10 Feb 2026
In this letter from Vet Times, UK's leading veterinary charity raises concerns with the CMA around some of its proposed remedies.
As the UK’s leading veterinary charity, operating across 43 pet hospitals and a number of associated clinics, PDSA is dedicated to supporting those pets and people who need our help most. We welcome the Competition and Markets Authority’s (CMA) aim to make veterinary care easier to access, transparent and more affordable.
However, we have raised concerns with the CMA around some of the remedies proposed and the impact they will have on us as charitable providers.
We support transparency and the regulations aimed at improving consumer choice. However, the CMA’s intention to target its remedies at first opinion practices will also impact non-commercial (for example, charities) practices.
These recommendations will significantly impact on PDSA during what are already challenging times. The rise in pet ownership in recent years, set against economic volatility and a spiralling cost of living crisis, means more people are being pushed into financial difficulty. Meanwhile, charities continue to experience growing cost pressures, leading to difficult decisions for some to reduce or withdraw services.
Many of the CMA remedies are aimed at improving choice for clients in the commercial marketplace; however, access to PDSA services is secured through pet owners satisfying specific eligibility criteria when they are unable to afford commercial practice fees, not through market comparisons. The proposed remedies will increase administration and cost burdens for PDSA, but would bring no benefit to the pet owners we help. Furthermore, some of the remedies will also impact smaller independent practices; if their viability and availability is reduced, this could drive demand for charitable care.
PDSA is, therefore, standing with those who are calling on the CMA to reconsider some of its recommendations; crucially, to differentiate between commercial and charitable practices by making it voluntary, rather than mandatory, for charitable veterinary practices to implement the remedies.
The solution is more complex than simply publishing standard price lists. However, for us to do so, outside those we already make available to our clients, adds administrative burden and costs to our charity, but does not resolve the commercial market issues that the CMA is trying to address. Furthermore, including PDSA prices as part of a wider national price comparator will cause confusion, increase demand from ineligible owners, and may drive attempted fraud to access charitable services. This will all place additional strain on valuable charity resources.
The CMA proposes mandatory written prescriptions for ongoing medication unless clients actively decline. PDSA strongly opposes this being applied to our services, where approximately 75% of our patients receive free care and the remainder low cost compared to commercial practices. This would create a major operational burden for PDSA, requiring us to communicate with, and record, the responses of hundreds of thousands of clients unnecessarily, or creating hundreds of thousands of prescriptions, for no added value to the client.
Regarding surveys, we already conduct extensive client surveys. Additional surveys suggested by the CMA would not add any additional benefit to our clients and would not contribute to market assessment by general pet owners, but would increase administrative burden and cost.
PDSA receives thousands of client survey responses annually, with an average 90-plus % satisfaction and 83-plus % net promoter score. Our paying clients’ value for money score (86%) far exceeds the CMA’s metrics for commercial providers (26% at LVGs, compared to 47% at independents); therefore, we do not believe we should be required to do anything further in this area.
The CMA suggests a levy on veterinary businesses to fund regulatory monitoring. Applying this levy to charities doesn’t make sense because the issues being addressed relate to the commercial sector. A levy would take money away from charitable work to the detriment of animal welfare. We suggest a levy should not just depend on size (as proposed), but also whether a practice is charitable or commercial.
We have also highlighted some missed opportunities to the CMA in our response.
Specifically, current prescribing rules (the cascade) prevent vets from considering more affordable human medicine even when clinically equivalent. The cascade requirements have had a negative impact on animal welfare since their introduction and have led to outcomes such as financially driven euthanasia, increased demand for charity services, and suboptimal treatment plans driven by the cost of veterinary licensed products. For context, six medicines alone cost PDSA an extra £370,000 more annually because human equivalent products cannot be used by default.
We have shared our views with the CMA and are keen to collaborate to ensure remedies that will deliver the best possible service and support for as many pets as possible.
We rely solely on donations to fund our work – without which, for some there would be nowhere else to turn. It is imperative that every pound we receive and every minute we have available is spent helping those who need us most and is not needlessly diverted to comply with measures aimed at the commercial arm of the sector.
Yours faithfully, Steve Howard, chief veterinary advisor, PDSA
