On 24 March 2026, the Competition and Markets Authority (“CMA”) published its final report on the market for Veterinary Services for Household Pets. The CMA concluded that there are certain features of the market for the retail supply of Veterinary Services for Household Pets by First Opinion Practices (FOPs) in the UK and the supply of outsourced out-of-hours (OOH) provision to FOPs in the UK that prevent, restrict or distort competition, and thereby have an adverse effect on competition
Following the CMA’s report, the CMA has made The Veterinary Services Market Investigation Order 2026 and this is accompanied by Undertakings given by the Royal College of Veterinary Surgeons (RCVS). The Order has just come into force.
Amongst other things, the Order aims to provide the owners of small pets with better pricing information and increased awareness of the ability to purchase medicines online and potential savings. There are also price caps for the provision of prescriptions.
The CMA has published an Explanatory Note to accompany the Order. What follows is mostly drawn from the Explanatory Note.
In the Order, “FOP” is an abbreviation of “First Opinion Practice” and refers to a site or physical premises at which primary veterinary care for Household Pets, comprising FOP Services and any out-of-hours (“OOH”) FOP Services that are provided by the same Veterinary Business.
References to “Articles” are to Articles in the Order.
Parasiticides
Article 8 requires any Veterinary Businesses operating a FOP which sells Parasiticides directly to Pet Owners to publish the prices of the FOP’s most commonly sold parasiticides (a Parasiticide Price List). The purpose of the Parasiticide Price List is to help Pet Owners choose between FOPs, assess the value of Pet Care Plans and facilitate price comparison with third-party retailers of Parasiticides. Article 8(1) provides that the Parasiticide Price List must be published on the website relating to the relevant FOP and in the FOP premises (and meet the display requirements in Article 4). The Parasiticide Price List must be clearly identifiable on the FOP’s website and easily accessible.
It must also be available in physical form in the FOP premises. The Parasiticide Price List must cover each FOP’s Most Common Parasiticides,
The Parasiticide Price List must include: (a) all information required for a Pet Owner to be able to identify each medicine on it, including the full, authorised product name, the brand name, whether it is an own-brand medicine, the active ingredient(s), the amount (volume or number of tablets), the strength and the dosage size. Information about instructions and other ingredients is not required; (b) any charges, such as dispensing or administration fees, that are necessary or applied as standard when purchasing the product at the FOP, and VAT.
The listed prices must be for individual medicine products (with separate prices for products with different formulations, sizes and dosages) and a notice that Pet Owners should consult their Veterinary Surgeon or a Suitably Qualified Person about whether their Pet needs Parasiticide product(s), and if they do, that the Veterinary Surgeon or Suitably Qualified Person will prescribe a specific product or make a recommendation based on their clinical judgement of what is best for the Pet. This information should be prominently displayed alongside the price list, to make clear that it is a list of the prices charged where a medicine is prescribed, not a menu of options for the Pet Owner nor an exhaustive product range. The Parasiticide Price List must be accompanied by a link to the Veterinary Medicines Directorate Register of Online Retailers, to facilitate Pet Owners being able to access potential savings they could make online should they request a written prescription for Parasiticide product(s).
Veterinary medicines
Part 4 of the Order deals with Veterinary Medicines. It contains provisions imposing obligations on Veterinary Businesses which aim to promote greater competition in the sale of veterinary medicines and put downward pressure on high medicine prices.
Pet Owner Awareness of Written Prescriptions
Article 14(1) requires that Veterinary Businesses providing FOP Services must make Pet Owners aware of their ability to request a written prescription, and of potential savings they could make by purchasing a veterinary medicine online or from other third-party retailers. Article 14 does this by requiring the use of standardised literature, messages and notifications across FOPs so that the messaging around the ability to request a written prescription is consistent.
RCVS Written Prescription Literature
Article 14(2) provides that Pet Owners (whether they are new or existing clients of a FOP) must be given a digital or physical copy of the RCVS Written Prescription Literature. The Literature will be produced by the RCVS The Literature will inform Pet Owners about their right to request a written prescription, inform them about the costs of doing so and provide information on where and how written prescriptions can be fulfilled.
Articles 14(6) to 14(9) require Veterinary Businesses providing FOP Services to display a Standard Written Prescription Notice (the Notice) in their waiting room(s) or reception area(s) and in each consulting room, in a Clear and Prominent manner and in at least A3 size.
The Notice will include the applicable and up to date Written Prescription fee at the FOP in which the Notice is being displayed. The Written Prescription fee is the prescription fee charged for providing a Written Prescription for the first medication prescribed within (or outside of) a consultation.
