Ricardo Zimbron

The UK Competition and Markets Authority (CMA) announced on Wednesday that it has opened three new consumer protection investigations into Trainline, Virgin Atlantic, and RED Driving School over concerns that mandatory fees were not included in the headline prices.[1]

The following is part of our annual publication Selected Issues for Boards of Directors in 2026. Explore all topics or download the PDF.


Antitrust in 2025 was marked by policy developments and enforcement that, while remaining aggressive, became less overtly anti-business. The U.S. continued several Biden-era cases but became more open to settlements, while maintaining the new and more burdensome HSR merger notification form and the more aggressive and less economically focused 2023 Merger Guidelines. It also faced leadership uncertainty, particularly at the DOJ. The European Commission conducted DMA enforcement actions and launched a broad consultation on the Merger Guidelines. The UK CMA shifted toward a more restrained approach, taking greater account of growth and signaling flexibility in merger remedies. China’s SAMR began intervening in transactions below filing thresholds and continued using antitrust as a tool amid geo-political tensions.

2025 was a fascinating year for UK competition and consumer enforcement, with the CMA changing its policies and practices in a number of areas. Our Year in Review summarises the most important developments of the past year and what we expect in 2026, as the CMA implements its reworked procedures for merger and market cases, begins to use its new consumer fining powers, and imposes digital conduct requirements for the first time. We also anticipate a Government consultation on significant changes to the decision-making model for mergers and markets.

The Competition and Markets Authority (CMA) has launched a significant consumer protection drive targeting online pricing and sales practices across the economy. This represents the first major enforcement effort under the sweeping powers granted by the new Digital Markets, Competition and Consumers Act 2024 (DMCCA). For an overview of the changes brought in by the DMCCA, see our related blog post here.

On 16 October 2025, the CMA launched a public consultation on its draft revised Merger Remedies Guidance (the Draft Guidance).[1]  The revision reflects the Government’s call for a more business-friendly, pro-growth approach to merger control.[2]

The long-awaited consumer protection reforms brought by the Digital Markets, Competition and Consumers Act (DMCCA) are here and set to transform consumer protection in the UK. As of April 6, the CMA can directly enforce consumer law breaches, rather than having to go through the courts to establish an infringement. The CMA sees the changes brought about by the DMCCA as an “opportunity to do [our] consumer protection work more effectively, more quickly and—hopefully—with even better outcomes for people in the UK”.[1] The CMA’s goal is to establish a robust and independent consumer protection framework that not only shields UK consumers and builds their trust but also ensures fair competition by creating a level playing field for businesses. The expectation is that this dual approach of safeguarding consumer interests and promoting fair business practices will, in turn, boost both consumer and business confidence, ultimately driving growth within the UK economy and fostering effective competition.[2]

The UK Competition and Markets Authority (CMA) has cleared the Vodafone/Three[1]merger subject to behavioural remedies. The transaction will bring together two of the four largest UK mobile network operators and potentially transform the UK telecoms landscape. The CMA’s approval decision comes against the backdrop of widespread scepticism of consolidation in the mobile telecommunications sector across Europe.  It also departs from the CMA’s previous policy of seeking structural remedies to address competition issues and blocking problematic deals where no structural remedy could be found.