Private Dentistry Review 2026: What the Five CMA Focus Areas Mean for Practice Finances

On 5 March 2026, the Competition and Markets Authority launched a market study into the supply of private dental services in the UK. The study covers preventative, clinically necessary and cosmetic dental treatments and is examining how effectively the private dentistry market works for patients and businesses. The CMA must publish its final market-study report by 4 March 2027.

The figures behind the review demonstrate the increasing importance of private dentistry. Private dental services accounted for approximately 69% of the UK dental market in 2025, while the private dentistry market was valued at £8.4 billion in 2023/24. The CMA also reported that around one in five people in Great Britain used private dental care in 2024.

The CMA cited independent evidence indicating that average initial consultation fees increased by more than 23% to approximately £80 between 2022 and 2024. Average routine check-up fees for existing patients were reported to have increased by more than 14% to approximately £55 over the same period. These figures form part of the regulator’s evidence gathering and do not, by themselves, establish that individual practices are charging unfair prices.

For private and mixed dental practice owners, this review is not simply a distant regulatory exercise. Its scope directly touches the way practices:

• Present prices to patients
• Explain treatment options
• Structure payment and membership plans
• Advertise private dental services
• Record NHS, private and cosmetic income
• Assess service-line profitability
• Handle complaints, refunds and remedial treatment
• Document associate incentives and referral arrangements

The CMA’s July 2026 update confirmed five themes for the remainder of its study:

1. Consumer journey and choice
2. Competition
3. Conduct
4. Regulatory frameworks
5. Market outcomes

The July update did not contain findings or conclusions. The CMA confirmed that evidence gathering and analysis would continue before it publishes its emerging thinking and final recommendations.

This guide explains each of the five themes from a dental practice finance and accounting perspective. It also outlines the practical actions private and mixed practices can take now to improve pricing records, VAT compliance, management accounts and financial planning.

Kudos Accounting provides specialist accounting support for dentists and dental practices, including bookkeeping, payroll, VAT reviews, service-line management accounts and strategic financial planning.

Key Takeaways

• The CMA launched its private dental services market study on 5 March 2026.
• The final market-study report is due by 4 March 2027.
• The study covers consumer choice, competition, conduct, regulation and market outcomes.
• The CMA has not yet announced final findings or remedies.
• Private practices should review pricing transparency and treatment-plan documentation now.
• Mixed practices should separate NHS, private and cosmetic income in their accounting records.
• Cosmetic dentistry VAT treatment should be based on the purpose and circumstances of the treatment.
• Dental groups should be able to produce reliable site-level and service-line financial information.
• Practices should treat possible regulatory changes as planning scenarios, not confirmed requirements.

The Five CMA Study Themes at a Glance

The CMA’s five themes cover the entire patient and commercial journey, from the way patients find a practice to the way treatment is priced, delivered and accounted for.

Each theme has a distinct commercial and accounting dimension.

Focus Area 1: Consumer Journey and Choice

The first theme examines how patients search for, understand and purchase private dental services.

This includes:

• The availability of treatment information
• Whether prices are disclosed before treatment
• Whether patients can compare providers
• How treatment alternatives are explained
• How patient finance and membership plans are presented
• Whether vulnerable patients receive appropriate support

For practice owners, the main issue is whether a patient can understand the expected cost of treatment before making a decision.

What this means for your fee structure

A practice is more exposed to patient disputes where:

• Website prices differ from final invoices without explanation
• Prices are described only as “from” amounts without meaningful context
• Additional clinical or laboratory fees are not disclosed
• Treatment-plan changes are not approved by the patient
• Membership-plan exclusions are unclear
• Finance charges are not explained separately
• The practice cannot show which version of a fee guide applied

Practices should ensure that the fee quoted to a patient is supported by the treatment plan, invoice and accounting records.

Clear nominal codes are useful for management reporting, but they do not prove that prices were transparent to patients. Patient-facing transparency depends on what the patient was shown and could reasonably understand before committing to treatment.

Separate private income by treatment category

A single accounting code called “private dental income” provides limited information.

A private or mixed practice should consider separate nominal codes for:

• Private examinations
• Private hygiene services
• Restorative dentistry
• Periodontal treatment
• Endodontic treatment
• Orthodontics
• Implant dentistry
• Prosthodontics
• Tooth whitening
• Composite bonding
• Veneers
• Facial aesthetic services
• Private dental-plan income
• Patient finance receipts
• Laboratory recharges
• Cancellation or failed-appointment fees

The appropriate level of detail depends on the size and complexity of the practice. A small practice does not need dozens of codes that no one reviews. However, the accounts should provide enough separation to explain where income is generated and how each major service line performs.

