United Kingdom

The CMA is the primary competition authority, with sector regulators (Ofcom, Ofgem, Ofwat, FCA) having concurrent powers. The Competition Appeal Tribunal (CAT) hears appeals and private damages claims.

Chapter I of the Competition Act 1998 prohibits agreements preventing, restricting, or distorting competition. Cartels are subject to civil fines and criminal prosecution under the Enterprise Act 2002 (dishonesty element removed by ECIA 2013).

Post-Brexit, the UK has its own Vertical Agreements Block Exemption Order (VABEO) effective June 2022. RPM remains a hardcore restriction. Most favoured nation (MFN) clauses in online platforms are restricted.

Chapter II prohibits conduct by dominant undertakings amounting to abuse. Dominance typically found at >40% market share. CMA has investigated excessive pricing (Pfizer/Flynn pharma) and exclusionary practices.

Voluntary merger notification regime (no mandatory filing). CMA can review mergers meeting share of supply test (25%+) or turnover test (target UK turnover >GBP 70m). Two-phase review: Phase 1 (40 working days) and Phase 2 (24 weeks). DMCCA 2024 introduced new thresholds and acquirer-focused safe harbours.

CMA offers Type A (no-knowledge immunity), Type B (existing investigation, up to 100% reduction), and Type C (discretionary reduction up to 50%). Criminal immunity for individuals also available.

CMA has settlement procedure offering up to 20% fine reduction. Commitment decisions available where CMA has reasonable grounds for infringement. Enhanced commitments regime under DMCCA 2024 for digital markets.

Civil fines up to 10% of worldwide turnover. Criminal cartel offence carries up to 5 years imprisonment and unlimited fine. Director disqualification orders available.

DMCCA 2024 creates a new digital markets regime. CMA can designate firms with Strategic Market Status (SMS) and impose tailored conduct requirements. Pro-Competition Interventions (PCIs) for structural changes. Fines up to 10% of global turnover for non-compliance.

Concurrent enforcement powers shared between CMA and sector regulators: Ofcom (telecoms/media), Ofgem (energy), Ofwat (water), FCA/PSR (financial services), NHS Improvement, ORR (rail), CAA (aviation).

CMA has extensive investigative powers including dawn raids on business and domestic premises (with warrant). Power to require documents and information. Digital forensics capabilities. Obstruction can result in criminal prosecution.

The CAT handles both standalone and follow-on damages claims. Collective proceedings regime introduced in 2015 (opt-in and opt-out). Several major class actions filed including against Apple (App Store) and Mastercard (interchange fees, GBP 14bn claim).

CMA has bilateral cooperation arrangements with the EU, US (DOJ/FTC), and other authorities. Active in ICN, OECD, and Five Eyes competition discussions. Post-Brexit cooperation with EU DG Competition continues informally.

Major focus on digital markets and implementation of DMCCA 2024. Active merger enforcement (Microsoft/Activision conditional approval). AI foundation models market study. Cloud computing investigation. Pharma pricing enforcement.