Key Points
- On 16 September 2026 the UK Competition Appeal Tribunal approved a £260m settlement in Rodger v Google, the largest collective settlement to be approved in the UK. This follows Apple being found liable for around £1.5bn in Kent v Apple in October 2025, a judgment Apple is appealing.
- In July 2026 the government proposed, in its consultation on competition redress, that the Tribunal give greater weight to the costs and benefits of a proposed collective action at certification.
- If more weight is to be given to such an assessment, then the measurement of the benefits needs to be correct. Beyond the compensation that is distributed to the class, it must include the deterrence effect, the multiplier effect of the settlement or award once it is spent or invested, and, where the distribution goes to businesses, the further investment it draws in.
- Applying the Office for Budget Responsibility’s compensation scheme multipliers to the Kent award provides an estimate of £1.4bn of additional real GDP over five years if the full award is distributed to the class or distributed by charitable award. For the distribution of the Rodger settlement, the Bank of England’s estimate of firms’ propensity to invest provides an estimate of £127m, on top of the award itself.
- Two case studies, the Royal Bank of Scotland innovation fund settlement and the Nesta innovation fund, illustrate how money returned to a market by a competition remedy draws in further private investment and lending.
Introduction
On 16 September 2026 the Competition Appeal Tribunal (“CAT”) approved the largest settlement in a UK collective action in the Rodger v Google case. Professor Barry Rodger had taken the action on behalf of thousands of UK-based app developers who, he alleged, had overpaid Google for worldwide app distribution services on the Play Store. Google agreed to settle the case before trial with Professor Rodger receiving £260m to pay his costs and distribute to the class. This follows the award of £1.5bn to Dr Rachael Kent on behalf of 36 million UK consumers by the CAT in the Kent v Apple case in October 2025, and a series of earlier settlements such as those in the McLaren v MOL cartel claim.1
In July 2026 the Department for Business and Trade asked, in its consultation on competition redress, whether the costs and benefits of a proposed collective action should be given greater weight at certification.2The economic principles of a cost-benefit analysis are well established and tell us that the relevant benefits include the compensation paid to the class, the multiplier effects of that compensation on investment, jobs and growth in the wider economy, and the forward-looking deterrent effect of the action.3 For example, reviewing the literature, the Competition and Markets Authority (“CMA”) found that the ratio of cartels deterred to cartel enforcement actions was between 4.6:1 and 28:1, suggesting that multiple cartels are deterred by a single cartel enforcement action.4 We begin by reviewing the economics of competition enforcement, then assess the macroeconomic impacts of settlements through a multiplier analysis and finally review large settlements in the UK retail banking sector.
Economics of Effective Competition
To understand the impact of effective competition on the UK economy we review literature from the OECD on the effects of an effective competition regime before turning to recent quantitative studies commissioned by the European Commission assessing the relationship between GDP growth and competition enforcement.
Competition (and hence the enforcement of laws that protect competition) drives a wide range of economic benefits. In 2014, the OECD reviewed the macroeconomic effects of competition policy and found that industries with greater competition have greater levels of productivity growth. This productivity growth affects the sector with more competition, but also spreads into other sectors across the economy. They also review evidence which indicates that competition interventions lead to higher levels of innovation. Finally, they find that in addition to driving growth, competition and competition enforcement specifically help to drive inclusive growth and to reduce inequality. This is because, “restricting competition causes harm to the many, while the profits generally go to the few. The poorest in society are often the worst affected by higher prices or lower quality.”5
These benefits of competition are blocked when anticompetitive conduct occurs. Recent studies commissioned by the European Commission have attempted to quantify the effects of competition interventions over the past twenty years in the European Union. In the European Commission report, the authors simulated the effects of markups on GDP growth. They found that during the period, increases in markups caused by increasing market power led to a decrease in the size of European GDP by about 5.7% and an increase in prices of about 5.2%.6 The researchers also found that the impact on European Union GDP would have been even higher, by almost a quarter (~7% decrease in GDP), in the last ten years without competition interventions in the European Union.
