How will the potential CMA investigation impact the private dental market?

Paul Graham, managing director of medical at Christie & Co, explores what the recent Competition and Markets Authority’s (CMA) review into private dentistry could mean for the future of the sector

The CMA has now begun its initial exploratory work, and, should a formal investigation evolve, this could harm private dentistry, a sub-sector that is ultimately the backbone of patient access in the UK.

After years of severe strain on NHS dentistry, with little meaningful government action to reform contracts, improve access, or stabilise the workforce, the private sector has effectively become the safety net.

For many operators, the rise in private provision is not a strategic land grab, but a forced duty to an NHS system that is no longer functioning sustainably.

Against this backdrop, scrutiny of the private sector without addressing NHS underfunding appears to be imbalanced.

I’ve spoken to CEOs leading predominantly-private groups, organisations that have diversified into NHS delivery over the past 18 months, and others who feel rattled by the timing of the announcement for the same reasons I’ve outlined above.

Interestingly, several senior dental teams with leaders who previously worked in the veterinary sector appear more relaxed.

Having adapted to the recent CMA outcome in veterinary services, they recognise that greater transparency in pricing and communication is both reasonable and achievable.

They also note that the veterinary investigation ultimately focused on transparency rather than heavy structural intervention.

One important contextual difference between the dental and veterinary markets is the level of corporate consolidation.

Dentistry, by contrast, remains far more fragmented.

Even the largest dental groups account for only a modest portion of total practices, and most of the market is still made up of independently-owned clinics.

So, dentistry’s structural fragmentation makes concerns around dominance or restrictive competition far less applicable.

It also potentially dilutes other components that could be contained within the CMA’s ‘market study’.

This context is essential as there is no question that market share in dentistry remains widely dispersed.

What will the regulatory body scrutinise?

The CMA will most likely analyse these three criticisms:

• Pricing transparency
• Practice data on volume of private treatments offered
• Patient communication and data records regarding NHS versus private options offered

The private sector underpins access in many communities throughout the UK, absorbing unmet patient needs, and often the only route to timely care as NHS capacity declines.

In addition, private dentistry is pivotal in the following three areas:

• Workforce retention – enabling clinicians and nursing staff to remain attracted to working in the UK system
• Treatment range – clinicians can deliver superior oral care and education to patients, the majority of which are not routinely funded by the NHS
• Technology advancements – private dentistry is at the forefront of being viable enough to adopt new technologies, ultimately benefiting consumer outcomes

Investors may extend due diligence and closely examine pricing, governance, and communication practices.

Based on the veterinary market outcome, transparency, not price caps, is the likely direction.

This could ultimately enhance investor confidence. 

What are the potential risks to private dentistry?

• Workforce shortages: Operators face a limitation on oral care delivery, not defined by capital or demand, but by the lack of clinical labour in the market. A lot of effort is being invested to address and improve this
• Over-regulation: This could be harmful to the sector. We’ve already seen that in general practice and primary vare with an increase in administrative workload. This could drive smaller dental providers out of the market, resulting in more ‘dental deserts’
• NHS Contract funding is being frozen in time: The significant cost inflation, especially over the last three years, has left some NHS contracts non-viable and structurally loss making, especially for high-cost regions and practices with recruitment challenges. This is essentially accidental privatisation

What are the possible opportunities for the sector?

• Better patient outcomes and productivity through digitisation and AI diagnostics
• An opportunity to lead the charge in prevention. Consumer expectations are shifting toward wellbeing, longevity, and proactive health
• Meaningful contract reform, not just adjustments around the edges of an outdated NHS contract

Private providers have stepped in where NHS dentistry has struggled to keep pace.

And growth in the private sector has not been opportunistic; it has been a necessary response to an NHS model that can no longer meet patient demand.

The review should acknowledge this reality and the critical role private dentistry plays in maintaining access to dental care.