United Kingdom: Implemented CMA digital markets competition regime guidance

On 1 January 2025, the Competition and Markets Authority’s (CMA) guidance for the operation of the digital markets competition regime under the Digital Markets, Competition and Consumers (DMCC) Act 2024 enters into force. The guidance outlines the criteria and processes for designating firms with Strategic Market Status (SMS), imposing conduct requirements, and implementing pro-competition interventions. SMS designation applies to firms operating in the UK that exceed turnover thresholds of GBP 25 billion globally or GBP 1 billion domestically, demonstrate entrenched market power, and hold strategic significance. The designation process involves a nine-month evidence-based assessment with public consultations and stakeholder engagement, with SMS status lasting five years and subject to review before renewal. Conduct requirements promote fairness, transparency, and competition, while pro-competition interventions address market harms through remedies or recommendations after a similar review. Non-compliance can result in penalties of up to 10% of global turnover, determined by severity and proportionality.