The CMA's Statement of Issues on the proposed merger between Vodafone and Three - Which? Response

We previously raised concerns about the proposed merger between Vodafone and Three in our response to the CMA’s initial invitation to comment during its Phase 1 inquiry. This response reiterates some of those concerns and includes an updated analysis from our prior response. 

Overall, we agree with the key areas of focus and theories of harm raised by the CMA in its issues statement. We share the CMA’s concerns about horizontal unilateral effects leading to higher prices and lower quality for consumers. Our own evidence shows that the two firms compete closely for end consumers and, therefore, that the merger risks less intense competition in the market on both price and quality.