Part 3: Enforcement of consumer protection law Undertakings Section 186: Effect of undertakings under section 185
This section prevents the CMA, once it accepts an undertaking under section 185, from giving a final infringement notice (under section 182) or an online interface notice (under section 184) to the same enforcement subject in relation to the same matter (subsections (1) and (2)). The underlying policy intent is that undertakings are an alternative to final infringement or online interface notices and therefore the effect is that a person cannot be subjected to multiple enforcement resolutions of the same matter.
	Nevertheless, subsection (3) provides that, where the CMA accepts an undertaking from a person, it is not prevented from giving a final infringement notice or online interface notice to that person) in circumstances which:
either are not covered by the undertaking, or
cast doubt on the effectiveness of the undertaking to stop or prevent the consumer detriment because of reasonable grounds for suspecting non-compliance with the undertaking (subsection (3), paragraph (c)), or a change to, or revelation regarding, the basis on which the undertaking was accepted (subsection (3), paragraphs (b) and (d)).
	However, subsection (3) does not remove the need to meet the threshold requirements in sections 182 and 184 before a final infringement notice or an online interface notice is given, i.e. subsection (3) does not permit the CMA to automatically issue a final infringement notice or online interface notice.
	Subsection (4) has the effect that undertakings are to be treated as released from the date the CMA gives a final infringement notice or an online interface notice in the circumstances set out in subsection (3) paragraphs (b), (c) or (d).