CAT Collective Proceedings – Winter 2025/6 Update

Developments in the UK’s competition collective proceedings regime continue apace with new claims recently issued in the Competition Appeal Tribunal (CAT).

Since our last update in the Summer of 2025 (see here), there have been a significant number of important developments in the UK’s competition collective proceedings regime before the Competition Appeal Tribunal (CAT). A number of key trends and themes run through this update.

First, while the rapid pace of newly issued claims has slowed, new collective claims continue to be filed and announced, with technology‑related claims featuring prominently.

Second, the CAT is exercising robust case management powers in an effort to control the length and cost of collective claims, including ordering joint or coordinated management of overlapping claims, and setting new procedural rules to expert evidence.

Third, the regime is attracting wider scrutiny and suggestions for change from multiple quarters. Given the regime’s relative youth - introduced just over a decade ago, with the first certification in 2021 and the first trial in 2024 - early lessons are likely to be an important ingredient in evaluating any potential reforms.

Fourth, the UK's collective action regime continues to mature, with the first two substantive trial judgments now handed down. The distribution of damages remains a key area for development, and experience in the Kent case is expected to provide further guidance over the coming year.

In this short update, we comment on these trends, identify other recent key developments, and highlight some events to look out for in the coming months.