From AI pricing algorithms to public procurement: UK Competition and Markets Authority publishes its 2026–27 annual plan

On 23 March, the UK Competition and Markets Authority (CMA) published its 2026-2027 Annual Plan (the Annual Plan): the first since the CMA set out its enforcement priorities in the 2026-2029 Strategy Report (the Strategy Report) in November 2025.¹ The Annual Plan outlines the CMA’s immediate operational priorities for promoting competition and protecting consumers in the UK. Indeed, the most recent CMA actions are all in consumer facing sectors within its enforcement priorities. This month alone, the CMA launched a market study into private dental industry, competition investigation into the hotel sector and monitoring of petrol and diesel prices. Today, the CMA also concluded its vet services sector market investigation with major reforms proposed.

In its Annual Plan, the CMA has sought to address how, in the next 12 months, it will achieve each of five strategic objectives set out in the Strategic Report: being (i) promoting competition, (ii) championing consumers, (iii) supporting government interventions, (iv) fostering a pro‑investment regulatory environment, and (v) prioritising UK interests, supported by the 4Ps framework (pace, predictability, proportionality and process). 

Below are some key practical takeaways for businesses: 

1. Consumer protection - key 2026-27 priority 

The Annual Report emphasises putting “money back in people’s pockets” and consumer protection as key priorities for the CMA. Fake reviews, hidden fees, unfair contracts and exploiting vulnerable consumers with aggressive sales practices are specifically called out as egregious practices the CMA will target this year under the DMCCA. We examine the CMA’s latest investigation into cancellation fees here.

Procedurally, the CMA will be focusing on streamlining and prioritising caseload , greater transparency and providing more information about ongoing investigations and deadlines. Further guidance can be expected to help businesses to comply given the comparative lack of case law in this area.

2. Enforcement – addressing the pro-growth agenda and use of AI as a detection tool

The Annual Plan draws out some key focus areas to support the CMA’s general ambition to remain a strong enforcer and to encourage pro-growth collaboration. The CMA will be using its AI capabilities to actively monitor any unlawful activity: 

• clamping down on bid rigging in public procurement,
• deterring unlawful AI algorithmic collusion,
• progressing investigations under the DMCCA regime which focus on price transparency and misleading online choice architecture, and    
• unlocking public procurement potential, e.g. by working with government to address systemic incumbency advantages that create barriers to growth, particularly in the defence sector. 

The Annual Plan emphasises encouraging legitimate business collaboration and barriers to growth e.g. to enable more interoperability and access to data. The CMA will actively pursue any chilling effects on such collaborations. In particular the CMA will focus on activity within the eight priority sectors identified in the Industrial Strategy: being Advanced Manufacturing, Clean Energy Industries, Creative Industries, Defence, Digital and Technologies, Financial Services, Life Sciences and Professional and Business Services.

The CMA will also use proportionate enforcement tools, including greater use of advisory letters to deter against unlawful conduct.

3. Digital Markets – remedies in search and mobile platforms and more ‘Strategic Market Status’ designations to come

Following the first ‘Strategic Market Status’ designations in respect of search (Google) and mobile platforms (Apple and Google) the CMA is currently working on designing and implement remedies in the UK.  The CMA will continue its work on the digital markets with additional Strategic Market Status designations expected in Q2 2026. 

4. Merger Control – highly targeted application in line with strategic objectives 

The Annual Report confirms the CMA is streamlining the merger process to target only the cases that raise serious competition issues affecting UK markets. We examine this UK-centric merger approach in the context of the government’s recent consultation on refining the UK competition regime here.

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^{1 The Strategy Report coincided with the launch of the CMA’s first major consumer law enforcement actions under the new DMCCA.  We discussed the implications for businesses in our article here.}