The launch of the Competition and Markets Authority (“CMA”) market study into private dentistry represents one of the most significant regulatory interventions in the UK dental sector in recent years. Announced on 5 March 2026, the study reflects growing political and consumer concern about access to dental care, pricing transparency, and consumer decision-making in a market increasingly relied upon by patients unable to obtain NHS treatment.
For dental groups, independent practices, investors and professional advisers, understanding the market study process and its potential consequences is essential. Whilst a market study does not itself determine that competition law has been breached, it can lead to significant recommendations, regulatory reform and, in some cases, a full Market Investigation Reference, carrying extensive powers of intervention.
Why Has the CMA Intervened?
The CMA has stated that it wishes to examine whether the private dental sector is working well for consumers. In particular, it is interested in whether patients can access the information necessary to make informed choices, whether competition between providers is functioning effectively, and whether existing regulatory arrangements adequately support consumer outcomes.
The backdrop to the study is well known. Access to NHS dentistry has deteriorated significantly over recent years, resulting in increasing numbers of patients seeking private treatment. At the same time, private dentistry has experienced substantial consolidation, with corporate groups occupying an increasingly important role within the sector. These developments have prompted questions about pricing, transparency, competition and consumer protection.
What Is a CMA Market Study?
A market study is an examination of how a particular market functions rather than an investigation into alleged wrongdoing by any particular business.
The CMA’s statutory powers permit it to investigate whether features of a market may be preventing, restricting or distorting competition. During a market study the CMA may:
- gather information from market participants;
- obtain evidence from consumers and trade bodies;
- analyse pricing and market structures;
- assess the effectiveness of existing regulation; and
- consider whether further intervention is required.
The study may conclude with recommendations for policy reform, requests for voluntary undertakings, consumer protection initiatives, competition enforcement activity, or a referral for a full market investigation.
Stages of a Market Study
The private dentistry market study commenced on 5 March 2026 and is currently scheduled to conclude with publication of a final report by the statutory deadline of 4 March 2027.
The CMA has already undertaken extensive engagement with consumers, dental professionals, representative bodies, major corporate dental providers and independent practices. In July 2026 it published a significant interim update setting out the progress of the study, responses received and the principal areas of continuing investigation.
As of July 2026, the CMA confirmed that it would continue gathering evidence across the sector and has issued further requests for information, including detailed questionnaires aimed at independent dental practices. This indicates that the Authority intends to ensure that the study reflects the experiences of all parts of the market rather than focusing solely on larger dental groups.
What Has the CMA Learned So Far?
The CMA’s July 2026 update provides the first meaningful indication of how its thinking is developing. Whilst the Authority has reached no formal conclusions and has expressly avoided prejudging outcomes, a number of themes have emerged consistently from stakeholder engagement and consumer feedback.
Among the issues identified are:
- patients’ ability to compare prices and treatment options effectively;
- the complexity of information provided to patients regarding treatment recommendations;
- transparency concerning ownership structures and business models;
- consumer understanding of costs and treatment pathways; and
- the impact of limited NHS access on consumer choice within the private dental market.
The CMA has confirmed that the remainder of the study will focus on five principal themes:
- Consumer journey and choice.
- Competition.
- Conduct.
- Regulatory frameworks.
- Market outcomes.
This is notable because it demonstrates that the study is not confined to pricing transparency alone. Instead, the CMA appears to be undertaking a broad review of how private dentistry functions, how patients engage with providers, and whether existing market arrangements deliver effective outcomes for consumers.
Potential Areas of Concern
Although the CMA has not yet expressed provisional findings, several issues are likely to receive detailed scrutiny:
Price Transparency
Markets operate most efficiently where consumers can compare products and services easily. The CMA is therefore likely to consider whether patients can readily understand treatment costs before making purchasing decisions and whether information is presented consistently across providers.
Information Asymmetry
Dentistry is a classic example of a market characterised by information asymmetry. Patients generally lack the technical expertise required to evaluate treatment recommendations independently and must rely heavily on professional advice. The CMA appears interested in understanding whether patients receive sufficient information to make informed choices and whether decision-making is affected by the complexity of available information.
Market Concentration
The increasing presence of corporate dental groups may prompt examination of local market structures, competitive constraints and barriers to entry. Whilst consolidation is not inherently problematic, the CMA will wish to understand whether market power has any adverse effect on consumer outcomes.
Regulatory Frameworks
The CMA has specifically identified regulatory frameworks as one of its core themes. This suggests consideration of whether existing professional and regulatory arrangements facilitate competition and consumer choice or whether reforms might be desirable.
How Should the Sector Engage?
The study has moved well beyond its initial consultation phase. Stakeholders should expect continued evidence gathering, information requests, consumer research and engagement exercises throughout the remainder of 2026.
Businesses should ensure that they:
- remain aware of developments within the study;
- respond fully and accurately to CMA information requests;
- review pricing and information practices from a consumer perspective;
- consider whether patient communications are sufficiently clear and transparent; and
- monitor possible recommendations that could affect commercial operations.
The CMA’s current timetable anticipates further development of its analysis during late 2026 before publication of its final report by 4 March 2027. Depending on its conclusions, the report could contain recommendations for reform, proposals for further investigation, or other interventions designed to address perceived market concerns.
Looking Ahead
Whilst some observers initially expected the CMA’s attention to focus narrowly on pricing transparency, the July 2026 update suggests a much broader review of the private dental sector. The Authority appears particularly interested in how consumers navigate a market characterised by professional expertise, information asymmetry, increasing corporate ownership and reduced NHS availability.
Whether the study ultimately leads to guidance, voluntary undertakings, regulatory reform or a full Market Investigation Reference remains unclear. However, what is already apparent is that private dentistry remains firmly under regulatory scrutiny. The market study is likely to influence the sector well beyond publication of the final report and may shape policy and commercial practice for years to come
Alexander Hall (dental), Partner
Charlie Markillie (competition), Partner
Knights Plc