The UK Government has published the final version of its Strategic Steer1 to the CMA, which aims to create a “level playing field” through better regulation2 and, despite recognising the CMA’s independence in the exercise of its statutory functions, appears to discourage CMA intervention to support the Government’s pro-growth strategy “in all areas where the CMA has discretion over which reviews, studies or investigations to commence, and in all cases where the CMA is considering remedies”.3
The final Strategic Steer published on 15 May requires the CMA to conform to the “overriding national priority” of growth. This fits into wider pro-growth initiatives including the creation of a new Regulatory Innovation Office, and the structural changes to the Financial Conduct Authority. Business Secretary Jonathan Reynolds emphasized that economic regulators are “crucial” to the Government’s pro-investment agenda. Sarah Cardell has stressed that the Steer will provide “clarity” on the CMA’s work as it begins enacting the “4Ps approach”: pace, predictability, proportionality and improved process.4
The Steer asks the CMA to focus on transparent, “pro-investment interventions” and on harms that would particularly impact UK consumers and businesses. This includes an expectation that the CMA will try to streamline their investigations alongside other UK and international regulators so that regulatory action is timely, coherent, and avoids duplication. The Steer emphasises collaborative engagement with interested parties to resolve issues quickly, and requires the CMA to seek regular business feedback to ensure it is accessible.
In line with the UK Government’s move to provide greater confidence for businesses, the Government will also consult on legislative reform with the aim of "addressing uncertainty with the existing Share of Supply and material influence tests”.
Speaking on this topic, Sarah Cardell has outlined a more “proportionate approach” that will create less “uncertainty” by separating deals with a direct UK impact from others where “action by other authorities could resolve UK concerns”.5
Next Steps
Whilst the Strategic Steer and the proposed legislative reforms demonstrate a clear effort to promote business certainty, this approach arguably sits somewhat uncomfortably with the changes to the CMA’s thresholds introduced by the Digital Markets, Competition and Consumers Act, which came into force earlier this year and introduced an acquirer-focussed threshold which does not require any UK overlap between the parties and was specifically introduced to prevent “killer acquisitions”. The Steer guides the CMA to use the DMCCA carefully and collaboratively to ensure growth and innovation benefits are prioritised.
The UK Government’s final Strategic Steer signals a shift towards a more predictable and investment-friendly stance, reinforcing the CMA’s commitment to the 4Ps approach to supporting economic growth. By clarifying jurisdictional tests and streamlining CMA interventions, the reforms aim to reduce uncertainty for businesses while ensuring competition. Doug Gurr, the Interim Chair of the CMA, maintains that “good regulation” must support its “broader macro-economic environment”.6 He encourages the CMA to go further and consider changes that “matter to businesses” so that they “choose the UK…as their home”.
This echoes the sentiment of Juliette Enser, the Executive Director for Competition Enforcement at the CMA, in a speech delivered on 15 May where she outlined the CMA’s future enforcement priorities. Among these, she highlighted the need to examine public procurement, an area particularly vulnerable to bid-rigging as well as focusing on the use of AI for detecting suspicious activities. In rolling out the 4Ps in competition enforcement work, Enser emphasised the new statutory duty of expedition in the DMCCA. To conduct work at pace, in many cases the CMA will aim to achieve a change in behaviour without a formal investigation, through warning and advisory letters for example. The CMA will try to use settlement and commitments procedures where appropriate. We may also see more international cooperation between competition agencies, which Enser described as “vital”.7 Turning to predictability, the CMA is investigating which other areas would benefit from CMA advice similar to the ‘Green Agreements’ initiative. This was launched in 2023 to provide competition advice to businesses collaborating to achieve sustainability goals. Enser emphasised that the CMA can help to prevent “competition law having an unnecessary chilling effect on positive, pro-competitive behaviour that [encourages] … innovation”.8
The UK Government is expected to consult on merger control reforms in the coming months in line with its stated aim to address the uncertainty in the existing Share of Supply and material influence tests.9
1See the final Strategic Steer here: Strategic steer to the Competition and Markets Authority - GOV.UK
2The Government’s press release for the Strategic Steer emphasises the importance of the CMA prioritising the creation of a “level-playing field for businesses through more transparent, timely and responsive regulation”. See the full press release here: Competition watchdog gets green light for growth in latest move to back business - GOV.UK
3Strategic Steer to the Competition and Markets Authority, accessed here: Strategic steer to the Competition and Markets Authority - GOV.UK
4See again the Government’s press release: Competition watchdog gets green light for growth in latest move to back business - GOV.UK
5See the 13 February 2025 CMA blog post of Sarah Cardell here: New CMA proposals to drive growth, investment and business confidence – Competition and Markets Authority
6Doug Gurr’s CMA blog post on 30 April 2025: What good regulation looks like and why it matters – Competition and Markets Authority
7Juliette Enser’s speech on 15 May 2025: Competition enforcement – a view from the CMA - GOV.UK
8See above.
9See the Government policy paper of 31 March 2025: New approach to ensure regulators and regulation support growth (HTML) - GOV.UK
