Everything you need to know about the CMA price-transparency Order

The deadline (and why it matters)

The Competition and Markets Authority published its final Order on veterinary pricing transparency in early 2026 after an 18-month market investigation into household veterinary services.[1] The headline change: every UK first-opinion practice must publish a structured, machine-readable price list covering the services the CMA has mandated, plus a defined set of disclosures about ownership, terms, and providers.

1. Sep 2026

   CMA Orders binding

   The Order takes legal effect. The CMA has formal enforcement powers from this date, including directions, undertakings, and civil penalties for non-compliance.

2. Dec 2026

   Large groups must comply

   Corporate vet groups (CVS, IVC Evidensia, VetPartners, Linnaeus, Medivet, Pets at Home Vet Group) and any practice owned by a group above the CMA's size threshold must publish a compliant price list across every branch.

3. Mar 2027

   Independents must comply

   Independently-owned practices and small groups have an additional three months. The same rules apply — only the effective date differs.

What happens if you miss the date? The CMA can require corrective action, accept binding undertakings, or escalate to the Competition Appeal Tribunal. In practice, the bigger risk is reputational: the CMA publishes a register of non-compliant practices, and consumer press has signalled it intends to scrutinise vet pricing aggressively in 2027. Search engines and any aggregator that consumes structured pricing data will favour practices with clean, machine-readable price lists, so a missing or broken price list also means missing from the channels prospective clients use to choose a practice.

There's a softer cost too. The CMA's market study found that 84% of pet owners had never compared vet prices before booking, and 76% didn't know whether their practice was independently or corporate-owned. The Order is, in effect, a forced step-change in how the public chooses a vet — the practices that meet the deadline with a polished, well-presented price list will be the ones that benefit from the new shopping behaviour. The ones that ship a barely-compliant table at 11pm on the 31st of March will not.

What the CMA actually requires

The Order is long, but the substance reduces to three obligations: publish prices for a defined set of services, disclose your ownership and material terms, and keep both up to date. Each piece has a specific shape.

Mandated price-list categories

Every practice must publish prices for the seven CMA-defined service categories. The categories below are the floor, not the ceiling — you can add custom categories on top, but the mandated set must be present and complete.

• Consultations. Standard, extended, and out-of-hours, with the consultation fee shown clearly.
• Vaccinations. Core canine, feline, and rabbit primary courses and annual boosters.
• Neutering. Cat and dog castration and spay, by weight band where price varies.
• Dentistry. Scale-and-polish base fee plus the practice's standard extraction tariff.
• Diagnostic tests. Common in-house bloodwork, urinalysis, and imaging.
• Prescription fees. The fee charged for issuing a written prescription, separately from any dispensing margin.
• Cremation. Individual and communal cremation tariffs, including the third-party provider used.

Ownership and funding disclosure

Practices must declare whether they are independently owned or part of a corporate group, and disclose the ultimate parent. This is the CMA's response to the finding that most pet owners did not realise their local practice was group-owned. The disclosure must appear on every page where prices are shown.

Terms transparency

You must publish your cancellation terms, your prescription terms, and a plain-English summary of any health-plan terms before a client signs up. Hiding fees in a long terms-and-conditions PDF no longer counts as disclosure.

The remedies in detail

The Order is structured as a series of numbered Remedies. Remedy 2d — the price-list remedy — is the one most practices need to read closely. The articles below are the ones that catch practices out most often. Every § reference links back to the CMA Final Decision Report on gov.uk.

Cancellation terms — Remedy 2d §6↗

Any non-refundable deposit, late-cancellation fee, or no-show fee must be disclosed up-front and shown on the price list itself, not only in the booking confirmation. The amount and the trigger (e.g. “cancellations within 24 hours”) both have to be visible before a client commits.

Parasiticide inclusion declaration — Remedy 2d §7–9↗

If your health plan includes flea, tick, or worm treatment, you must declare which species and parasites are covered, the equivalent non-plan annual price, and whether the treatment is dispensed in-house or supplied as a written prescription. Naming specific branded products is prohibited — the CMA wants comparable category-level disclosure, so use wording like “a year of broad-spectrum flea and worm cover” rather than a brand name.

Renewal reminders — Remedy 2d §18↗

Health-plan members must receive a renewal reminder at least 30 days before any auto-renewal, with a clear summary of what they will be charged and how to cancel. The reminder has to itemise any price changes since the last renewal and state the new monthly figure.

Health plan price-list link — Remedy 2d §15↗

Where a service is included in a health plan, the published price list must show the equivalent non-plan price for that same service. This anchors any “you save £X with a plan” claim and lets clients compare like-for-like. If you advertise a saving figure, you also need a written calculation basis (§11) and a later-year saving figure where lifetime services dominate the headline number (§10).

Ownership and funding disclosure

Every page of your price list must state whether the practice is independent or part of a group, and identify the ultimate parent. Where the practice is funded by external investors, that must also be declared. The Order is explicit that “family owned” or “locally owned” cannot be used unless literally true at the level of the parent entity.

Mandated fee caps — Remedy 10

Separately from the disclosure remedies, the CMA has imposed price caps on a small set of charges where its investigation found systemic over-pricing — most notably written prescription fees and out-of-hours triage charges. These caps apply regardless of what your published price says. If you display a fee that exceeds the cap, you are non-compliant on two counts: charging above the cap, and publishing an unlawful price.

Common pitfalls

Most practices we audit get the categories right on the first pass. The compliance failures that surface in review tend to come from five recurring patterns.

• Ambiguous “from” pricing. A price shown only as “from £45” with no upper bound or worked example fails the §3 clarity test. Either give a range, a worked typical case, or move the line item to “price on application” with a stated reason.
• Missing VAT clarity. Every published price must state whether it is inclusive or exclusive of VAT. Practices that mix the two within one list (vaccines inc., diagnostics ex.) will be flagged. Pick one convention per list and label it clearly.
• Hidden bundle maths. Vaccination courses advertised as “£65” that turn out to be £65 per visit across three visits will fall foul of the Order. The customer must see the total cost of the course, not just the per-visit fee.
• Undeclared third-party providers. Out-of-hours and cremation are usually contracted to specialist providers (Vets Now, CVS OOH, Dignity Pet Crematorium). The provider name must appear on the price list against the relevant line item, not buried in a separate policy page.
• Draft vs published confusion. The CMA cares about what a client sees on your website, not what sits in your practice management system. A draft price list that has not been published does not count, even if it is technically correct. Make sure your publish step is part of the workflow, not an afterthought.

How Pricebook.vet handles each requirement

Pricebook.vet was built end-to-end against Remedy 2d. Every mandated requirement maps to a feature that’s in the product today.

Frequently asked questions