UK CMA Review of AI Foundation Models

Foundation models are general AI systems that can be adapted for different products and tasks. Their development and deployment may depend on important inputs such as compute, data, expertise and routes to users. Because a small number of firms may operate at several layers, competition authorities examine whether partnerships, integrations or control of key resources could affect entry, choice or bargaining power. They also consider consumer issues such as unclear limitations and difficulty comparing services. The Competition and Markets Authority began its initial AI Foundation Models review in May 2023, published an initial report in September 2023 and issued an update paper in April 2024. The CMA case page marks that initial review closed, while explaining that it continues to monitor AI market developments through its broader work. The 2024 update confirmed six principles: access, diversity, choice, fair dealing, transparency and accountability. The principles are practical lenses rather than a checklist for proving a legal violation. Access concerns ongoing availability of inputs without undue restrictions. Diversity considers whether a range of models and business approaches remains available. Choice and fair dealing relate to the ability to choose, switch or use multiple services and to avoid anti-competitive conduct such as self-preferencing, tying or bundling. Transparency asks whether developers, deployers, businesses and consumers receive information needed to understand risks and limitations. Accountability asks firms to take responsibility for what they control. When reading the review, separate three things: what the CMA observed about market structure, what it identified as a risk, and what action it said it would take. A market study does not establish that every named partnership is unlawful. The CMA’s concerns can inform follow-up investigations or policy, but each enforcement decision depends on evidence and legal tests. Check publication dates and current CMA material rather than presenting the 2024 update as a complete description of the market in 2026.