Veterinary Businesses must give Pet Owners a Standard Electronic Message (which reads ‘Written prescriptions are available. See the RCVS website for further information.’) in emails, texts or other electronic communication which confirm or remind them of upcoming consultations.
Oral offers of Written Prescriptions
Articles 14(15) and 14(16) require Veterinary Professionals to make an oral offer to the Pet Owner of a Written Prescription during consultations where non-urgent veterinary medicines are being prescribed and where they are not required to be administered by the Veterinary Professional.
Once a Written Prescription has been requested, the Veterinary Business must either provide a paper copy to the Pet Owner by the end of the consultation or prepare a digital copy of the prescription by the end of the second Working Day following the consultation or, in cases where a request for a Written Prescription is made outside of a consultation, by the end of the second Working Day following the request.
Article 15(2) states that Controlled Drugs are excluded from the requirement to provide digital Written Prescriptions. This is because Controlled Drugs are subject to additional regulations which, among other things, require a wet ink signature on a prescription.
There is an exception to the requirement to provide a Written Prescription where the Veterinary Professional considers there is a clinical need for the medication to be administered by a Veterinary Professional (for example, certain injectables) or for the Pet to start taking it urgently (for example, administering first aid and pain relief).
Own Brand Medication
An Own Brand Medication is a version of a veterinary medicine product that, rather than having the brand name of a manufacturer, has a brand name given by the retailer or distributor of the product. It can be referred to as a ‘private label’ or ‘white label’ product. Each Own Brand Medication has a Reference Product which is clinically identical to it and is available for Pet Owners to purchase from third-party retailers.
Articles 17(1) to 17(4) stipulate that where a Veterinary Business is providing FOP services and a Veterinary Professional is prescribing an Own Brand Medication during a consultation, the following steps must be taken:
(a) the Veterinary Professional must inform the Pet Owner that their Pet is being prescribed an Own Brand Medication and that the Reference Product alternative is available for purchase from third parties such as Authorised Online Retailers;
(b) when the Own Brand Medication is dispensed, the Pet Owner must be provided, in writing, with the name of the Reference Product; and
(c) the labelling which is applied to the Own Brand Medication and on the accompanying invoice must state that the Reference Product alternative is available to purchase from third parties. This labelling does not need to include the name of the Reference Product.
The purpose of these steps is to ensure that Pet Owners being prescribed Own Brand Medication receive enough information that they know they are being prescribed such medication, they are made aware that a suitable alternative is available to them, and they are given the specific name of that suitable alternative to allow them to compare prices.
Where the relevant Veterinary Professional considers that the Reference Product is not appropriate for clinical reasons (for example chewable versus non-chewable tablets or a different bottle or package size is available and preferable for a specific Pet’s needs), a different medication which they consider to be clinically appropriate in the circumstances should be used instead as the comparator product
Maximum fees for Written Prescriptions
Article 18 imposes maximum fees (also referred to as price caps) on the price which a Veterinary Business can charge for providing Written Prescriptions. This is to enable Pet Owners to benefit from lower prices, greater choice and stronger competition when purchasing veterinary medications.
Article 18(1) establishes two price caps. The first cap is on the prescription fee for the first medication prescribed, whether that be within or outside a consultation (the Primary Prescription Fee Cap). The second cap covers each additional medication prescribed in the same consultation or during the same event outside a consultation (the Additional Prescription Fee Cap).
The applicable price caps until 31 March 2028 are:
(a) the Primary Prescription Fee Cap: £21.40, inclusive of VAT; and
(b) the Additional Prescription Fee Cap: £12.70, inclusive of VAT. 25 185.
The price cap figures will be adjusted for inflation on an annual basis using CPI.
The price caps are the maximum amounts which a Veterinary Business can charge for providing a Written Prescription. No additional fees may be charged (for example, additional administration charges for preparing or transmitting a Written Prescription). Veterinary Businesses can charge an amount below the price cap for providing a Written Prescription.
The strength of the medication prescribed or the quantity of medication (eg sufficient tablets to last six months) does not affect the applicable price cap. Both should be chosen by the relevant Veterinary Professional based on the specific clinical requirements in each case.
Veterinary Businesses providing FOP and OOH services must put certain policies and procedures in place to ensure there is no difference between the duration that a medication would be prescribed for when it is supplied in a FOP or OOH Centre and when it is issued as a written prescription. This is to avoid written prescriptions being issued for shorter periods than what is offered in Practice, undermining a Pet Owner’s ability to make savings from purchasing medication elsewhere. As per 18(3), this requirement does not apply where Controlled Drugs are prescribed.