The CMA’s final remedies on veterinary pricing: why context must not be lost

By David Harris MRCVS and Susie Samuel MRCVS

The CMA’s final remedies have now been published 

The Competition and Markets Authority has now published the final remedies in its veterinary market investigation. These remedies will be implemented through a formal Order, which will place new obligations on veterinary businesses in areas including ownership transparency, pricing information and consumer choice. 

Much of the discussion has understandably focused on the requirement for standardised price lists. However, the final decision also appears to introduce new limitations on what practices are permitted to say within those price lists, including through paragraph 3.84(d), paragraph 3.92 and footnote 201. 

That is important because there appears to be little or no obvious opportunity to give further feedback on these points before the Order is made. And these are not small drafting details. They go to the heart of whether veterinary price transparency will genuinely help pet owners make better-informed choices, or whether it will remove important context that explains what different practices are actually offering. 

We support price transparency – but not at the expense of understanding 

We support the goal of clearer veterinary pricing. 

Pet owners should be able to see prices more easily, compare providers more effectively and make informed decisions. That is good for consumers and good for a well-functioning market. 

But clarity should not come at the cost of meaning. 

A price list is only useful if a pet owner can understand what sits behind the number. If all meaningful context is stripped away in the name of standardisation, then the result may be a list that is easier to read, but less useful. Ultimately, it becomes a list of numbers with a net loss of transparency, as the pet owner cannot tell what exactly they are expected to pay for. 

The key issue: factual explanation is not “marketing” 

Our central concern is simple. 

There appears to be an assumption in the final remedies that free text used to describe services risks becoming marketing. But where that text is used to explain what is included, how a service is delivered, what facilities are involved or what support surrounds the treatment, that is not marketing in any meaningful sense. It is consumer information, and is necessary to help a pet owner understand and evaluate price – and determine whether or not they are getting value. 

As an example, if you were in the market for a new fridge, and this standardised approach was taken, you would be able to compare price exactly, and you would know if it was large, medium or small; whether it came with an ice box; and how many shelves it had. But you wouldn’t know how efficient it was, how long the power cord was, or what additional features to came with. 

This is directly analogous to the “checklists” for surgical procedures. A pet owner would know what the standard price was for their size of animal, whether sedation, general or local anaesthesia, post-op pain relief, hospitalisation and monitoring, pre-op bloods and post-op checkups were included – but nothing else. In addition, the practice would be under no obligation to state how much those other services cost! So, if GA wasn’t included, the pet owner would have no way of knowing how much the procedure would be! 

Treating all explanatory wording as if it were promotional language risks creating a much narrower and less informative version of transparency. 

Veterinary services are not all delivered in the same way 

This matters because veterinary services can vary by far more factors than a standardised set of checkboxes can capture. 

In our own work collecting prices, some of the most common and basic differences between practices were things like: 

• whether a buster collar was included  

• whether post-operative food was included  

• whether intravenous fluids were included  

These are not covered by the CMA check boxes and are not trivial add-ons. They help explain why one practice’s price may differ from another’s. 

There can also be more significant differences in the way a service is delivered. A procedure may be carried out in a purpose-built, human-standard theatre in one setting and in a more basic environment in another. This is not necessarily a question of one being good and the other bad. It is an example of real differentiation in the market. 

Other issues arise with this limitation too – the CMA specify that the price for a cat spay MUST be for a midline spay. But what if the practice routinely does flank spays? Why do they need to specify the price of a potentially slower and more expensive procedure? 

Likewise, what if a practice routinely offers vaccines containing parainfluenza for dogs, or FeLV for cats? The CMA state that the prices listed must include WSAVA core vaccines – so does the practice list an untrue price (in that it is not what most clients would receive), or look like they are more expensive than a practice which does not offer those options routinely without being able to explain why? 

If practices are prevented from describing these differences, consumers may be left comparing prices without understanding what they are comparing. 

The CMA itself recognises that services cannot be fully standardised 

This is why the wording in the final decision feels particularly difficult to reconcile with the CMA’s own comments elsewhere. 

In paragraph 3.87, the CMA acknowledges that practices take different approaches to providing some services and treatments, and that those approaches cannot be fully standardised because they depend on differing clinical judgements by veterinary professionals. 

If that is accepted, then it is hard to understand how practices can then be prevented from describing what those different approaches are. 

That is not marketing rhetoric. It is core information. Without it, the consumer is being shown a figure without the context required to interpret it properly. 

