CMA draft remedies: RCVS recognises need for change, but cautions over unintended consequences

We have responded to the potential package of remedies issued by the Competition and Markets Authority (CMA) as part of its ongoing market investigation into ‘veterinary services for household pets’. While recognising the need for change, we express caution over the potential for unintended consequences, including increased regulatory costs on practices, which could be passed on to consumers, and reduced availability of veterinary services in some areas.

The CMA published its draft paper on 1 May 2025, setting out its current thinking on the remedies that may be needed, should harm be found, both to change the commercial relationship between veterinary businesses and pet owners, and to bring about reform of the regulatory framework. Interested parties were given until Tuesday 27 May 2025 to respond.

In our response, which was developed by our CMA Working Group, we acknowledge the recent changes in the veterinary sector that prompted the CMA’s market investigation and the need for an increased consumer focus and welcome the opportunities for improved consumer protection that it could bring.

We recognise the issues raised by the CMA’s investigation so far, although our response notes that it is not yet clear which of these may be identified as having adverse impacts on the market for veterinary services for household pets. We also point out the risk of unintended consequences posed by proposed remedies in those areas not covered by the market investigation, for example, the care of production, equine and exotic animals, and the charity sector.

In our response, we note that we are keen to engage with any measures that help increase transparency and information available to consumers regarding the cost of veterinary treatment to increase freedom of choice. However, we also sounded a note of caution that any proposed remedies should be proportionate as additional regulatory measures will incur greater cost for the businesses providing veterinary services, and for the regulator to monitor and enforce. It therefore may be difficult to mitigate against the likelihood that regulatory costs will be passed on to consumers.

Additionally, increasing the cost of regulation to practices may impact smaller practices to the extent they may be unable to continue operating, which would ultimately reduce available choices for consumers and disproportionately increase costs.

As such we recommend that any measures put in place by the CMA are proportionate, enforceable, effective, applicable across all veterinary settings, and mindful of the fact that any additional burden on veterinary practices could have the unintended consequence of raising prices to the consumer. There should also be a clear review mechanism to make changes, if necessary.

We recommend that building on existing structures and measures, such as the RCVS Practice Standards Scheme and free online Find a Vet service, would be more proportionate and less costly than establishing new bodies to carry out these functions. We would also welcome additional monitoring powers and enforcement by the CMA in relation to those aspects of veterinary services delivery that are challenging to enforce under existing legislation.  

In our overview, our response stated: "We believe that the key change required to bring about improvements to consumer protection, standards within veterinary practice, and support for veterinary professionals working within clinical practice, would be for the RCVS to implement a scheme of mandatory practice regulation. To achieve this, new legislation is required. The RCVS has been pushing for such legislation for many years, as the Veterinary Surgeons Act 1966 is out of date – a point well understood by the CMA.

"We recognise that more can be done until new legislation is forthcoming to ensure that consumers have access to the right information, at the right time, so they can make good choices for their pets and their pockets. We have already begun this work, improving the information and advice that we make available via our website to animal owners."

We look forward to working with the CMA in the coming weeks and months on their proposed remedies to help achieve these important reforms.

Our full response to the CMA working papers is available to download in PDF format.