Competition | UK Regulatory Outlook April 2026

Digital markets 

The Competition and Markets Authority (CMA) continues to exercise the powers granted to it under the Digital Markets, Competition and Consumers Act 2024 (DMCCA). In relation to the three strategic market status (SMS) designations it made last year, the CMA has: 

• on 18 March, closed a consultation on conduct requirements (CRs) in relation to Search. It is likely that relevant CRs will be imposed imminently;
• accepted commitments in relation to some of its concerns in Mobile, requiring that these are implemented by 1 April 2026. These commitments are intended to address the CMA's concerns around the fairness of app review, app ranking and data use as well as objectivity and transparency around interoperability requests;
• carried out a call for evidence, which closed on 22 April 2026, on recent developments in relation to app store rules in relation to fees and design choices. This is ahead of a planned consultation on potential steering measures in the first half of 2026;
• carried out, and continues, an engagement programme on the importance of innovation in the digital wallet sector, with a specific focus on widening access to the near-field communication (NFC) chip with an update expected in the first half of 2026; and
• outlined an expectation to progress work in relation to browsers as well as interoperable access to functionality for connected devices over the course of this year.  

Additionally, on 31 March, the CMA announced a package of actions on business software and cloud services, building on concerns identified in its cloud market investigation. This includes: 

• active engagement with Amazon and Microsoft on egress and interoperability;
• launching a further SMS investigation, currently planned for May 2026. This will be into Microsoft's business software ecosystem and the impact of software licensing on competition in cloud. 

Businesses should remain up-to-date with the CMA's work in digital markets given the economy-wide impact changes to digital products can have. Please see our dedicated page for more details on how Osborne Clarke can support with this. 

CMA annual plan 

The CMA published its final Annual Plan for 2026 on 23 March 2026, detailing how its new three-year strategy (2026 to 2029) will be implemented.  

The overarching goal is to drive economic growth and improve household prosperity through promoting competition and protecting consumers. Five of its principal objectives are: 

1. Promoting effective competition : The CMA will step up action to enable pro-growth business collaboration, particularly for the eight Industrial Strategy priority sectors and environmental sustainability agreements.
2. Championing consumers: Under the enhanced regime introduced by the DMCCA, the CMA will focus enforcement on egregious practices including aggressive sales tactics, fake reviews, hidden fees and unfair contract terms. A private dentistry market study has also been confirmed.
3. Advising government on pro-competition and consumer protection policy: The CMA is expanding its advisory role, identifying opportunities to remove anti-competitive regulation and helping government tackle illegal bid-rigging in public procurement alongside HM Treasury.
4. Fostering investor confidence through the 4Ps: The 4Ps framework (pace, predictability, proportionality and process) will be embedded across all areas of the CMA's work, with a clear commitment that every merger capable of being cleared unconditionally, or with effective remedies, should be.
5. Digital markets: a key priority: Following the first SMS designations, the CMA is designing proportionate interventions including fair ranking requirements for AI-powered search, choice screens on mobile devices, and improved interoperability for fintechs and app developers. The CMA is also monitoring commitments from Amazon and Microsoft to remove data egress fees, deploying AI to detect anti-competitive behaviour, and has announced a new SMS investigation into Microsoft launching in May 2026.  

What changed from the draft plan released on 21 January 2026? 

The core priorities are unchanged from the January draft plan, but notable additions include: a private dentistry market study commitment; collaboration with HM Treasury on bid-rigging; expanded digital markets detail; a reference to agentic AI; and an acknowledgement of geopolitical risk affecting cost of living pressures. 

The bottom line 

The message from the CMA is clear: it wants to be a more agile, proportionate and business-friendly regulator, without softening its resolve to tackle genuine harm. Now is the time for businesses to engage with this evolving regulatory landscape. 

Fast-track market study into domestic heating oil 

The CMA has launched a market study into the retail supply of heating oil for domestic use in the UK, amid concerns about rising prices driven by conflict in the Middle East. 

