Veterinary Surgeons Act
What's the issue?
The current Act was designed for a different era. Nearly 60 years later, more than half of UK households now have a pet, technology has changed dramatically, and the way vets care for animals has been transformed. Key issues include:
- Vets are regulated, but the veterinary practices they work for are not – this means individual vets and nurses are held accountable for business decisions which are often outside their control, but can directly impact animal health and welfare.
- Anyone can call themselves a veterinary nurse - highly skilled and qualified, registered veterinary nurses work closely with veterinary surgeons, yet no formal training or qualifications are actually required for someone to call themselves a ‘veterinary nurse’
- There is no recognition of the wider vet-led team - Vets are closely supported by registered veterinary nurses, vet techs, musculoskeletal professionals and equine dental technicians and others, which are now an essential part of veterinary care, yet their roles are not recognised in the current Act.
What’s our view?
We strongly support reform of the Veterinary Surgeons Act 1966.
We need new primary legislation that modernises the regulatory framework, making it fit for purpose and protects the title ‘veterinary nurse’. This will benefit animal health and welfare, delivery of veterinary care and retention of veterinary professionals.
For details on the changes we’d like to see, read our response to the RCVS legislative reform consultation.
What are we doing?
We’ve long been calling for reform of the Act, making it a priority in our manifesto for animals, vets and public health, and using every opportunity we can to highlight it’s importance to decision makers.
We’re pleased to be part of a core working group formed by Defra, alongside key organisations including RCVS, BVNA and VSC, tasked with developing the detail of draft recommendations for Ministers
We working to ensure veterinary surgeons are protected by any new legislation, and that key areas such as regulation of practices, recognition of allied professionals and legal protection for the veterinary nurse title are included.
Support for reform of the Act is growing:
- The Government confirmed their commitment to the reforms in February 2025, at our annual London Dinner. Minister for Environment, Food and Rural Affairs Daniel Zeichner said: “I think each [Ȥҹapp] dinner I've been to, the Veterinary Surgeons Act has come up. We absolutely understand it. We’re engaging with you and with the other stakeholders from the RCVS, the BVNA, the Vet Schools Council, to look at how we can go about reforming the VSA and that core working group is looking at how changes to policy can support the profession, animals and consumer in a future facing and future proof way.”
- We welcomed the CMA’s clear recognition of the urgent need for veterinary legislative reform, as part of their Market Investigation into UK veterinary services for household pets.
Webinar recordings
Watch our three-part webinar series, focusing on reforming the Veterinary Surgeons Act:
PART 1
PART 2
PART 3
Regulation
Regulation is the legal way something, like a profession or industry, is controlled to ensure public interest is protected and practices are fair.
Vets are regulated by the Royal of College of Veterinary Surgeons (RCVS) via the Veterinary Surgeons Act 1966 (VSA) and The Royal Charter 2015
A regulator typically holds a register of appropriately qualified and competent professionals, sets and maintains standards, oversees professional education, ensures professional conduct and deals with cases of professional misconduct. A regulator’s main function is to safeguard the public and in the case of veterinary professionals to safeguard animal welfare.
Self-regulation is where the regulator’s decisions are independent of government. It doesn’t mean that members of the profession are regulated by their peers.
Self-regulation has advantages for both the public and the organisations or professionals regulated. The regulator has a deeper understanding of the sector, which can increase responsiveness and flexibility, particularly where a profession is specialised.
Self-regulation can be open to criticism, particularly a perceived lack of transparency and conflict of interest. These concerns can be addressed through appropriate checks and balances.
A Royal College is a professional or academic organisation, that upholds standards of practice, education, and training within a specific field, such as medicine. Royal Colleges are established through a Royal Charter, which is a formal, legal document issued by the Sovereign on the advice of the Privy Council.
A Royal College that regulates is an organisation established by Royal Charter that serves as the official regulatory body for a specific profession. The Royal College of Veterinary Surgeons (RCVS) is unique in this respect. The dual functions provide flexibility but can attract criticism around lack of clarity of function.
General
The current VSA is outdated, and how vet care is delivered has significantly changed. Before 1998, only registered vets could legally own and run vet practices. Today most are not owned by vets and this means that practices are unregulated. In addition Registered Veterinary Nurses (RVNs) are not fully recognised in law, and other allied professionals working as part of the veterinary team are unregulated.
