The CMA has issued the final version of its Annual Plan. In summary, it says that it will drive growth by promoting competition, protecting consumers and enhancing business and investor confidence. 

The Annual Plan describes how the CMA will reflect the new draft strategic steer from the UK government in its activities over the coming year. The draft steer reinforces the importance of a strong, independent competition and consumer protection regime, in the context of the government's mission to enhance growth in the UK economy.

The CMA will go ahead with reviewing pricing and discount claims, customer reviews and green claims, and other practices, to ensure that they comply with new consumer laws, under threat of massive fines, which it will be able to directly impose without the courts.

Focus areas   

The plan includes the CMA's approach to its new powers under the Digital Markets, Competition and Consumers Act 2024.  The digital markets and completion regimes came into force on 1 January and most of the consumer provisions come into force on 6 April.  

The Plan contains details about the CMA's planned early activity in the new digital markets and new consumer protection regimes. The CMA particularly emphasises the value of effective consumer protection to both business and consumer confidence, and says that it will use its enforcement powers proportionately to put money back into people's pockets and protect the level-playing field for fair-dealing businesses.  

The CMA also plans to concentrate its markets work on unlocking investment in critical infrastructure and identifying opportunities for key horizontal enablers (like access to data or technology adoption) which could improve growth. It will also give particular focus to priority sectors in the government's Industrial Strategy (advanced manufacturing, clean energy, creative industries, defence, digital and technologies, financial services, life sciences, and professional and business services).

Consumer protection work

The plan reasserts the CMA's commitment to its ongoing programme of rapid, meaningful changes based around four key principles – pace, predictability, proportionality and process (business engagement). The CMA committed to implementing these '4Ps' across its functions late last year, starting with merger control and recently talked about its approach to enforcing consumer law.

It has now reiterated that at the beginning of April, alongside final guidance, it will publish an 'Approach' document for its new consumer protection powers. This will include information about its enforcement priorities for the first 12 months of the new regime with a focus on the most egregious harms: for example, aggressive sales practices that prey on vulnerability, providing information to consumers that is objectively false, and contract terms that are very obviously imbalanced and unfair.

It says that it is also mindful of the need for predictability, proportionality and strong engagement with businesses as the new regime is launched. Businesses have told the CMA that they want to do the right thing for their customers and many are working hard to ensure they comply. However, smaller companies in particular are concerned that the compliance burden is proportionate and that it is clear what they have to do, especially in areas where the law has been updated or is less clear-cut.  The CMA's final guidance should take these issues into account.