Anticompetitive conduct blocks these gains for as long as it lasts. A public authority or a private claimant can bring it to an end. Public enforcement can stop the conduct, but private enforcement can do the same and can also return the overcharge to those who paid it, and release the spending and investment which the overcharge had held back during the conduct. The catch-up effect that is created by private enforcement then adds to UK growth, investment, jobs, productivity and tax receipts.
A full accounting of the benefits of a prospective collective action would therefore include the compensation returned to those who paid the overcharge, the deterrence effect that return creates, and the further multiplier effect on the wider UK economy. We investigate this in the next section.
Multiplier Analysis
The Office for Budget Responsibility (“OBR”) estimates various multiplier effects that we can use to understand the likely effect of an award or settlement for UK consumers or businesses.
Awards or settlements for UK consumers
The OBR publishes a set of multipliers for each category of public spending. Each gives the addition to real GDP from £1 of spending in the year it is made and in each of the five years that follow. The compensation scheme multipliers are the closest published analogue to a CAT award or settlement. The OBR introduced them in October 2024 for the payments to the victims of the Post Office Horizon scandal. Table 1 below shows the multipliers calculated by the OBR for the compensation scheme as well as the multipliers for welfare (AME row) and public investment (CDEL).
In the table, £1 paid out as part of a compensation scheme leads to additional real GDP of £0.30 in the year the compensation is paid, £0.28 in the following year, and further, though diminishing, additional real GDP over the subsequent three years. These additions sum to £0.95 by the end of year 4. With the £1 of compensation itself, the benefit is £1.95, nearly double what an assessment based on compensation alone (£1) would record. In addition this does not include any of the additional deterrence value that is generated.
Table 1: Fiscal multipliers
| Year 0 | Year 1 | Year 2 | Year 3 | Year 4 | Year 5 | |
|---|---|---|---|---|---|---|
| Welfare (AME) | 0.60 | 0.57 | 0.43 | 0.23 | 0.07 | 0.00 |
| Compensation schemes | 0.30 | 0.28 | 0.22 | 0.12 | 0.03 | 0.00 |
| Public investment (CDEL) | 1.00 | 0.83 | 0.43 | 0.23 | 0.07 | 0.00 |
Notes: AME = Annually Managed Expenditure; CDEL = Capital Departmental Expenditure Limit. Source: OBR7
Using the OBR’s compensation scheme multipliers as a proxy for the effects of a lump sum settlement, we calculate the additional real GDP that can be expected to be added to the UK economy from the £1.5bn Kent v Apple award, which is currently under appeal. Table 2 below calculates these figures.
Table 2: Estimated additional real GDP due to Kent £1.5bn award (£m)
| Year 0 | Year 1 | Year 2 | Year 3 | Year 4 | Year 5 | |
|---|---|---|---|---|---|---|
| Additional real GDP (£m) | 450 | 420 | 330 | 180 | 45 | 0 |
Source and notes: OBR compensation scheme multipliers applied to the £1.5bn Kent award; Fideres analysis.
The Kent award would, if confirmed, therefore return £1.5bn from Apple to UK consumers and add a further £1.425bn in real GDP to the UK economy over five years. The figure scales with the share of the award that is either distributed to the class or that otherwise enters the economy, for example through charitable dispersals: if this were 50 per cent of the award, the addition to real GDP would be approximately £710m. To understand what that growth means for people within the economy it is useful to remember that 3% growth is estimated to decrease unemployment by 1% which would equate to more than 300,000 jobs in the UK in 2026 along with the associated tax receipts that can be used for investment in the country’s priorities.8
Awards or settlements for UK businesses
UK collective actions are often also taken on behalf of UK businesses as well as consumers. Compensation paid to UK businesses generates its own multiplier effect. The Bank of England estimates that £1 of unexpected income drives an initial £0.31 of investment.9 This in turn generates a multiplier effect. If this private investment carries the same multiplier that the OBR expects public investment to have, then Professor Rodger’s settlement would generate about £50m of investment and approximately £127m of real GDP over five years, in addition to the award itself.10
Geography
Many of the collective actions brought in the CAT have been against large multinational firms who are alleged to have increased margins through anticompetitive conduct. Where such a firm earns a margin above the competitive level from UK consumers or UK businesses, that margin accrues to its shareholders as dividends or buybacks, taxed where those shareholders live. Where the shareholders are outside the UK, a proportion of the margin leaves the UK economy. Compensation and charitable distribution returns part of it to the UK economy and the consumers and businesses who paid it, and as a result the spending and investment that follow, and the tax on them, take place in the UK.