Consumers should not be underestimated 

We were also concerned by the suggestion that “the average pet owner did not have the technical knowledge to understand the relative value of staff qualifications and descriptions of equipment that might be used as quality indicators for certain treatments.” 

That is, at best, patronising – and at worst, evidence of a profoundly anti-transparency mindset.  

Pet owners do not need to be veterinary professionals to understand that qualifications, experience, facilities, equipment and aftercare may be relevant factors when deciding what represents value.  

Consumers make these kinds of judgements in many other sectors. They are trusted with information and allowed to decide for themselves what matters to them. Some may prioritise price. Others may place greater weight on qualifications, monitoring, facilities or what is included in the package. That is how informed choice works. 

The answer to complexity should not be to withhold information. It should be to present it clearly and honestly. 

“Advanced equipment is not necessarily indicative of quality” is not a sensible reason to suppress information 

Another striking line in the CMA’s reasoning is the suggestion that “factors like advanced equipment were considered by some vets to not necessarily be indicative of quality.” 

That does not seem to us to justify limiting what practices can say. 

Of course advanced equipment is not, on its own, a complete measure of quality. But almost no single factor is determinative on its own. Qualifications are not absolute proof of quality. Experience is not absolute proof of quality. A longer consultation is not absolute proof of quality. None of that makes those things irrelevant. 

The fact that a factor is not always decisive is not a reason to stop consumers being told about it. If anything, it is the opposite. Because no single indicator tells the whole story, consumers need more context, not less, so they can weigh different factors together. 

There is a real risk of flattening the market 

This is not just a theoretical concern. 

If practices are no longer able to explain investments they have made in facilities, equipment, staffing, monitoring or aftercare, the likely effect is to create a market in which those differences become less visible. 

That risks favouring practices that do not offer these things, because higher-priced practices become less able to explain the basis for the difference. 

A provider that invests more heavily in quality-related inputs may then appear simply “more expensive”, rather than “different for a reason”. 

That would be a highly unfortunate outcome. A transparency remedy should not inadvertently penalise practices that invest in their service offering or reduce their ability to explain that value to clients. 

And yes, of course the practice is (rather grudgingly) permitted to state this information elsewhere on their website. But if the CMA (as they claim) wants the pet owning public to do more direct comparisons, then we should make this easier, not harder, for them. 

The concern about “marketing resources” feels out of step with reality 

We were also struck by the apparent concern that allowing free text might advantage those practices with stronger marketing resources, enabling them to attract customers through more persuasive wording. 

That feels like an unusual argument in today’s world. 

We are now in an era in which clear and effective wording can be generated very easily using widely available AI tools. More fundamentally, this line of reasoning appears at odds with how most markets operate. Businesses are generally actively encouraged to explain and describe their services, provided they do so accurately and without misleading consumers. 

The solution to the risk of misleading wording is not to suppress meaningful explanation altogether. It is to require that descriptions are factual, clear and fair. 

Standardisation has value – but only up to a point 

Standardisation can be helpful. It can improve consistency, reduce confusion and make headline comparisons easier. 

But a useful comparison is not one that strips everything back to the lowest common denominator. 

The challenge is to combine: 

• standardised core information  

• with enough factual explanation and context for consumers to understand material differences between providers  

Without that second element, price transparency may become a shallow exercise. Consumers may see the number, but not the value. 

Why this matters for both practices and pet owners 

For practices, the issue is the ability to explain what sits behind their prices. 

For pet owners, the issue is the ability to make a meaningful comparison. 

A price list should not merely show what something costs. It should help someone understand what is included, how the service may be delivered and why one provider may charge differently from another. 

That is not anti-transparency. It is real transparency, as opposed to faux-transparency so as to be seen to do something, whether or not that is actually helpful. 

Our view 

We support clearer veterinary pricing. 

We support easier comparison. 

We support reforms that help pet owners make informed choices. 

But we do not believe those goals are served by limiting practices’ ability to provide factual explanatory information about what their services include and how they are delivered. 

If the final remedies are interpreted in a way that prevents practices from including or placing alongside a price list the context needed to explain material differences in service delivery, that would be a mistake. 

A good market is not one in which all providers are made to sound the same. It is one in which consumers can understand genuine differences and decide for themselves what matters. 

Real transparency is not just about making prices visible. 

It is about making them understandable so that the client can make a real choice, not an artificial selection.  

The pet owner needs to be able to see what they are getting (or not) for their money – not hidden away elsewhere on the website but next to the price. The practice needs the opportunity to explain what the service contains, so that their clients and potential clients can make an informed decision. And that’s why we’re calling on the CMA to review this as a matter of urgency.