CMA confirms Aldi and Lidl will be subject to the same land agreement rules as other large UK supermarkets

On 22 October 2026, the CMA published its decision to designate Aldi Stores Limited (Aldi), Lidl Great Britain Limited and Lidl Northern Ireland Limited (together, Lidl) as Large Grocery Retailers (LGRs) under the Groceries Market Investigation (Controlled Land) Order 2010 (the Order).

This follows its provisional decision on 7 August 2026, when the CMA invited views on its proposal to designate Aldi and Lidl under the Order. The CMA subsequently received responses from four interested parties: Morrisons and Waitrose (both existing LGRs); Iceland (another grocery retailer); and an “anonymous shopper”. All of the responses supported the CMA’s proposal, agreeing that Aldi and Lidl operate larger grocery stores in the UK and meet the designation criteria. Morrisons and Iceland further submitted representations regarding Aldi’s and Lidl’s future store expansion plans, which are understood to be centred on stores larger than 1,000 square metres (sqm).

Notably, Aldi and Lidl told the CMA that they did not intend to make representations in response to the provisional decision.

The Order

The Order was originally introduced following the Competition Commission’s (CC) 2008 groceries market investigation, with the aim of remedying the adverse effect on competition found by the CC in relation to highly concentrated local markets for the supply of groceries by mid-sized and larger grocery stores, and the control of land in highly concentrated local markets by incumbent retailers. The Order aims to prevent large supermarkets from using certain land agreements to block competitors from opening nearby stores. In particular, the Order prohibits LGRs from entering into:

1. restrictive covenants that may restrict grocery retailing on nearby land, except in limited circumstances
2. exclusivity arrangements that prevent competing grocery retailers from operating on a site for more than five years

The Order also requires LGRs with a strong market position in a highly concentrated local market:

1. to release any existing restrictive covenants that may restrict grocery retailing
2. not to enforce any exclusivity agreements in those local markets

For the latter requirement to apply, a relevant party must have notified the CMA of the restrictive covenant or exclusivity agreement, and the CMA must have confirmed that it exists in a highly concentrated local market.

When introduced in 2008, only seven large supermarkets were designated as LGRs and were therefore required to comply with its terms. The designated supermarkets were Asda, Co-op, Marks and Spencer, Morrisons, Sainsbury’s, Tesco, and Waitrose. However, the Order provided for the designation of additional grocery retailers as LGRs if they:

1. operate ‘Large Grocery Stores’[1] throughout Great Britain, Northern Ireland, or both, or in a considerable part of the UK
2. carry a full range of ‘Groceries’[2] for sale at the retail level
3. have an integrated grocery wholesaling function that purchases directly from the grocery suppliers

Aldi and Lidl were not designated as LGRs when the Order was introduced. They were instead considered to be Limited Assortment Discounters (LADs). This reflected their more limited product ranges and low-price business models at that time.

Final decision

Having reviewed the evidence presented on their current operations, the CMA has found that Aldi and Lidl no longer qualify as LADs within the meaning of the Order. Whilst they both continue to sell groceries at low prices, they no longer carry a significantly more limited range of Groceries than an LGR. They now, in fact, meet the criteria for LGRs based on the following:

1. store footprint and geographic coverage: they both operate Large Grocery Stores i.e. with a shopfloor area of more than 1,000 sqm throughout Great Britain or Northern Ireland
2. product range: they both carry a full range of Groceries, although they may offer less choice within some specific categories than some of the existing LGRs
3. procurement model: they both purchase Groceries directly from suppliers through an integrated grocery wholesaling function

Accordingly, the CMA’s decision is that Aldi and Lidl are designated LGRs under the Order due to the scale and geographic coverage of their stores, their full range of Groceries, and their procurement models. Additionally, the CMA recognises that, based on the evidence presented, Aldi and Lidl now hold significant market shares (although market share is not a designation criterion), ranking them amongst the top five retailers in the UK’s food and grocery market – which is worth an estimated £222.7 billion.

In response to a CMA request in 2025, the evidence provided by Aldi and Lidl indicated that a significant proportion of their land agreements may contain relevant restrictions that could fall within the Order:

• Aldi carried out a 10% sampling exercise of its existing land agreements, and 50-60% contained a restriction on grocery retailing
• Lidl GB carried out a 10% sampling exercise of its existing land agreements and 10-20% contained a restriction on grocery retailing
• Lidl NI reviewed all its existing land agreements and 20-30% contained a restriction on grocery retailing

However, the CMA has emphasised that it has not conducted a detailed assessment of those agreements against the Order.

Next steps

Now that Aldi and Lidl have been designated as LGRs, they will be subject to the same controlled land requirements as the existing designated supermarkets. As such, existing agreements may be reviewed by the CMA at the request of interested landowners, developers and competing supermarkets. Additionally, Aldi and Lidl cannot include prohibited restrictions in new agreements or enter exclusivity arrangements that contravene the Order.

The CMA’s decision will therefore require Aldi and Lidl to review their existing property agreements to identify any restrictions that may be caught by the Order. In particular, any existing restrictive covenants and exclusivity arrangements may become unenforceable and need to be released.

How we can support you

Our Competition and Foreign Investment team has extensive experience advising on the application of the Order and broader competition law to land agreements. If you would like to understand how the rules apply further, please don’t hesitate to get in touch.

[1] Large Grocery Stores are defined by the Order as grocery stores with a net sales area of more than 1,000 sqm.

[2] Groceries are defined by the Order as food (other than that sold for consumption in the store), pet food, drinks (other than those sold for consumption in the store), cleaning products, toiletries and household goods; but excludes petrol, clothing, DIY products, financial services, pharmaceuticals, newspapers, magazines, greetings cards, CDs, DVDs, video and audio tapes, toys, plants, flowers, perfumes, cosmetics, electrical appliances, kitchen hardware, gardening equipment, books, tobacco and tobacco products.