Linking a reformed Veterinary Surgeons Act to the Animal Welfare (Sentience) Act 2022 is being considered, so as that Act potentially changes in the future so would the species covered in the veterinary Act. This would mean vertebrates, including fish, as well as decapod crustaceans and cephalopod molluscs would currently be included in a new VSA.
This hasn’t been decided yet.
Practice regulation
Under reformed legislation, the exact definition of a veterinary practice will need to be decided. It would likely include any entity which provides veterinary clinical care/services (whether that service is paid or unpaid) that is delivered in the UK. This would include ambulatory services and educational establishments, where clinical care is provided. The definition would include businesses run by non-vets, including RVNs or allied veterinary professionals (AVPs).
Workplaces that do not provide clinical services would not be regulated by the new Act, although some may already be regulated under other legislation.
Not all veterinary practices are owned by vets or RVNs. Non-regulated people are currently in influential positions in veterinary practices are able to make decisions that impact on clients and on regulated veterinary professionals. Regulation of practices will make all veterinary business owners responsible. Veterinary practice standards are also currently voluntary, which means that clinical and consumer standards are not ensured.
These are likely to be similar to current RCVS Practice Standards Scheme (PSS) ‘core standards’ but with an enhanced focus on consumer protection. They may include: health and safety requirements; a requirement for suitably qualified, registered, and adequately trained staff; good governance, record keeping and alignment with professional and legal requirements; responsible management and usage of medicines; good leadership and staff welfare; and consumer focussed duties.
The standards will be mandated in law, and all practices will have to meet these minimum standards. This will be assessed through regular practice inspections. Higher level PSS standards are likely to still exist for those practices wanting to be accredited at a higher level.
It has been suggested that responsibility would be at two levels, at company level with senior directors and at a local level with a regulated professional within that practice.
Like the current Practice Standards Scheme this would sit with both the regulator and the Veterinary Medicines Directorate (VMD).
The definition of a veterinary business would be one in the UK, delivering veterinary clinical and animal healthcare/services (paid or unpaid). Businesses in scope, would be any carrying out acts of veterinary surgery? by a licensed veterinary professional (vet, RVN, AVP). This would include clinical services provided by an educational establishment, ambulatory services and businesses run entirely by RVNs or AVPs.
If mandatory practice regulation is introduced, practices must comply with inspections and Powers of Entry can be used, as long as there are appropriate constraints. This would be preferable to the alternatives, such as removal of a practice licence, which could be disproportionate and would negatively impact staff, clients and patient welfare. Practice inspections must however focus on the practice and those responsible, not on other individual registrants.
The CMA has noted that a results in problems for veterinary professionals and clients and supports the concept of veterinary business regulation.
Licence to practise
At the moment vets with an ‘eligible qualification’ can register with the RCVS and practice in the UK. A ‘Licence to practise’ would mean that other things including a declaration of ‘Fitness to Practise’ would be required too. Continuing Professional Development (CPD) would also be mandatory. In reality, this would have very little impact on vets.
In order to comply with the Equalities Act 2010, someone who has not been able to demonstrate their day one competencies due to a disability or long-term health condition, could still be given a Licence to Practise under certain conditions - this will be called a Conditional Licence to practise. Ȥҹapp has made it clear that this must not replace ‘reasonable adjustments’ and that a Conditional Licence should be an absolute exception for those with disabilities.
The option of having a conditional licence to practise means that in the future it may be possible to consider a move away from omni-potential practise for overseas and/or UK-graduated veterinary professionals. This would however require secondary legislation (complete with full professional and public consultation). Ȥҹapp does have reservations that this could be a slippery slope to loss of omnipotential and be damaging for niche species and emergency care provision.
An emergency Licence to Practise could be used in exceptional emergency scenarios, such as a sudden workforce shortage, a public health crisis, or an animal welfare crisis.
Revalidation is likely to take place every few years and include requirements such as a self-declaration of fitness to practise and completion of Continuing Professional Development (CPD). The exact details of revalidation will sit with the Regulator.
Fitness to practise
A Fitness to Practise scheme is a system of ensuring that the Regulator can protect the public, clients, and animals, and maintain confidence in and the reputation of the veterinary professions, by ensuring all those licenced to practice are physically and mentally able to do so safely and effectively.
