Disputes
The Competition and Markets Authority revoked nine market investigation orders on 4 November 2026 under its Strategic Markets Review Revocation Order 2026, signed by CMA panel chair Kirstin Baker. The orders, made between 1987 and 2017 under the Fair Trading Act 1973 and Enterprise Act 2002, included the Payment Protection Insurance Market Investigation Order 2011, the Payday Lending Market Investigation Order 2015, the Statutory Audit Services Order 2014, and six further orders covering tour operators, package holidays, new cars, extended warranties, and store cards. The CMA launched its strategic review of 33 remedies on 19 January 2026, published provisional decisions on 12 August 2026, and received five responses before confirming the revocations without modification. Each order was revoked on the basis that a change of circumstances had rendered it no longer appropriate under sections 161 and 162 of the Enterprise Act 2002. The Payday Lending Order had required online lenders to list products on FCA-authorised price comparison websites and provide customers with borrowing summaries; that obligation ceases immediately on revocation.
Why this matters
Mass revocation of decade-old market remedies is rare: the CMA last undertook a similarly broad sweep under the predecessor regime. Revoking the PPI Order matters despite PPI redress being largely exhausted, it removes residual compliance obligations on lenders still subject to the 2011 framework. The Statutory Audit Order revocation arrives as audit market reform continues via the Financial Reporting Council's replacement body, signalling the CMA's view that the 2014 remedy is now superseded. For payday lenders, the removal of mandatory price comparison website listing and borrowing summary requirements reduces compliance cost but raises questions about whether FCA conduct rules provide equivalent consumer protection. The breadth of the review, 33 remedies examined, nine revoked, signals the CMA's intent to rationalise its remedies register and free enforcement capacity for digital markets work under the new DMCC Act regime.
On the Ground
Competition and regulatory lawyers will be advising clients still subject to any of the nine orders that their compliance obligations have lapsed as of 4 November 2026 and that internal compliance programmes should be updated accordingly. Consumer finance and audit practices face immediate client queries on what, if any, FCA or FRC rules fill the gap left by the PPI and Statutory Audit orders. Trainees should pull the Revocation Order PDF and the CMA's Final Decision in the strategic review, map each revoked order against current FCA/FRC rule equivalents, and draft a gap analysis memorandum for affected clients.
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“What does the CMA's mass revocation of legacy market investigation orders mean for firms that were still subject to them, and does it leave any consumer protection gaps?”
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