CMA Complaints Process Rules for UK Vet Practices

What the CMA will require on complaints

Order made; this duty applies from 22 March 2027, for every size of business. The CMA made the Veterinary Services Market Investigation Order 2026 on 22 September 2026, and it came into force the next day. Under Article 3 of the Order, in-house complaint processes, complaint logs and mediation all have a compliance date of 22 March 2027 for larger and smaller businesses alike, and practices must comply from the next working day after that date.

Under Articles 21 to 23 of the CMA Order, your practice will have to run a written in-house complaints process for each practice site, publish it, handle complaints to defined timeframes, keep a complaint log, and take part in mediation when a complaint cannot be resolved in-house. The CMA's guide for small veterinary businesses is explicit that they must "ensure that each FOP or OOH Centre they operate publishes the complaint process on its website".

Most practices already deal with complaints. What the reforms add — here as across the Competition and Markets Authority vet rules generally — is structure: a written process clients can read in advance, fixed timeframes for acknowledging and responding, and a record you can produce on request. This guide turns the requirement into the documents and habits a practice manager needs in place.

The timeframes that matter

The part of the rule most likely to trip a busy practice is the timing. The Order sets three clocks, and the first one decides when the other two start.

• Ten working days to resolve informally. A practice must first try in good faith to resolve a complaint informally. If that fails within ten working days of the complaint being made, it becomes an "Actionable Complaint" (Article 21(2)(b)).
• Five working days to acknowledge. The Order requires "that an Actionable Complaint must be acknowledged in writing by the Veterinary Business within five Working Days of it becoming an Actionable Complaint".
• Eight weeks for the full response, extendable to 12. The practice must send a full letter of response "within a reasonable timeframe and in any event no longer than eight weeks after their Complaint becomes an Actionable Complaint". If it needs longer, it must write to the owner within those eight weeks explaining why and giving a date for the full response. That date can be no later than 12 weeks after the complaint became actionable.

Two things follow:

• Acknowledgement is a near-immediate obligation. Five working days is roughly a week — the acknowledgement has to be a routine, reliable step, not something that waits for the practice principal to have time.
• Log the actionable date. Both later clocks run from the day the complaint becomes actionable, so that date is the one your log must capture. The 12-week limit is a hard outer limit, and using it requires a letter sent inside the first eight weeks.

The full response must show that the practice has understood the complaint and how it reached its conclusions, set out any remedial action offered, and include the RCVS decision tree of redress routes (Article 21(2)(f)). The RCVS is still preparing that decision tree. The CMA's guide says it "will be made available by 22 January 2027". From your compliance date you must also display it on prominently placed signage in reception and on your practice website (Article 21(3)(i)).

When this starts to apply to your practice

Complaints is one of the remedies with no larger/smaller split. Ownership disclosure is another. The Order's Article 3 table gives the in-house complaint process (Article 21), complaint logs (Article 22) and mediation (Article 23) a compliance date of 22 March 2027 for every business.

Two things follow for a smaller practice:

• No extra three months here. Most of this package gives smaller businesses a longer runway; this one does not. 22 March 2027 applies to a single-site practice exactly as it does to a national group.
• You have to choose a mediation provider. Article 23(1) requires each practice to select a specific alternative dispute resolution (ADR) provider offering mediation. The provider must be approved under the ADR Regulations or the Digital Markets, Competition and Consumers Act 2024 and be free for pet owners. Your published process must name it. The CMA's guide adds that "The RCVS has undertaken to contract an ADR provider which meets these requirements and which Veterinary Businesses may choose to use by the next working day after 22 March 2027." You can pick a different approved provider, but the Order's Explanatory Note warns that a practice which does "may need to pay for that ADR service."

What your written process will have to cover

A complaints process that meets the requirement is more than a promise to "take complaints seriously." Article 21(2) lists what it must explain. Build the written document around what a client needs to know up front:

1. How to complain — that owners have a right to complain, and how (email or online form, letter, telephone or in person).
2. What happens next, and when — the ten-working-day informal stage, the acknowledgement within five working days, and the full response within eight weeks, stated plainly.
3. What to do if it is not resolved — that the practice will take part in mediation in good faith if the owner wants to, the name of the approved ADR provider, and the RCVS decision tree.

Publishing this on your website will be the explicit requirement — it will not be enough to hold the process internally and produce it only when a complaint arrives.

The complaint log

Article 22 requires a log of Actionable Complaints for each practice site. As a minimum it must record the date the complaint became actionable, the owner's details, the complaint handler, the acknowledgement date, a summary, the outcome and its date, and any actions taken. The Order's rules on keeping it are specific:

• Keep each entry for at least 12 months from when the complaint was resolved.
• Review it periodically, with a process for doing so, and make reasonable improvements that the review identifies.
• Be ready to hand it over. If the RCVS asks, you must submit your complaint process and a log covering the previous year. That log must use the format in Schedule 4 of the Order and be anonymised as to the vets, handlers and owners involved.

Building it into practice routine

The risk with a complaints process is not writing it — it is keeping the timeframes reliable when the practice is busy. A few controls help:

1. Make acknowledgement a standard step. Assign clear responsibility for sending the written acknowledgement within five working days, so it does not depend on one person's availability.
2. Record the actionable date. The eight-week response clock runs from when the complaint becomes actionable. Capture that date in the log at the point of acknowledgement.
3. Template the response. A house structure for the full response letter, with the decision tree built in, makes the eight-week deadline easier to hit consistently and keeps the tone even.
4. Build the log in the Schedule 4 format from the start. It saves reformatting when the RCVS asks for it.
5. Review the log on a cycle. Fold the periodic log review into your existing clinical governance framework so it actually happens rather than being remembered ad hoc.

How complaints fit the wider CMA package

The complaints process is one of several CMA remedies a practice operationalises together. It sits alongside published price lists, written estimates, prescription transparency and fee caps, and ownership disclosure. Sequencing them is what the CMA preparation timeline is for, and the CMA compliance self-assessment tool flags which remedies your practice still has open. Run as one workstream inside your governance cycle, the package stays manageable for an independent practice.

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Reviewed 26 October 2026. The CMA made the Veterinary Services Market Investigation Order 2026 on 22 September 2026 and it came into force on 23 September 2026. The timeframes, log requirements, mediation duty and compliance date above are taken from the Order itself, not from the draft consulted on in July and August 2026. This is general compliance information, not legal advice. Verify the current position against the Order and its Explanatory Note and the CMA's guide for small veterinary businesses (14 or fewer practices) or large ones (15 or more), and consult your defence body for practice-specific advice.