At the moment the RCVS disciplinary system is ‘punitive’ - based upon previous disciplinary issues, all the RCVS can really do to ensure public and animal safety is remove a vet or RVN from the Register. A fitness to practise system would be forward looking and consider the support that can be provided to ensure people are practising safely, rather than simply focusing on removing individuals from their roles.
Automatic barring offences mean that if someone is convicted of a certain serious offence, they will automatically lose their licence to practise, or be barred from gaining one. These serious offences will include murder, rape/sexual violence, modern slavery, terrorism, bestiality, and drug/human trafficking.
In most situations, for example at revalidation, vets would declare themselves as being ‘Fit to practise’, based upon their own professional judgement. If a concern is subsequently? raised against a registered vet however, a process will be triggered to ensure the person is indeed Fit to Practise or determine whether additional support is needed. Cases will be triaged, and if necessary, move to Case Examiners and then finally unresolved cases would move to a tribunal.
In all fitness to practise cases, the burden of proof (to civil standard) will be on the regulator. Fitness to practice will be based upon current impairment rather than past problems. The case examiners and others involved in fitness to practice will be properly trained and their work audited and reflected upon. There will always be two (sometimes three) people involved. Any health assessments will not be shared with the regulator. Any sanctions must be proportionate, targeted, workable and measurable.
There will be a requirement on employers who are licensed veterinary businesses to initially address health and performance matters internally by putting appropriate support n place through their own processes.
A licence may be removed for certain listed barring offences such as rape and murder. Otherwise, licence removal will only occur where all other avenues of case review, tribunal and appeals have been worked through. Voluntary removal of licence may be permitted during the process for those nearing retirement or not intending to work as veterinary professionals again.
Appeals will be possible at all stages of the process. Appeals against the outcome of a tribunal hearing will be heard by the High Court. Appeals will need to be made within 28 days of the tribunal outcome and will need to meet the High Court’s requirements for an appeal.
Veterinary nurses
Registered Veterinary Nurses are currently regulated under the Royal Charter powers of the RCVS, which means they are not considered ‘members’ of the Royal College in the same way as veterinary surgeons and the title of ‘veterinary nurse’ is not protected in law. Regulation of RVNs would protect the public, empower RVNs to further develop their careers and under certain circumstances to work autonomously (e.g. as district RVNs).
The regulator will decide which tasks can be carried out by regulated veterinary nurses and what level of direction and supervision is required. This will be in consultation with the professions.
Much of the detail of a reformed VSA, that will affect us in our daily working live, will not be in primary legislation but may be covered in secondary legislation and will be included in updated RCVS Codes of Conduct?. As above, the regulator will decide which tasks can be carried out by regulated veterinary nurses and what level of direction and supervision is required. This will be on consultation with the professions. Going forward, RVNs may be able to castrate cats.
Allied professionals
Allied veterinary professionals are other trained professionals who may as part of their work carry out tasks that are considered to be acts of veterinary surgery.
Some allied professionals are already carrying out acts that many would consider to be in ‘grey areas’ under the VSA. Regulation of these allied professionals would help protect animal welfare and ensure public confidence in the veterinary professions.
The regulator will determine which professions are regulated. Considerations might include the procedures being carried out, risk to animal welfare, available training, cohesiveness of the profession.
The regulator will consult on and recommend to government which allied veterinary professionals should be regulated, such as Equine Dental Technicians, Musculoskeletal practitioners, Cattle Hoof Trimmers, VetTechs, Behaviourists and Bare-hoof Trimmers.
The regulator will decide which tasks can be carried out by regulated allied veterinary professionals and what level of direction and supervision is required. This will be in consultation with the professions.
Farriers are in discussion with Defra over their inclusion in a reformed VSA. Bringing farriers into this legislation would ensure that farriery is regulated in Northern Ireland. This would mean repealing the Farriers (Registration) Act 1975, and all aspects set out in this consultation applying to farriers. This would also lead to the abolition of the Farriers Registration Council.
There will continue to be an exemption to allow farmers to carry out acts of minor veterinary surgery and medical treatment on their own animals and this will be in the form of an exemption order that can be made conditional, subject to training.