Treatment-plan documentation

Every private treatment plan should clearly explain:

• The treatment proposed
• The main alternatives discussed
• The expected fees
• Whether laboratory charges are included
• Whether follow-up or maintenance appointments are included
• Whether the amount may change
• How any changes will be approved
• The payment timetable
• The cancellation and refund terms

A signed treatment plan is important evidence that the patient received and accepted the information. However, signing the plan does not necessarily mean that the entire value of the treatment should immediately be recognised as income.

Accounting recognition depends on factors including:

• When treatment is delivered
• Contractual milestones
• The practice’s accounting basis
• Whether the payment is refundable
• Whether the practice still has substantial obligations
• Whether the patient has paid a deposit or the full balance

For example, a deposit collected before a multi-stage treatment begins may initially need to be recorded as deferred income or a patient creditor rather than immediately recognised as completed treatment income.

Patient finance arrangements

The CMA is also considering how patients understand finance and payment arrangements.

A practice offering patient finance should maintain a clear distinction between:

• The underlying treatment fee
• Any deposit
• Amounts paid by a finance provider
• Administration charges
• Interest or finance costs
• Refunds to the patient or finance provider
• Uncompleted treatment obligations

Patient finance receipts should be reconciled against patient ledgers. The practice should not treat a finance-provider receipt as unidentified income merely because the provider pays a net amount after deducting fees.

The accounting and VAT treatment depends on the structure of the arrangement and the nature of each supply. It should not be determined solely by whether the plan is described as interest-free.

Focus Area 2: Competition

The second CMA theme examines whether competition between private dental providers is producing effective choices and fair outcomes for patients.

Relevant issues may include:

• The number of providers in a local area
• Barriers to switching practices
• The availability of clear comparative information
• Practice acquisitions and group ownership
• The relationship between NHS availability and private demand
• Differences in price and capacity between regions
• Whether local markets are concentrated

This area is particularly relevant to dental groups, corporate operators and practices completing acquisitions.

What this means for independent practices

An independent single-site practice is not automatically at risk simply because it is the principal provider in a local area. Market position alone does not establish inappropriate conduct.

However, all practices should ensure that:

• Prices are determined through a documented commercial process
• Competitor information is gathered lawfully
• Sensitive pricing information is not exchanged improperly
• Referral arrangements are transparent
• Patients are not given misleading claims about the absence of alternatives
• Marketing accurately describes ownership and clinical provision

A practice should not coordinate pricing with competitors or exchange commercially sensitive information in a way that could restrict independent decision-making.

What this means for dental groups

Groups should be able to explain differences in prices between locations.

A dental group may legitimately charge different prices because of:

• Local property costs
• Employment costs
• Laboratory arrangements
• Treatment mix
• Equipment investment
• Capacity constraints
• Local demand
• Clinician experience
• Finance-provider charges

However, those differences should be supported by reliable financial information.

Group management accounts should normally separate:

• Income by legal entity
• Income by practice location
• NHS and private income
• Income by major service line
• Direct clinical costs
• Laboratory costs
• Associate costs
• Central management charges
• Marketing costs
• Site-level operating profit
• Capital expenditure

Kudos Accounting’s bookkeeping and payroll service for dental groups can help multi-site practices create consistent coding structures and site-level reporting.

Responding to a CMA information request

The CMA may request information from businesses as part of a market study. Not every questionnaire or request automatically carries the same statutory consequences.

Where a practice or dental group receives a formal statutory information notice, it should:

1. Confirm the legal basis of the request.
2. Record the response deadline.
3. Appoint a senior person to coordinate the response.
4. Preserve relevant documents and data.
5. Obtain competition-law advice promptly.
6. Identify which information is commercially confidential.
7. Reconcile financial information before submission.
8. Avoid providing estimates where exact figures are available.
9. Explain any limitations in the data.
10. Retain a complete copy of the response.

Failure to comply with a formal statutory request without reasonable excuse can result in significant penalties. The exact exposure depends on the applicable statutory powers and circumstances, so any recipient should obtain legal advice rather than relying on a general summary.

The accounting team should support the response, but it should not attempt to provide competition-law advice unless appropriately qualified.

Focus Area 3: Conduct

The third theme examines conduct within the private dental services market.

This may include:

• Misleading advertising
• Hidden or unexpected charges
• Inaccurate price claims
• Pressure-selling techniques
• Inadequate disclosure of treatment alternatives
• Unfair contract terms
• Anti-competitive behaviour
• Inappropriate referral or incentive arrangements

This theme has a direct connection with financial records because patient-facing representations should agree with the amounts invoiced and collected.

