The Competition and Markets Authority (CMA) has given veterinary businesses that provide outsourced out-of-hours (OOH) services to first opinion practices until 11:59pm on 23 October 2026 to submit a report confirming they comply with Article 19 of the Veterinary Services Market Investigation Order 2026. The web form guidance was published on 15 October, two days after the CMA issued separate compliance guides for large and small veterinary businesses that care for household pets.
Article 19 has applied since the Order was made in September. OOH contracts must not have notice periods longer than 12 months, and termination fees may only apply where a practice client stops using the service before the notice period ends. Providers must also write to their practice clients about the contract changes by the next working day after 22 December 2026.
The report must be submitted by a chief executive, managing director or senior director of a company or limited liability partnership, or by an owner or authorised individual in a partnership or sole trader. The CMA says a legal representative may not submit it on the business’s behalf. A business that becomes aware it is not complying with Article 19 must tell the CMA within 14 calendar days.
Two timetables
The large business guide covers groups with 15 or more practices and the small business guide those with 14 or fewer. For large groups, the next deadline is the working day after 22 December 2026, when practice information, a standard price list covering 36 defined services, parasiticide prices, pet care plan details, cremation options and prices, and written policies enabling vets to give independent advice under RCVS codes must be in place. Ownership disclosure, prescription fee caps, in-house complaint processes and mediation follow after 22 March 2027, and written estimates, itemised bills and the written prescription measures after 22 June 2027.
Smaller businesses must meet most of the information and complaints requirements after 22 March 2027, with written estimates, itemised bills, the prescription measures and fee caps after 22 September 2027. Both guides require businesses operating practices, OOH centres, crematoria or referral centres to send the RCVS their business and contact details by the end of 30 November 2026.
Fee caps and scope
Both guides set the maximum written prescription fee at £21.40 for the primary prescription and £12.70 for each additional medicine, including VAT, applying until 31 March 2028 and then adjusted annually for CPI inflation. Those figures are higher than the £21 and £12.50 in the CMA’s summary guidance, last updated on 22 September; the new guides do not explain the difference. The large business guide defines household pets as excluding livestock, poultry, equines and animals kept primarily for commercial, agricultural, sporting or working purposes. If businesses do not comply, the CMA says it could work with them to stop a breach, issue directions or impose a financial penalty.
Equanine’s reading
- The 23 October attestation is the first hard compliance test under the Order, and it falls on OOH providers whose contract terms are already in force.
- Equine work sits outside the Order’s definition of household pets, but mixed practices that also treat household pets will carry the compliance workload across the business.
- With two sets of prescription cap figures on GOV.UK, practices repricing written prescriptions have reason to confirm the current numbers with the CMA before changing systems.