Lessons from Awards or Settlements in the Banking Sector
As there are only a handful of collective action settlements and awards that have been approved and distributed in the UK, useful proxies are two interventions in the UK banking sector. The first is the Royal Bank of Scotland (“RBS”) innovation fund settlement and the second is the Nesta innovation fund which was part of the CMA Open Banking initiative.
Case study of effects of the RBS innovation fund settlement
As a result of the 2008 financial crisis, the UK government took a large shareholding in RBS which the European Commission later found counted as State Aid that distorted competition. The initial remedy accepted was structural, involving the divestment of a portion of RBS’s business. Once this was deemed untenable, the European Commission instead accepted a monetary settlement remedy for reinvestment. These had the same stated goal of increasing competition in the SME banking market in the UK. This remedy has a direct read-across to the collective action settlements as it was implemented as a remedy to a competition issue and involved the transfer of large sums of money at discrete points in time.
There were two funds created to promote competition: a £425m Capability & Innovation Fund which would be used to fund scale-up banks and fintechs in order to create new competitors in the SME banking market and £275m for an Incentivised Switching Scheme11 to overcome barriers to customer switching from RBS to these new competitors. The Banking Competition Remedies Corporation (“BCR”) was created to disburse the funds.
Funds were disbursed as part of a competitive tender process as per Table 3:12
Table 3: Disbursement allocation of funds
| Pool | Purpose | Awardees |
|---|---|---|
| A – £280m (reduced to £230m with return of £50m from Metro Bank) | To develop more advanced business current account offerings and supporting products for SMEs. | Starling Bank, Metro Bank*, ClearBank/Tide |
| B – £80m (reduced to £30m with return of £50m from Nationwide) | To modernise existing business current account offerings, to develop new ones, or to create supporting products for SMEs. | Nationwide*, Investec, The Co-operative Bank |
| C – £40m | To expand business offerings to include lending or payment services – including international payment services – for UK SMEs. | Atom Bank, iwoca, Modulr, Currencycloud |
| D – £25m | To facilitate the commercialisation of financial technology relevant to SMEs. | Codat, Fluidly, Form3, Funding Options, Swoop |
| E – £100m | £80m to Pool A, B and C Bodies and £20m to Pool D Bodies – Reduced | Onfido*, Funding Xchange, Codat, ezbob*, Fractal Labs (t/a tomato pay), Previse, Virgin Money, ClearBank/Tide, Ebury Partners*, Kriya (formerly known as MarketFinance) |
| F – £12.5m | £5m to A, B, C Bodies, £7.5m to D Bodies | Cashplus Bank, Codat, Swoop |
* Returned funds: Metro Bank – £50m, Nationwide – £50m, Onfido – £5m, Ebury – £7.5m, ezbob – c.£0.4m (ezbob monies returned in 2022 and distributed to Business Debtline)
The banks in Pools A and B obtained a 30% share of the UK SME business accounts. Along with the funds awarded, the winners co-invested an additional £560m of their own and have in time received a further £2.8bn in funding from private equity. Meanwhile challenger banks (Starling Bank, ClearBank/Tide, Metro Bank, The Co-operative Bank, Investec, Virgin Money, and Cashplus Bank) who had received the awards from the fund, collectively created direct bank loans of £6.1bn.13 This ‘crowding-in’ effect on investment from market-shaping interventions (in this case from protecting the markets from anti-competitive conduct) is documented in the work of Mazzucato, though its roots date back to Keynes.14 As set out in section 4, these funds carry a multiplier effect that adds to real GDP.
