The 2025 UK Government’s Strategic Steer to the CMA: The Beginning of a New Era for the UK Antitrust Watchdog

By: Paul Johnson, Frances Murphy & Leonidas Theodosiou (Morgan Lewis & Bockius)

In this blog post, authors Paul Johnson, Frances Murphy & Leonidas Theodosiou (Morgan Lewis & Bockius) explore the UK government’s recently released draft strategic steer for the UK Competition and Markets Authority (CMA). This document outlines the government’s expectations for how the CMA should approach enforcement, particularly in alignment with the administration’s core economic growth agenda. This article examines the significance of the strategic steer, the CMA’s response, and the potential impact on the authority’s enforcement priorities—especially with the Digital Markets, Competition and Consumers Act (DMCC) set to take effect in April 2025.

The government has launched a consultation on the draft strategic steer, which will remain open until March 6, 2025. Industry stakeholders are expected to respond positively to the proposals, and the consultation’s outcome will influence the CMA’s annual plan for 2025/2026, expected to be published by the end of March.

At the start of each parliamentary term, the government issues a strategic steer to set out its priorities and guide the CMA’s enforcement approach. Although not legally binding, this steer plays a crucial role in shaping the authority’s focus. This year’s steer marks a significant shift, as it diverges from the approach of the previous administration by emphasizing economic growth as a core objective.

The previous government had encouraged the CMA to act as a global thought leader, leveraging its post-Brexit role to influence international discussions and maintain strong independence. In contrast, the new government directs the CMA to prioritize economic growth, align with actions taken by competition and consumer agencies in other jurisdictions, and coordinate regulatory efforts to avoid unnecessary duplication.

This stark difference between the two strategic steers suggests that the CMA’s enforcement priorities and processes may undergo significant changes.

The latest strategic steer aligns with the Labour government’s focus on driving economic growth and directs the CMA to:

• Use enforcement tools proportionately to encourage investment and growth, with a focus on:
  • Pro-growth and pro-investment initiatives
  • Addressing market issues that particularly impact UK consumers and businesses
  • Supporting international competitiveness in the industrial strategy’s eight key sectors
• Coordinate with other regulators by monitoring similar enforcement actions abroad and ensuring that regulatory measures are aligned, particularly in areas such as merger reviews and the implementation of the DMCC regime—which closely mirrors the EU’s Digital Markets Act and is expected to impact many of the same companies, products, and services.
• Foster business engagement and reduce uncertainty by ensuring transparent, predictable, and responsive interactions with businesses. The government also urges the CMA to review its procedural guidance to make it clearer and more accessible.
• Engage with the government on policy alignment, identifying areas where the CMA can support broader government initiatives.

This shift underscores the government’s intent to balance enforcement with economic policy goals, marking a potentially significant evolution in the CMA’s regulatory approach.

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