The CMA’s Market Study into Private Dentistry: What does it mean for the Dental Sector?

The UK’s Competition and Markets Authority (CMA) recently launched a major market study into private dentistry. Having previously conducted similar market studies in veterinary services and funeral services, the CMA’s spotlight has now shifted over to private dentistry.  The pattern appears to be the CMA looking closely at fragmented markets where there is often rapid private equity driven consolidation.  

So, what is the market study all about and what could it mean for the dental sector?  

What the Review Is About

At its core, the review seeks to determine whether the private dentistry market is working effectively for consumers. Specifically, the CMA is examining:

• Access to services: How easy is it for patients to find and switch dentists?
• Pricing and value: Whether price increases are justified and transparent.
• Consumer understanding: Whether patients can make informed choices.
• Competition dynamics: How providers compete locally and nationally.
• Business conduct: Whether practices engage in misleading, unfair, or anti-competitive behaviour.
• Complaints and redress: Whether patients can effectively resolve disputes.  

The study is not limited to headline pricing; it will also explore the entire patient journey, from initial search and consultation through to treatment decisions and aftercare.

Importantly, this is not yet a formal enforcement exercise. A market study allows the CMA to gather evidence and, if necessary, escalate to a full market investigation following which the CMA could impose a range of remedial measures to counteract any adverse effects on competition or harm to consumer interests.  The market study will involve a detailed information gathering exercise - from businesses, consumers and stakeholders across the dental sector.

Why the Review Is Happening

1. Rapid Growth of Private Dentistry

   Demand for private dentistry is on the increase and its growth has been driven in large part by limited access to NHS dentistry, forcing many patients into private care.

2. Rising Prices and Cost-of-Living Concerns

   The review follows significant price increases in both initial consultations and routine check-ups. These increases have triggered political concern, particularly in the context of the broader cost-of-living crisis. In November 2025, Rachel Reeves explicitly requested the CMA’s involvement, citing issues such as “hidden costs, lack of transparency and overtreatment.”

3. Concerns About Transparency and Consumer Harm

   Government and regulatory attention has been sharpened by allegations of:

   • Opaque pricing structures.
   • Upselling or overtreatment.
   • Difficulty comparing providers.
   • Barriers to switching dentists.

   These concerns suggest a classic competition law problem where consumers cannot make effective decisions due to lack of clear or comparable data.

4. Structural Changes and Market Consolidation

   The sector has also seen increasing corporatisation and consolidation, with large dental groups and private equity-backed platforms expanding their footprint.

   This raises questions about whether local competition remains effective, particularly in areas where a small number of providers dominate, giving them more concentrated market power and leading to less choice for consumers.

Key Legal and Regulatory Issues

The CMA’s review engages various core areas of UK competition and consumer law.

1. Consumer Protection Law

   A central issue is whether dental providers comply with consumer protection rules, including:

   • Clear and upfront pricing.
   • Honest representation of treatment necessity.
   • Transparency around alternatives and risks.

   If practices are found to engage in misleading actions or omissions, they could face enforcement under consumer protection legislation.

   Dentistry is a classic example of a sector where consumers rely heavily on professional expertise to assess what treatment they need.

   This creates legal and economic risks:

   • Patients may not be able to judge whether treatment is necessary.
   • Providers may have incentives to recommend higher-value procedures.

   The CMA is likely to examine whether this dynamic leads to systematic consumer detriment. It has said it will consider whether the current regulatory framework is fit for purpose.

2. Competition Law and Market Power

   The CMA is examining whether competition between dental providers is delivering:

   • Competitive pricing.
   • Innovation and quality improvements.
   • Meaningful consumer choice.

   Local market concentration will be a key focus. Even if national concentration appears modest, concerns over a lack of competition may arise where localities are served by just one or only a very small number of providers.

What the CMA Seeks to Uncover About The Patient Experience

A defining feature of this review is its strong emphasis on the patient experience.  

1. Decision-Making and Choice

   The CMA is investigating how patients:

   • Find a dentist.
   • Compare providers.
   • Decide between treatment options.

   The concern is that complexity and lack of information may prevent effective choice.

2. Understanding of Pricing

   Patients often face:

   • Unclear pricing before treatment.
   • Unexpected additional costs.
   • Difficulty comparing like-for-like services.

   The CMA wants to understand whether patients can accurately anticipate total costs before committing to treatment.

3. Perceived Necessity of Treatment

   The CMA is exploring:

   • Whether patients feel pressured into treatments.
   • Whether they understand alternatives.
   • Whether recommendations are perceived as clinically justified.
4. Access and Availability

   The review will also consider:

   • Geographic disparities in access.
   • The ability to switch providers.
   • Availability of urgent care.

   These factors are particularly relevant given the spillover from NHS access constraints.

5. Complaints and Redress

   The CMA is examining whether patients can:

   • Easily raise concerns.
   • Obtain refunds or corrections.
   • Navigate dispute resolution systems.

   Weaknesses here may indicate broader consumer protection issues.

Implications for Corporate Acquirers and Investors

The market study could have significant implications for corporate dental groups, private equity investors, and prospective acquirers, particularly if the CMA goes on to launch a formal market investigation and order remedies to correct any problems it finds with the way the market is operating.

1. Increased Regulatory Scrutiny of Roll-Ups

   The CMA will look at how profitability is driven by corporate structures and financing models. It has shown growing interest in “roll-up” strategies, where investors acquire multiple smaller businesses to build scale.

   In dentistry, this could trigger scrutiny of:

   • Local market concentration post-acquisition.
   • Reduced competition in specific geographic areas.
   • Pricing alignment across group practices.
2. Pressure on Pricing Models and EBITDA Assumptions

   Private equity-backed dental groups often rely on:

   • Pricing optimisation.
   • Treatment mix (including higher-margin cosmetic procedures).
   • Operational efficiencies.

   If the CMA identifies excessive pricing or opaque fee structures, this could lead to:

   • Pricing transparency requirements.
   • Price caps or other pricing regulation.
   • Downward pressure on margins.

   This could have a knock-on effect on valuation models and exit strategies.

3. Compliance and Operational Costs

   Corporate groups may face:

   • Enhanced compliance requirements.
   • Investment in pricing transparency systems.
   • More robust consumer communication processes.
   • More exposure to competition from other providers.

   These changes could increase operating costs and reduce profit margins for corporate groups.

4. Due Diligence and Transaction Risk

   For all acquirers, the CMA’s market study has highlighted the importance of due diligence on:

   • Historical pricing practices.
   • Complaint volumes and dispute handling.
   • Marketing and patient communication materials.
   • Local competition dynamics.

Conclusion

The CMA’s market study into private dentistry reflects a broader shift in regulatory focus toward essential consumer services that increasingly operate on private, market-driven models.

At one level, the review is about pricing transparency and competition. At another, it is about something more fundamental: whether patients, often with limited alternatives, are able to make informed, confident decisions about their healthcare.

For corporate operators and investors, the message is clear. The sector’s growth and consolidation have brought it squarely into the CMA’s field of vision. 

For patients, the outcome could be a more transparent and accountable system.

The CMA’s market study is to be concluded by March 2027.  Interested parties now have a window of opportunity to comment on the study and make representations by 2 April 2026.  The CMA wants to hear from various stakeholders across the dental sector, including consumers, corporate groups and independent practices.  

The timetable is as follows:

• March 2026 to early September 2026 - evidence gathering and analysis (including commissioning of research, industry roundtables and meetings with stakeholders, market data analysis, working with government and regulatory bodies).
• October to November 2026 - consultation on outcomes.
• Final report scheduled to be published by 4 March 2027.

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