BSAVA responds to CMA working papers

27 March 2025

BSAVA has jointly responded (Friday 21st March) to the five ‘working papers’ published by the Competition and Markets Authority (CMA) in February which outlined their current assessment and emerging views as it continues its Market Investigation into UK veterinary services for household pets. We collaborated with the British Veterinary Association (BVA), the British Veterinary Nursing Association (BVNA), the Society of Practicing Veterinary Surgeons (SPVS) and the Veterinary Management Group (VMG), to provide our current views on the CMA’s outputs to date.

The working papers show that the CMA has recognised the professionalism and commitment of individual vets and that 88% of owners considered their vet focusses on the highest standard of care for their pets. They also demonstrate that the CMA recognises the significant changes our sector has undergone over the last 10-15 years and that it has been listening to the concerns raised by BSAVA and other veterinary bodies in understanding the complexities of the veterinary landscape and how services are delivered by veterinary professionals.

We support the CMA’s view that for animals to be well cared for we need a thriving veterinary sector, staffed by capable veterinary professionals who provide satisfactory services for clients. We also support healthy competition, consumer choice and a diversity of business models that enable clients to select from a wide range of veterinary service providers, whether corporates or independents, so ensuring the best option for their needs and for the health and welfare of their animals.

As part of our response, we asked that any proposed remedies are carefully considered and introduced in a way that allows businesses to adapt, as well as avoiding any unintended consequences. Overall, we recognise the need for change and we are keen to play our part in supporting a well-functioning market.

BSAVA highlighted the key points covered in our joint response during its formal Hearing with the CMA Inquiry Group on 14th March, which it attended alongside BVA, BVNA, and the Federation of Independent Veterinary Practices (FIVP). The Hearing was an opportunity to represent our profession and provide evidence on some key points including transparency, medicines and veterinary regulation, with a view to influencing the CMA’s thinking before it publishes its proposed remedies.

We have briefly outlined below some of these key points which reflect the joint contributions made to the CMA by all the veterinary organisations mentioned above.

Transparency and client choice

  • We agree there is a lack of available and comparable information available to pet owners on price, quality or business ownership. Information about the ownership of veterinary businesses should be provided to clients in the terms of business and be readily available both on the practice website and at the practice premises.
  • Transparency around costs, the true value of veterinary care and also, contextualised care, are all components that support client choice. We support further guidance on contextualised care and also, a shift towards new models of pet healthcare plans which focus on a tailored approach rather than dispensing products routinely.
  • The way in which veterinary care is delivered and valued is far removed from the way consumers behave when shopping around for more ‘transactional’ services such as insurance or utilities. Clients who switch practices frequently risk fragmented care for their pet, potentially leading to suboptimal treatment and communication, and additional costs.
  • On issues relating to the provision of affiliated services, we consider that:
    • For referrals, explanatory resources for clients could be developed, to include greater clarity around the qualifications of the referral vet;
    • Cremation services associated with the practice and if owned by the same company, should be clearly communicated as such to clients;
    • For OOH services, we would strongly advise against any remedies which would result in business models that are commercially unviable to deliver due to insufficient demand, set against the challenge of modern working practices and recruiting, to cover an OOH rota in addition to the normal daytime provision.

Medicines

  • To facilitate choice around medicines, there should be a consistent approach by practices to proactively offer a prescription where clinically appropriate, provide clients with dispensing options and ensure clarity around communicating the cost of a prescription.
  • We consider that practices should clearly display the fees most commonly associated with administering and dispensing medicines to help clients make informed decisions.
  • We strongly support vets being able to retain their professional autonomy in matters of responsible prescribing and dispensing.
  • There is a role for RCVS and VMD in providing improved clarity around the application of the Cascade to support vets in decision-making.

Regulatory framework

  • Mandatory practice regulation should be introduced as part of veterinary legislative reform.
  • For veterinary professionals, more could be done to promote the RCVS Code and its application.
  • Registered Veterinary Nurses (RVNs) could be more fully and effectively utilised within existing legislation. Extending the range of tasks that RVNs are permitted to undertake, with appropriate additional training and supervision, could offer positive benefits for all parties.
  • A formal, agreed and consistent complaints process for the veterinary sector, that is both pragmatic and proportionate, should be introduced. There is also scope for better promotion of the Vet-Client Mediation Service (VCMS).

To view the joint response to the CMA’s working papers in full, please access the following link www.bva.co.uk/media/6299/bva-bsava-bvna-spvs-vmg-joint-response-to-cma-working-papers.pdf