Case study of Nesta innovation fund
Separately, as part of the Open Banking remedies, the CMA created a pool of money (£5m in 201715) funded by the largest retail banks to grant to fintech companies who were developing products using the new Open Banking standard. We are not aware of a cost-benefit analysis of the fund. We note however that as of 2023, the UK Open Banking sector, which was created through a combination of behavioural remedies and monetary incentives, had grown to be worth more than £4.1bn and had created over 4,800 skilled jobs.16
Conclusions
Reviews of economic literature on competition enforcement, macroeconomic effects including spending multipliers, and real-world case studies of settlements point to there being benefits of collective actions that go beyond the direct compensation to the class. These include the deterrent effects on conduct in the future and in other markets, the multiplier effects of the money once it has been spent or invested by the class or charity that received it, and, where the compensation goes to businesses, the further investment it draws in. An assessment of the costs and benefits of a collective action is therefore complete only when set against all of these benefits.
Sources
1 Mark McLaren Class Representative Limited v MOL (Europe Africa) Ltd and Others The McLaren settlements were approved in stages between December 2023 and early 2026, the last being £54m from the remaining defendants.
2 Department for Business and Trade, Swifter and Simpler Competition Redress, Regulatory Appeals and Competition Enforcement, consultation, 17 Jul 2026, Q5.
3 We do not review the deterrent effects of competition policy here but note that research suggests that effective competition policy has a significant effect in deterring anticompetitive conduct. See for example Bos et al., ‘Does Enforcement Deter Cartels?’. Walker ‘The deterrent effect of competition authorities’ work’ Centre for Competition Policy, and ‘Deterrent effect of competition authorities’ work’ CMA.
4 CMA ‘Wider Benefits of Competition Policy and Enforcement, CMA Microeconomics Unit literature review’ 2025.
5 OECD, Factsheet on Competition and Macro-Economic Outcomes, 2–3. Ennis et al (2019). https://academic.oup.com/oxrep/article-abstract/35/3/518/5531384. Note that this is a net effect that already accounts for any earnings that ordinary consumers might earn from those anticompetitive rents, for instance via investment by their pension provider.
6 European Commission. Directorate General for Competition. et al., Exploring Aspects of the State of Competition in the EU, 288.
7 Office for Budget Responsibility, response to a Freedom of Information request on the fiscal multipliers used in the October 2024 Economic and Fiscal Outlook, Nov 2024, available at https://obr.uk/docs/dlm_uploads/FOI06112024.pdf (accessed 26 Oct 2026).
8 Okun, Arthur M., William Fellner, and Alan Greenspan. ‘Upward Mobility in a High-Pressure Economy’. Brookings Papers on Economic Activity 1973, no. 1 (1973): 207. https://doi.org/10.2307/2534087.
9 Alati et al., ‘Firms’ Sales Expectations and Marginal Propensity to Invest’. Available at https://www.ssrn.com/abstract=4916093.
10 Fideres calculation: £160m multiplied by 0.31 gives £49.6m of investment. The CDEL multipliers in Table 1 sum to 2.56 across the six years shown, and £49.6m multiplied by 2.56 gives £127m. The £160m is the settlement sum net of the £100m set aside for costs.
11 As a result of the incentives provided as part of the Incentivised Switching Scheme, BCR oversaw about 69,000 business current account switches. Anderson, ‘How Banking Competition Remedies Supported the Growth of UK FinTech’.
12 Anderson, ‘How Banking Competition Remedies Supported the Growth of UK FinTech’.
13 Anderson, ‘How Banking Competition Remedies Supported the Growth of UK FinTech’.
14 See Keynes, The General Theory of Employment, Interest, and Money. And Mazzucato, The Entrepreneurial State.
15 Available at https://www.nesta.org.uk/press-release/open-challenge-twelve-winning-fintechs-selected-advance-future-small-business-banking/.
16 Hallas, The £4bn Open Banking Ecosystem | Coadec.