Heating oil powers around 1.5 million homes across the UK, including almost two-thirds of all households in Northern Ireland. Ongoing conflict in the Middle East is driving up prices for key commodities including oil, leading to sudden and significant increases in the retail price of heating oil. Many consumers have also raised concerns about the terms on which they are supplied heating oil. The CMA has identified an urgent need to examine the heating oil market closely and assess whether it is working well for consumers. 

Unlike other forms of home heating, the CMA notes that the heating oil market is not regulated by Ofgem or the Utility Regulator. This raises several concerns, including lack of protection for consumers suffering financial difficulty and absence of formalised regulations on charging, allowing scope for price discrimination. 

Focus areas 

The CMA will focus on a number of key areas including the impact of a sudden increase in global oil prices on heating oil retail prices and profit margins, as well as the reasons behind retail price rises and any corresponding increase in retail profits. In doing so, it will consider the challenges suppliers have faced in sourcing and maintaining sufficient stock, and how any shortages have affected pricing incentives. 

The CMA will further consider any evidence of poor conduct on the part of suppliers which may harm customers, including during periods of volatile input costs. 

Timeline and next steps 

The study was launched on 20 March 2026 and the CMA aims to publish a report within three months (by June 2026). This is a significantly shorter timeline than usual, given the acute nature of the challenges currently faced by consumers. 

Possible outcomes 

The market study could result in a range of different outcomes. The CMA considers the most likely to be making recommendations to government on regulatory protections or price transparency, or taking direct enforcement action where breaches of consumer or competition law are identified. 

Revision of the EU Merger Rules: encouraging European champions?  

The European Commission is reviewing its Horizontal and Non-Horizontal Merger Guidelines, driven by the need to ensure that European companies can compete effectively on the global stage. Since they were adopted in 2004 and 2008, significant market trends and geopolitical developments including digitalisation, decarbonisation and global market shifts have put the existing framework to the test.  
 
The revised guidelines are expected to place greater weight on innovation, investment and the resilience of the internal market in merger assessment considerations. Notably, corporate deals that drive technological progress, boost research and development and secure access to critical inputs may benefit from a more favourable assessment. 
 
President von der Leyen has been clear about the policy ambition: "merger guidelines that reflect the realities of the global market, not just the European one, and that enable the emergence of true European champions." The EU's competition chief Teresa Ribera has echoed this, while stressing that protecting consumer interests, ensuring a level playing field and preventing abuses by dominant players remains the Commission's core mission. 
 
The review process has been extensive. A call for evidence was launched in Q2 2025, followed by two parallel public consultations from May to September 2025. Stakeholder workshops took place in December 2025 and January 2026, and a high-level conference was held in Brussels in March 2026. A consultation on the draft revised text is expected in Q2 2026, with formal adoption targeted for Q4 2026. 

EU-UK Competition Cooperation Agreement 

On 16 April 2026, the UK Foreign, Commonwealth and Development Office (FCDO) announced that the EU-UK Competition Cooperation Agreement had been presented to Parliament for approval. This agreement will provide a framework for the CMA, Commission and EU Member State national competition authorities to cooperate. 

Notable aspects of the agreement are:  

• the duty on competition authorities to protect the confidentiality of information shared and requiring that the parties' consent is obtained before sharing this information. This is subject to each country's rules on information sharing under applicable domestic law;
• a negative comity agreement requiring the parties to carefully consider important interests of the other during their enforcement activities and a requirement to make "all reasonable efforts" to accommodate each other's important interests; and
• an obligation to review its implementation within two years of coming into force with a view to "further developing their cooperation" in competition law. 

This is likely to affect all businesses, not only those with pan-UK and European operations. That is because both the Commission and the CMA are able to review agreements implemented outside of their jurisdiction as long as they have an impact on competition within their jurisdiction.