RCVS publishes response to CMA's working papers

We have now published our response to the ‘working papers’ issued by the Competition and Markets Authority (CMA) as part of its ongoing market investigation into ‘veterinary services for household pets’.

The CMA published its five working papers on 6 February 2025, setting out its current assessment of the evidence it has gathered so far and its emerging views. The College was given until Friday 21 March 2025 to respond and we submitting a combined response to the five working papers, comprising an overview and then point-by-point responses to relevant areas of the working papers.

In our response, which was developed by our CMA Working Group, we reiterated that we welcomed the market investigation and the opportunity it provided for improved consumer protection. We also welcomed the investigation’s recognition of the important contribution made by veterinary surgeons and veterinary nurses to animal health and welfare and the high trust that the animal-owning public placed in veterinary professionals.

However, our response also noted concerns that the CMA’s investigation still considered the veterinary sector in terms of ‘household services’ and not alongside more comparable markets such as health and social care.

In its overview, our response stated: “This is not a commodity market, but a multifaceted one, which includes complex professions. As a regulator of the standards and conduct of those professions, the role and remit of the RCVS is more closely comparable with other professional regulators, for instance those for solicitors, architects and human healthcare professionals. As such, the RCVS may not fall within the parameters expected by the CMA when compared to regulators that have statutory duties beyond the education, registration, standards and discipline of individual professionals operating in their sector.

“Furthermore… the wider factors at play, around public health, animal health and welfare and, in some cases, planetary health, mean that solely choosing what’s best for the consumer may not be appropriate – in either the short or long term. Balancing all these factors when making decisions is the role of veterinary professionals, and the RCVS is clear to set standards that allow these professionals autonomy, while safeguarding the public interest.

“There is the additional complexity that, due to the NHS, many animal owners are not aware of the prices of human medical treatments. Veterinary care is therefore often considered a quasi-public service – and when costs are quoted, they are often felt to be very high as there is no meaningful comparator. Meanwhile, the vast majority of veterinary work is being carried out by a private market. The provision of emergency cover 24 hours a day is seen by many consumers as a national necessity, but it is provided by private practitioners, who need to maintain the sustainability of that costly service.”

Regarding enhanced consumer protections, our response stated that mandatory practice regulation, which we are currently seeking to implement via legislative reform, would be the best way to achieve this.

Recognising that the legislative change required to make this happen may take some time, we expressed a willingness to work with the CMA on any short-term remedies. Our response stressed that such remedies needed to be proportionate, enforceable, effective, applicable across all veterinary settings, and mindful of the fact that any additional burden on veterinary practices could have the unintended consequence of raising prices to the consumer.

The full RCVS response to the CMA working papers is available to download in PDF format.