Ryanair Fails to Block CMA Information Notices as High Court Refuses Interim Relief and Adjudicator Rejects Procedural Complaint
The CMA's consumer protection enforcement investigation into Ryanair has cleared two significant procedural hurdles, with the case page updated on 30 September 2026 to reflect both developments. On 5 August 2026, Ryanair issued proceedings in the Administrative Court seeking permission to judicially review the legality of information notices sent by the CMA. Simultaneously, on 6 August 2026, the airline applied for interim relief (a temporary court order suspending its obligation to comply with parts of those notices and preventing the CMA from imposing fines for non-compliance while the judicial review ran). The Administrative Court refused that application on 10 August 2026, meaning Ryanair remained obligated to respond to the CMA's information requests. Separately, on 6 August 2026, Ryanair complained to the CMA Procedural Complaints Adjudicator (PCA), arguing the CMA had wrongly refused to pause the compliance deadline. On 30 September 2026, the PCA published a decision concluding the complaint fell outside its remit: Ryanair had not first raised concerns with the Senior Responsible Officer, the complaint went to the legality of the notices (not the ability to comply), and Ryanair was simultaneously litigating the same issue in court. The underlying investigation, opened on 10 June 2026, concerns a potentially unfair mandatory fee and how it is presented on Ryanair's UK website. A 'rolled up' hearing (covering both the permission question and, if permission is granted, the substantive judicial review) has been listed for 24 to 26 November 2026. The investigation's information-gathering phase runs to December 2026.
Why this matters
Ryanair's dual-track challenge (judicial review plus a PCA complaint) represents an aggressive litigation strategy to neutralise the CMA's investigative tools before the agency can build its enforcement case. The Administrative Court's refusal of interim relief and the PCA's rejection of the procedural complaint both preserve the CMA's ability to gather evidence without pause, maintaining the regulator's investigative momentum. The November 'rolled up' hearing will be the first substantive test of whether the CMA's information notices were lawfully issued, and the outcome will matter beyond aviation: it will signal how courts weigh a regulator's information-gathering powers against a company's right to challenge those powers before complying. If Ryanair succeeds, it will embolden other companies to mount pre-compliance judicial reviews as a delay tactic.
On the Ground
The matter engages public law, consumer protection enforcement, and regulatory litigation practice areas. The legal work on Ryanair's side involves judicial review proceedings in the Administrative Court and managing parallel procedural avenues, while the CMA's external counsel (not named in the sources) focuses on defending the legality of the information notices and the enforcement framework. For any firm advising a regulated business facing a CMA information notice, this case illustrates the limits of interim relief as a blocking mechanism. A trainee on this matter would assist with drafting regulatory notification responses, preparing a compliance tracker for the statutory timetable, and indexing court filings and Administrative Court orders for the trial bundle ahead of the November hearing.
Interview prep
Question you might get
“How would you advise a corporate client that has received a CMA information notice it believes was issued unlawfully, and what does the Ryanair case tell us about the limits of challenging that notice before complying?”
Sign up free to see the full answer
A model answer you can lift into an interview — how to frame this story for a partner.
Sign up freeMy notes
saved