Hidden fees and price changes

A practice may need to change a treatment fee where:

• The clinical position changes
• Additional diagnostic work is needed
• Laboratory requirements change
• The patient selects a different option
• An unforeseen complication occurs
• The original estimate contained an error

A fee change is not necessarily inappropriate. The risk arises when the change is not explained or agreed before the additional treatment is delivered.

Differences between the original estimate and final invoice can result in:

• Patient disputes
• Credit notes
• Refunds
• Delayed collection
• Complaints
• Bad debts
• Remedial work
• Damage to the practice’s reputation

The practice should document why the treatment or price changed and obtain the patient’s agreement wherever practicable.

Income recognition and signed treatment plans

A signed treatment plan supports the practice’s evidence of:

• The services proposed
• The price disclosed
• The payment terms
• The patient’s agreement
• Any agreed limitations or exclusions

However, it does not automatically determine when the full treatment value is recognised as income.

For longer treatment plans, management accounts may need to distinguish between:

• Deposits received
• Treatments completed
• Treatments in progress
• Amounts invoiced but unpaid
• Patient credit balances
• Refundable amounts
• Finance-provider receivables

This is particularly relevant to implant, orthodontic and complex restorative work delivered over several months.

Advertising and marketing records

Practices should audit any marketing that refers to:

• “Free” consultations
• Prices “from” a stated amount
• Limited-time discounts
• Guaranteed results
• Interest-free finance
• Membership savings
• Same-day treatment
• Before-and-after outcomes
• Exclusive technologies
• Specialist expertise

The practice should retain evidence supporting objective claims.

Where a campaign refers to a specific price, the practice should be able to show:

• The treatment included
• The period during which the price applied
• Any eligibility conditions
• Any common additional costs
• Whether all participating locations offered the same price

Changes arising from the CMA review could require practices to update websites, printed fee guides, patient leaflets and advertising campaigns. Practices with substantial marketing activity may wish to include a modest compliance or website-update budget in their 2026/27 planning.

Focus Area 4: Regulatory Frameworks

The fourth theme examines whether the existing regulatory and complaints arrangements provide effective consumer protection.

The private dental market interacts with several bodies and frameworks, which may include:

• The General Dental Council
• Care regulators in the UK nations
• Consumer protection law
• Professional indemnity arrangements
• Alternative dispute resolution
• Practice-level complaints procedures
• NHS bodies where mixed treatment is involved

The CMA’s review does not mean that a new insurance, warranty or compensation scheme will necessarily be introduced. No such universal requirement has been announced.

Possible recommendations could nevertheless create additional:

• Administrative costs
• Training requirements
• Record-keeping obligations
• Complaint-handling costs
• Redress costs
• Website and documentation costs
• Insurance or indemnity considerations

These should be treated as planning risks rather than confirmed future expenses.

Complaints and financial records

Every complaint with a financial consequence should be recorded consistently.

Relevant accounting categories may include:

• Patient refunds
• Credit notes
• Remedial treatment
• Laboratory remake costs
• Legal fees
• Professional advice
• Complaint settlements
• Indemnity recoveries
• Ex gratia payments

A complaint should not automatically create an accounting provision.

A provision may be appropriate only where the relevant accounting requirements are satisfied, including the existence of a present obligation, a probable financial outflow and an amount that can be estimated reliably.

Practices should avoid dealing with complaint costs informally outside the accounts. Informal refunds or unpaid remedial treatment can obscure the true cost of complaints and distort service-line profitability.

GDC costs and wider regulatory pressure

The GDC Annual Retention Fee increased to £698 for dentists and £108 for DCPs in 2026.

The CMA market study is separate from the GDC’s fee-setting process, so the two should not be presented as directly linked. However, both demonstrate the increasing importance of regulatory and compliance costs within dental practice budgets.

Read our 2026 GDC fee tax-treatment guide for guidance on associate deductions, employee reimbursements and practice-paid registration fees.

Focus Area 5: Market Outcomes

The CMA’s market-outcomes theme covers matters including:

• Prices
• Profitability
• Capacity
• Market structure
• Consumer outcomes
• Corporate ownership
• Financial incentives
• Treatment availability

The CMA cited independent evidence suggesting that average initial consultation and routine check-up prices increased notably between 2022 and 2024. However, price increases must also be viewed alongside changes in the underlying cost of providing dental care.

