On 4 November 2026, the Competition and Markets Authority (CMA) published its final decision in its strategic review of markets remedies, revoking nine orders that had been in force for decades across multiple consumer-facing sectors. The orders removed include the Payday Lending Market Investigation Order 2015, the Payment Protection Insurance (PPI) Market Investigation Order 2011 (as varied in 2018), the Statutory Audit Services Order 2014, the Store Card Market Investigation Order 2006 (as varied in 2011), the Supply of Extended Warranties on Domestic Electrical Goods Order 2005, the Supply of New Cars Order 2000, two Foreign Package Holidays orders from 2000 and 2001, and a Restriction on Agreements and Conduct (Tour Operators) Order from 1987. The revocations are consolidated into the Strategic Markets Review Revocation Order 2026, which came into force on the date of publication. The CMA launched this strategic review in January 2026, covering 33 remedies made between 1987 and 2017 under either the Fair Trading Act 1973 or the Enterprise Act 2002. Following a provisional decision in August 2026, the CMA received five responses and made no modifications before confirming the final decision. The CMA determined that, in each case, a change of circumstances had taken place rendering the original remedy no longer appropriate. The payday lending order had required online lenders to publish product details on FCA-authorised price comparison websites and to give customers borrowing summaries, obligations the CMA concluded were overtaken by subsequent market and regulatory developments. The PPI order similarly addressed a market the CMA judged had materially changed since the original investigation. The statutory audit order is also among those removed.
Why this matters
The simultaneous removal of nine long-standing remedies, spanning financial services, consumer retail, and professional services, is a significant deregulatory signal from the CMA and reflects its published priority of reducing regulatory burden where markets have shifted. The revocation of the payday lending and PPI orders is particularly notable: both arose from contentious investigations that generated major compliance obligations across the financial services sector and were closely watched by consumer groups. For firms previously subject to these orders, the removal of compliance obligations reduces cost but also removes a formal framework that shaped pricing transparency behaviour. The strategic review approach, covering 33 remedies at once, also sets a precedent for how the CMA may manage its growing legacy remedy estate going forward.
On the Ground
Competition law practices at firms advising financial services clients will need to review whether any clients were subject to the now-revoked orders and confirm obligations have formally lapsed. The revocation of the audit services order may prompt activity in the statutory audit sector. Regulatory compliance teams will update client compliance programmes to remove obligations tied to the payday lending and store card orders. A trainee on this matter would prepare compliance gap analysis memos identifying which specific obligations have been lifted, update internal regulatory filing trackers, and draft client briefing notes summarising the practical effect of each revocation for affected sectors.
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“Why would the CMA revoke remedies like the payday lending order now, and what does this mean for firms that had built compliance programmes around them?”
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