CMA Issues First Civil Penalties on Individuals for Concealing Dawn-Raid Evidence
On 24 September 2026 the UK CMA fined a senior manager £20,000 and an office manager £5,000 for hiding evidence during a dawn raid — its first penalties imposed on individuals.
On 24 September 2026, the UK Competition and Markets Authority imposed civil penalties on two individuals for concealing evidence during an unannounced visit to a business's premises. According to the Perkins Coie report, a member of senior management was fined £20,000 and an office manager £5,000, marking the CMA's first use of its penalty powers against individuals rather than undertakings alone.
The signal matters because it converts what many treat as housekeeping compliance during a dawn raid — preserving and producing documents, laptops and messages — into personal, financially enforceable exposure for management, and it lands as the UK merger and competition regime is under active reform debate. The amounts are modest, but the precedent is not: officers will now weigh the cost of resisting an inspection against their own liability, and boards should be asking who is authorised to respond to a dawn raid and who is not.
For counsel, the concrete action is to refresh dawn-raid protocols and preservation instructions so that individuals likely to be on site when investigators arrive understand both the duty to cooperate and the personal consequences of moving or hiding material. Watch for any CMA follow-up indicating whether these were contested proceedings and whether further individual penalties follow.