Relevant costs may include:

• Dental-team salaries
• Employer National Insurance
• Laboratory charges
• Materials
• Rent and premises costs
• Utilities
• Equipment
• Finance costs
• Indemnity
• GDC fees
• Compliance costs
• Software
• Marketing
• Associate remuneration

A price increase does not automatically demonstrate excessive profitability. Equally, an increase in costs does not remove the need for clear patient disclosure.

What profitability scrutiny means for your accounts

A practice with significant private income should understand the margin generated by its main services.

This does not mean that every individual procedure needs a separate profit and loss account. It means management information should be sufficiently detailed to identify the principal commercial drivers of the business.

A useful reporting structure may separate:

• NHS contract income
• NHS patient charges
• Private general dentistry
• Private hygiene
• Implant services
• Orthodontics
• Cosmetic dentistry
• Membership-plan income
• Facial aesthetics
• Other clinical services

Direct costs can then be attributed or allocated using a documented approach.

Relevant costs may include:

• Associate fees
• Laboratory charges
• Clinical materials
• Finance-provider fees
• Treatment-specific marketing
• Clinician or surgery time

Shared overheads such as reception wages, rent and utilities may be allocated using an appropriate and consistent basis.

Service-line accounts are management evidence, not a legal defence

Service-line management accounts can help a practice explain the commercial reasons behind its prices.

They may demonstrate:

• Rising input costs
• Investment in equipment
• Capacity constraints
• Differences between services
• Margin changes
• The financial effect of staffing shortages

However, they do not determine whether a fee or contractual term is legally fair. Consumer and competition-law questions require appropriate legal analysis.

Corporate structures and financial incentives

The CMA is also interested in how commercial incentives may affect treatment and pricing outcomes.

Groups and larger practices should maintain clear documentation for:

• Associate percentage arrangements
• Performance bonuses
• Treatment-volume incentives
• Referral fees
• Laboratory rebates
• Supplier discounts
• Internal referral arrangements
• Central management charges
• Finance-provider commissions
• Marketing incentives

Financial incentives should be accurately recorded and should not be hidden within general expenditure categories.

The practice should also ensure that commercial incentives do not undermine clinical decision-making or patient communications.

Possible Financial Outcomes of the CMA Review

The CMA has not announced its final findings or recommendations. Practices should therefore avoid presenting any particular outcome as certain.

The following are planning scenarios rather than predictions.

Scenario 1: Guidance or voluntary industry commitments

The CMA could recommend clearer industry guidance or voluntary commitments covering matters such as:

• Upfront fee information
• Standardised treatment plans
• Patient-finance disclosure
• Complaint handling
• Website pricing

The main cost would be the time required to update systems, templates and training.

Scenario 2: Stronger mandatory pricing-transparency requirements

Possible requirements could include:

• More detailed website prices
• Standardised fee descriptions
• Itemised treatment plans
• Clear disclosure of common additional charges
• Improved finance information
• Better cancellation and refund terms

This could create one-off costs for:

• Website development
• Practice-management software
• Staff training
• Printed materials
• Legal review
• Compliance audits

It could also generate ongoing administration costs.

Scenario 3: Stronger complaints or redress arrangements

Potential recommendations could affect:

• Complaint response times
• Record keeping
• Patient redress
• Alternative dispute resolution
• Regulatory coordination
• Treatment-remediation procedures

No specific new universal redress or insurance obligation has been confirmed. Practices should therefore model possible costs without treating them as existing liabilities.

Scenario 4: A reference for a full market investigation

A market investigation reference is one possible outcome of a market study. The CMA has not yet announced whether it considers that escalation necessary.

A full investigation could examine the market in greater depth and potentially lead to legally enforceable remedies. Practices should not assume that a market investigation will or will not happen before the CMA communicates its emerging thinking.

Prudent planning position

Preparing for improved pricing transparency is a sensible middle-ground response.

The same steps also improve ordinary business management:

• Better fee documentation
• Clearer patient communications
• More detailed income analysis
• Improved VAT controls
• Stronger site-level reporting
• Better complaint-cost information

VAT and Cosmetic Dentistry

The CMA study covers cosmetic dental treatment as well as preventative and clinically necessary services. This adds attention to an area that already involves important VAT questions.

Dental services supplied by registered dental professionals may be exempt from VAT where their principal purpose is the protection, maintenance or restoration of health.

Services supplied purely for cosmetic reasons may be subject to VAT at the standard rate.

The label used for a treatment does not determine the VAT position. HMRC states that cosmetic services supplied as part of a dental healthcare treatment can form part of an exempt supply, while cosmetic dentistry performed outside healthcare can be standard-rated. Each case should be considered according to its purpose and circumstances.

