance. Supporting businesses to comply with the law, alongside tough enforcement where it really matters to people. That is the recipe to maximise the value of the new regime for consumers and fair dealing businesses - and you can expect it to continue. Those first 2 objectives are unsurprising priorities for the CMA, and rightly so. But the third reflects an important change we've been making over the last year – dialling up our role as an enabler of competition through advice and recommendations to government. Beyond our enforcement work, many of you will be familiar with the CMA's role advising government and public authorities on pro-competitive interventions they can make in service of broader policy goals. This is more valuable than ever in the context of the growth mission and cost of living pressures. It is essential, over the next 3 years, that we act as much as an enabler of competition as an enforcer of it. So, expect a gear-shift here, as we help government and public authorities design and deploy pro-competition interventions to support growth, innovation and investment-related policies. This is where the unique combination of the CMA's markets, microeconomics and public policy expertise really comes to the fore. We believe the impact could be significant – whether by removing anti-competitive regulation standing in the way of companies scaling, or unlocking cross-economy barriers to growth, like more interoperability and access to data. A great example is public procurement. This costs taxpayers £385 billion each year, yet bid rigging can inflate prices by 20% or more. Our data science and cartel enforcement teams have developed tools to scan bidding data and identify illegal activity at scale. Working closely with central government departments and other public bodies, this could deliver very substantial public savings and safeguard the level playing-field for fair-dealing businesses. There is a greater opportunity beyond even this. Applying a pro-competition lens to public procurement can help government shape markets to achieve critical policy objectives – from creating opportunities for high-potential firms to scale, to building supply chain resilience, and boosting UK competitiveness. But time and again, we hear from stakeholders that the full potential of public procurement is not being realised, including across many of the IS-8 (Industrial Strategy growth-driving) sectors. We are already providing advice about this to government departments – for example in defence. Expect this third objective to be an important focus of our work in the coming years. Our fourth objective reflects how, in a world of mobile capital and talent, the UK must work hard to attract the investment needed to power growth. For the CMA, that means doubling down on our contribution to a UK regulatory landscape that instils business confidence and acts as a magnet for investment. This does not mean less robust decision making, nor that we will always see eye-to-eye with parties in individual cases. But achieving the outcomes in our strategy requires a foundational level of business and investor confidence in our regimes. That is what our comprehensive 4Ps framework was designed to address. The 4Ps have driven transformative change across the organisation over the last year - and stakeholders report that we are moving the dial. There is always more to do and embedding these changes remains a central focus in our new strategy. Our fifth and final objective is an essential wrapper: across all of our work, we will focus relentlessly on delivering tangible benefits for the UK. There are two elements to this. First, consciously prioritising markets and issues that deliver the greatest positive impact for the UK's economy, citizens, and businesses, setting the UK on a path to a more stable and prosperous future. And second, leveraging the unique design of the UK's competition and consumer protection regimes to deliver outcomes that make a real difference for the country, and to foster a global reputation for a purposeful and pragmatic British approach. The digital markets competition regime exemplifies this objective. As new technology permeates every aspect of our lives, effective competition in these markets is key. Many of the competition concerns in digital markets are global in nature but we can apply a unique UK lens to the solutions. The flexible, participative design of the UK regime means we can foster digital ecosystems here in which both global tech giants and UK start-ups can innovate, invest and grow. And the forward-looking design means we can tackle issues as they arise, keeping up with rapidly evolving technologies, rather than solely addressing yesterday's problems. In combination this means that, wherever possible, we can move at pace and look for proportionate, constructive and future-facing solutions - rather than becoming mired in stand-offs and litigation. Though, of course, this also depends on how others choose to engage with our process and approach. And our focus on the UK interest means prioritising issues we are best placed to tackle - those where UK businesses and consumers will experience the greatest tangible benefits from our work. The regime also gives us the flexibility not to prioritise some issues, for example when they are being effectively addressed in other jurisdictions. An early example of these unique design features in action can be seen in our search designation. Through the course of the investigation, an emerging issue was whether the search designation should extend to Gemini. We worked closely with Google and the wider ecosystem to get the balance of our assessment right. The flexible and forward-looking nature of our regime meant we were able to conclude it was premature to include it at this point, whilst keeping open the possibility of revisiting this question if the way Gemini was used for search evolved in the future. At the same time, we decided it was essential to include the use of AI overviews and AI mode. And we are prioritising action on remedies that enhance transparency, choice and attribution for content providers in this context – issues that matter to many UK news publishers and other UK businesses. Results So we have a clear purpose, from which flow 5 strategic objectives. But, of course, the results are what really matter. Applying these strategic objectives across all our work, we will contribute to a set of mutually reinforcing outcomes, where:
Underpinning all of this is an upgraded operating model designed around maximising agility and productivity, to deliver the greatest impact for the UK with the resources we have available. And, above all, we must be accountable for the success of this strategy. So, we are developing a new suite of KPIs, launching new stakeholder surveys, as well as updating our established Impact Assessment methodology to better reflect the full range and impact of our evolving portfolio of work. That is our 2026 to 2029 strategy. I know you will all keep our feet to the fire delivering it. And, by staying purposeful and pragmatic – anchored in reality, responsibility, and results – I have every confidence that we will. Acknowledgements Thanks to Ruby Riley, Assistant Director of Communications at the CMA, for assistance in the development of this speech." |