Why the M&J Case Became a CMA Enforcement Landmark
The CMA's first civil penalties against individuals for concealing evidence during an investigation.
Last verified: 5 October 2026
IMPORTANT DISTINCTION
The penalties described on this website concern failures to comply with CMA investigative requirements during an inspection.
The separate CMA investigation into suspected bid-rigging remains ongoing.
The CMA has expressly stated that no assumption should currently be made that competition law has been infringed.
The CMA described the penalties imposed on Barry Pirrie and Tracey Woods as its first civil penalties issued against individuals for concealing evidence during an investigation.
This makes the M&J case significant beyond the company itself. It signals the regulator's willingness to impose personal financial penalties on individuals — not only companies — where evidence is concealed or misleading statements are made during an inspection.
Why This Matters
Construction companies — individual directors and staff can now face personal penalties, not just corporate fines.
Directors — personal liability attaches to conduct during inspections, not only to the company.
Estimators and office managers — any employee who acts on an instruction to conceal evidence may be penalised.
Procurement professionals — evidence preservation obligations apply throughout the supply chain.
Competition-law compliance teams — dawn-raid protocols must cover individual conduct, not just corporate procedure.
The Individual Penalties
- Barry Pirrie (Estimating Director) — £20,000
- Tracey Woods (Office Manager) — £5,000
These penalties are separate from the £25,000 penalty imposed on M&J Group itself.
CMA press release, 24 September 2026 — describing the penalties as the first of their kind for evidence concealment [S002]