Competition and Markets Authority publishes informal guidance on LENs

On 23 January, the Competitions and Markets Authority (CMA) published guidance relating to LENs. This follows an approach by us a year ago, inviting them to review the LENs model, how it works, and to assess to what extent competition law issues may apply.

In this post, Simon Miller, 3Keel’s Managing Director, explains the significance of the guidance and how it might help others who want to drive forward collaboration in sustainability programmes.

When we started 3Keel 13 years ago, the aim was to develop and pursue programmes that make a difference on the ground. Early on my co-founder Tom Curtis recognised the need for landscape-scale solutions, and our initial scoping, research and pilot work led in time to the development of the LENs model, which is now widely recognised

Over the course of LENs’ evolution, we have repeatedly encountered the question from funders and other stakeholders about the potential for the collaborative LENs approach to come under scrutiny from the CMA. There’s nothing new here. In my 25+ years in the sustainability sector, fears over the perception of anti-competitive behaviour have stalled a number of innovative collaborative solutions with high potential to change the status quo. I get it – no one wants to risk being responsible for drawing their organisation into disrepute or unclear legal territory for trying something new. However, “fears over perceptions” are very easily flagged but much more difficult to dispel.

Given this naturally precautionary approach to competition law, if we want LENs – and other collaborative models – to secure the comfort of potential participants, then this inherent challenge must be addressed. And so about 12 months ago, as we were overhauling the LENs processes and procedures, we approached the CMA and invited them to review the LENs model, how it works, and to assess to what extent competition law issues may apply. We wanted to be proactive and to invite scrutiny, rather than let uncertainty linger in the background, potentially undermining the willingness of organisations to act.

Those familiar with the CMA will know it is duty bound to advise caution and to highlight all areas of concern. The CMA does not casually dish out “there’s nothing to worry about” verdicts from its investigations. As such, last week’s guidance on LENs does identify elements where care is needed. But from our own interpretation and a discussion with a LENs partner’s legal counsel, the CMA’s findings are overwhelmingly positive. The topline statement is “the CMA has advised that we would not expect to take enforcement action against the LENs 2.0 scheme framework, subject to a number of conditions set out in the informal guidance”. The three areas highlighted in the CMA report for consideration make sense, and all three have already evolved in the LENs model since the CMA did its assessment in summer 2025.

Credit is due to the conviction of the LENs team led by Donald Lunan for initiating the engagement. Thanks to the CMA for the detailed work conducted and the 23-page report.

Early on in my career in the 2000s, I did many presentations trying to bring to life the environmental warning signs and to make the case for action to reduce impacts and build more resilient systems. Back then, one of my slides used the Chinese proverb “If you do not change direction, you may end up where you are heading”. Twenty-odd years on, this applies more than ever, and to achieve change needs different ways of operating. I am delighted, therefore, that the LENs team has leaned into one of the reservations inherent in landscape collaborations, and that we now have this positive and constructive feedback from the CMA to draw from.

Given our deep belief in the need for collaborative action, we hope the detail in the report helps others doing similar work. We are passionate about accelerating change and are more than happy to discuss the report’s findings or other elements of the LENs approach.

If you would like to find out more about LENs, contact the team at lens@3keel.com or contact Donald using the form.