Review of SME Banking Undertakings 2002
Source: gov.uk (2025-12-01)

The Competition and Markets Authority (CMA) formally reviewed the remaining SME Banking (Behavioural) Undertakings 2002.

Case timetable

This timetable was published in line with guidance on the CMA’s approach to the variation and termination of merger monopoly and market undertakings and orders (https://www.gov.uk/government/publications/remedies-guidance-on-the-cmas-approach-to-the-variation-and-termination-of-merger-monopoly-and-market-undertakings-and-orders). Any revisions to the timetable will be published on this page.

Final decision

1 December 2025: The CMA has published its final decision that the remaining provisions of the SME Banking Undertakings 2002 are no longer appropriate. Accordingly, the undertakings have now been released in entirety.
- Final decision (https://www.gov.uk/government/consultations/provisional-decision-review-of-the-sme-banking-undertakings-2002) (1.12.25)
Provisional decision consultation: closes 3 September 2025

13 August 2025: The CMA has published its provisional decision that the remaining provisions of the SME Banking Undertakings 2002 are no longer appropriate and should be released.

Review group appointed

2 April 2025: The CMA appointed the following Panel group members to the review of the SME Banking Undertakings 2002:
- Kirstin Baker (https://www.gov.uk/government/publications/cma-panel-member-biographies-and-disclosures-of-interest/inquiry-chairs-biographies#kirstin-baker)
- Paul Hughes (https://www.gov.uk/government/publications/cma-panel-member-biographies-and-disclosures-of-interest/panel-members-biographies#paul-hughes)
- Ulrike Hotopp (https://www.gov.uk/government/publications/cma-panel-member-biographies-and-disclosures-of-interest/panel-members-biographies#ulrike-hotopp)
Decision to carry out a review

2 April 2025: The CMA decided to launch a review of the remaining SME Banking Undertakings 2002 (https://www.gov.uk/government/publications/small-and-medium-sized-enterprise-sme-banking-undertakings). In 2014, the CMA reviewed the Undertakings and decided in 2016 to release all but 4 provisions in the Undertakings. These 4 provisions prohibit 8 designated banks from compelling an SME customer to open or maintain a business current account as a condition of accessing business loans or deposit accounts (the ‘Limitation on Bundling Provisions’).

The purpose of this review is to determine whether, as a result of any change of circumstances, the Limitation on Bundling Provisions are no longer appropriate and need to be varied, superseded or released.

The CMA consulted on:
- potential changes of circumstances that may mean that the Limitation on Bundling Provisions are no longer appropriate
- if such changes are identified, whether they mean that the Limitation on Bundling Provisions should be varied, superseded or released
- in the case of identifying the need to vary the Limitation on Bundling Provisions, what are the proposed changes that could be made
Find out more about this consultation (https://www.gov.uk/government/consultations/review-of-sme-banking-undertakings-2002).

Contact

xxx@xxx.xx (mailto:xxx@xxx.xx)

Your personal data

Your name and contact details are your personal data. In collecting, receiving, storing, accessing and using your personal data, the CMA, as controller, is processing your personal data. The CMA processes personal data in accordance with data protection law. The CMA is processing your personal data so that it can contact you again, should it need further help or information from you, in order to carry out its statutory duty under section 88(4) of the Fair Trading Act 1973 (as preserved in Schedule 24 Enterprise Act 2002) to keep under review undertakings and orders.

For more information about how the CMA processes personal data and your rights relating to that data, read our privacy notice (https://www.gov.uk/government/organisations/competition-and-markets-authority/about/personal-information-charter).