Treatment names do not provide the complete answer

Treatments such as the following should not automatically be classified solely by name:

• Tooth whitening
• Composite bonding
• Veneers
• Orthodontic treatment
• Implant treatment
• Facial aesthetic services
• Restorative procedures with an aesthetic element

The practice should consider:

• The clinical diagnosis
• The treatment purpose
• The clinician’s notes
• Whether the treatment forms part of a healthcare programme
• Whether the service is supplied purely for appearance
• Who supplies the service
• Whether goods and services form a single or separate supply

HMRC notes that cosmetic services can remain exempt where undertaken as part of a healthcare treatment programme, while services undertaken purely for cosmetic reasons are generally standard-rated.

Why CMA pricing scrutiny makes VAT records more important

Incorrect VAT treatment can affect the price shown to patients.

For example, where a treatment should be standard-rated but VAT was not included:

• The practice may have an underdeclared VAT liability
• The quoted patient price may not reflect the correct gross amount
• Historic margins may be overstated
• Correcting the issue may affect future pricing
• The practice may need to consider disclosure to HMRC

Where a treatment has incorrectly been treated as taxable when it should be exempt, the practice may have charged patients unnecessarily and recovered input tax incorrectly.

The safest approach is to maintain a treatment-level VAT matrix supported by clinical and tax reasoning.

Read our VAT and cosmetic dentistry guide for further guidance.

Kudos Accounting’s healthcare VAT specialist team can review the treatment classification, VAT records and effect on private pricing.

What Private Dental Practices Should Do Now

Regardless of the CMA’s final recommendations, the steps that prepare a practice for scrutiny also produce better financial information.

1. Separate private income by service type

Review the chart of accounts and determine whether the practice can distinguish between its main private income streams.

At minimum, many mixed practices should be able to identify:

• NHS income
• Private general dentistry
• Private hygiene
• Cosmetic dentistry
• Implant treatment
• Orthodontics
• Patient-plan income

Larger practices may require additional detail.

2. Document the pricing process

Retain evidence of:

• Fee-review dates
• Cost information used
• Who approved the prices
• Updated website fees
• Treatment-plan templates
• Patient communications
• Effective dates
• Previous fee schedules

This supports commercial management and enables the practice to explain why fees changed.

3. Review every patient-facing price

Compare:

• Website prices
• Reception fee guides
• Treatment-plan templates
• Practice-management software
• Online booking prices
• Finance-provider information
• Advertising campaigns

Inconsistent prices should be corrected.

4. Review cosmetic-treatment VAT classifications

Prepare a list of every cosmetic or aesthetic service and document:

• The likely clinical purpose
• Whether the service forms part of healthcare
• The VAT classification
• The evidence retained
• The accounting code used
• The price before and after VAT

Obtain specialist advice where the position is uncertain.

5. Produce service-line management accounts

Ask your accountant to provide reporting that distinguishes:

• NHS activity
• Private general dentistry
• Cosmetic services
• Membership income
• Other major service lines

The report should show income, identifiable direct costs, a sensible allocation of shared costs and the resulting margin.

6. Produce site-level accounts for groups

Each location should have:

• A consistent chart of accounts
• Separate income reporting
• Direct labour and associate costs
• Laboratory costs
• Local marketing costs
• Site overheads
• Central charges
• Operating profit
• Cash-flow reporting

This reduces the time needed to respond to financial questions.

7. Review patient-finance accounting

Reconcile:

• Treatment-plan value
• Patient deposits
• Finance-provider receipts
• Provider deductions
• Outstanding receivables
• Deferred treatment
• Refunds
• Cancelled plans

Do not rely solely on bank deposits.

8. Record complaints and financial outcomes

Create clear accounting codes for:

• Refunds
• Credit notes
• Remedial treatment
• Legal and professional fees
• Complaint settlements
• Indemnity recoveries

Review the total complaint cost periodically.

9. Review associate incentives

Document:

• Associate percentages
• Bonuses
• Referral payments
• Volume incentives
• Laboratory recharges
• Finance deductions
• Marketing contributions

Ensure practice accounts and associate statements are consistent.

10. Model possible implementation costs

Include planning estimates for:

• Website updates
• New fee displays
• Software changes
• Legal advice
• Staff training
• New treatment-plan templates
• Compliance reviews
• Additional complaint administration

These are not confirmed costs, but a planning reserve can prevent future changes from becoming an unexpected cash-flow problem.

Practices considering ownership changes should also review our guide to buying a dental practice in 2026.

Mixed practices affected by NHS changes may also find our NHS dental contract reform guide useful.