The Competition and Markets Authority (CMA) is investigating the recent acquisitions by Hays Travel of Polka Dot Travel and Millington Travel.
The CMA has separate Initial Enforcement Orders (IEOs) under the Enterprise Act 2002 relating to the two acquisitions.
It says it has ‘reasonable grounds for suspecting that it is or may be the case that Hays Travel Limited (Hays) and Polka Dot Travel Limited (PDT) have ceased to be distinct’.
It has issued a separate order, using the same wording, for Hays’ acquisition of The Independent Travel Company Limited, trading as Millington Travel.
It adds: “The CMA is considering, pursuant to section 22 of the Act, whether it is or may be the case that a relevant merger situation has been created and whether the creation of that situation has resulted or may be expected to result in a substantial lessening of competition in any market or markets in the United Kingdom (UK).”
IEOs under the Enterprise Act 2002 are used by the CMA to prevent parties in a potential merger or acquisition from taking actions that could harm competition before the CMA fully investigates, ensuring both businesses remain independent until the review concludes.
The orders commenced on 16 December 2025 and include a list of stipulations.
Hays can’t integrate the businesses further, transfer ownership or ‘impair’ the brands’ ability to compete independently until the CMA has concluded its investigation.
In addition, Hays must ensure no significant changes can be made to the organisational structure of management responsibilities, no changes to key staff can be made and Hays can’t negotiate on behalf of the acquired agencies or enter into any joint agreements.
Technology platforms of the acquired agencies must remain unchanged, except for routine changes and maintenance and IT cannot be integrated into the Hays business.
Customer supplier lists need to be operated and updated separately and any negotiations with any existing or potential customers and suppliers in relation to the acquired agencies’ business must be carried out by the agencies alone.
All contracts of the acquired agencies’ business and the Hays business must continue to be serviced by the companies to which they were awarded.
Required information must be provided on 30 December and every two weeks after that, during the investigation.
Hays bought 15-branch Polka Dot Travel at the end of October and 14-branch Millington Travel in early November. They are the third and fourth businesses to join Hays’ retail portfolio this year, after Hays acquired 12-branch and homework network Spears Travel in June and Cruise.co.uk owner Victoria Travel Group in July.
A Hays spokesperson said: “We are committed to cooperating with the CMA throughout the review process. Each brand will operate separately.”
