The Competition Reform Bill is the next iteration on top of a regime that has already been substantially recast by the Digital Markets, Competition and Consumers Act 2024 (DMCCA). The DMCCA reorganised UK competition law into four interacting layers: (i) the Strategic Market Status regime in Part 1, which gives the CMA bespoke conduct-requirement and pro-competition-intervention powers over firms it designates; (ii) modernisation of merger control in Part 2, including the new hybrid threshold and reformed jurisdictional tests under the Enterprise Act 2002 as amended; (iii) revised Chapter I/II enforcement under the Competition Act 1998, with new penalty-turnover rules under SI 2024/1235; and (iv) consumer protection, including the direct CMA enforcement regime and the statutory ADR scheme under Part 4 Chapter 4.
The SMS layer is the operative novelty: the CMA can designate undertakings with strategic market status in a specified digital activity and then impose conduct requirements without needing a full market investigation. The 2026 designations of Apple and Google in mobile platforms, Google in search and search advertising, and the open Microsoft business software investigation are now the live test cases for how the new framework operates in practice. Appeals route to the Competition Appeal Tribunal under amended CAT Rules (SI 2025/999).
Layered on top is a public-interest merger control regime focused on newspaper enterprises and foreign powers (SI 2025/737, SI 2025/921, SI 2025/922, SI 2025/1351, SI 2026/144). That layer sits in the Enterprise Act 2002 architecture but is operated by the SoS rather than the CMA. It is functionally distinct from competition-only merger control.
The Competition Act 1998 block-exemption mechanism continues to be used to refine the boundaries of permitted horizontal and vertical cooperation: SI 2022/1271 (R&D), SI 2022/1272 (specialisation), SI 2022/516 (verticals) and now SI 2026/369 (technology transfer). The 2026 Order also signals a deliberate refresh of the boundaries against EU block exemption frameworks the UK no longer applies.
Finally, the ADR regime in Part 4 Chapter 4 of the DMCCA represents a structural shift in consumer redress: accreditation of providers, fee-funded oversight, and information reporting are all live obligations from 6 April 2026, with the Chartered Trading Standards Institute as ADR authority. The Competition Reform Bill is being prepared on top of this scaffolding to refine merger-control pace and proportionality, SMS process, and market investigation timelines — themes flagged in the DBT 'Refining our competition regime' consultation.