You may know that DEFRA have published their “white paper” on the reform of the VSA (currently the Veterinary Surgeons Act, though this is likely to be subject to a change of title). You can access the full document here.
If you do have the time to read through the document in detail, you may notice some slight inconsistencies. These can occur when documentation is produced earlier than planned ahead of significant changes to government personnel. Whilst there are some details which need to be clarified, it is great to see that the reform of the VSA is progressing.
For the behaviour sector in particular, there are some strong positives coming out of the white paper, but also some notable disappointments – please see a summary below.
CCAB Certification are in direct contact with both DEFRA and the RCVS and have also requested updates from the recently formed AVP (Allied Veterinary Professionals) working group, lead by one of the RAMP (veterinary physiotherapy) representatives. This group does not yet have official recognition from DEFRA or the RCVS, but CCAB Certification have reached out to offer our support, cooperation and to be kept informed.
We encourage all of you to read the white paper and let us know if you have any questions or concerns you would like us to put forward to DEFRA or the RCVS/future regulator of our sector.
We continue to work hard to represent CCABs and to strive for the highest standards – not only in clinical approach, but also in regulation.
The CCAB Certification Committee
Positives from the white paper
CCAB Certification participated during all stages of the DEFRA consultation (via the online consultation, the in-person workshops, the focus group meetings and by in-depth interview). We wanted to ensure that should legal regulation of the behaviour sector go ahead (which we are in strong favour of), that regulation was appropriate, proportionate and beneficial for CCABs as well as the animals and clients we work with.
The white paper discusses the regulation of individual practitioners and of businesses and we feel DEFRA have taken on board the views of CCAB Certification regarding the small companies (often individual practitioners) which are common in our sector.
Transition periods and timely implementation of new regulations are discussed, another point we (and other AVP groups) raised.
The Licence to Practice regulatory model and the proposals for the mechanisms of regulation seem suitable for the behaviour sector.
AVPs are likely to have protected titles, with the work they do being the remit solely of those holding that title. The specific titles for AVPs may come in secondary, rather than primary legislation, meaning it is more adaptable to change in the future.
“The regulator” is proposed to be a remodelled version of the RCVS (which is likely to be renamed), where non-vets would sit on the board alongside vets, with over-arching representation for AVP groups too. The RCVS have previously stated an interest in regulating the clinical animal behaviour sector (see their report from the RCVS Fellowship Science Advisory Panel’s Animal Behaviour Working Party from March 2025). The RCVS express that the nature of the work done by clinical animal behaviourists is tantamount to an act of veterinary surgery via clinical assessment, having a logical, evidence-based approach and using interventions which can directly impact the emotional and cognitive health of the animals under the care of the practitioner. CCAB Certification feel the RCVS were well-placed to regulate CCABs given the clinical approach our practitioners take, our alignment regarding standards for CPD and regulation and we believe that a remodelled RCVS-style “regulator” would also be well-placed to perform this role. Ultimately, if this goes ahead, it is likely that all current clinical animal behaviour regulators would hand over regulatory responsibilities to the RCVS. Existing companies may remain as assessing organisations – this will be determined in later discussions.
Disappointments from the white paper
The main cause for concern coming out of the white paper is the lack of clear commitment from DEFRA that the behaviour sector would be included in the AVP groups, and at what stage. There is conflicting information on this in the paper, which CCAB Certification will seek clarification on. The following statements are included:
In possible future legislation, anyone performing veterinary or animal healthcare activities on any ’animals’ must hold a licence to practise. Conducting veterinary or animal healthcare activities without a licence to practise will be a criminal offence. It is important that the definition covers the activities currently undertaken by registered veterinary professionals. It must also be broad enough to align with the activities undertaken by many AVPs. We will decide on the precise definition before bringing forward the new legislation. It will likely give the regulator the ability to regulate ’veterinary and animal healthcare activities’, which could include, but are not limited to:
– examination and diagnosis of diseases, injuries, disorders or abnormalities in animals, including the performance or interpretation of diagnostic tests
– provision of advice, recommendations or care plans based on assessment or diagnosis, enabling opportunities for care to be continued by owners and carers
– medical, surgical, and therapeutic treatment of animals – this includes corrective, rehabilitative, supportive, and maintenance interventions
– performance of surgical operations, including anaesthesia
[CCAB Certification feels this clearly includes the work CCABs perform, as outlined previously by the RCVS]
At times, the list of AVPs is said to be likely to include:
which is clearly positive. However, one section discusses the timeline for onboarding the new regulation and states:
We propose to implement regulation in tranches to ensure a safe and orderly transition. This will allow sufficient time to develop profession-specific standards, education and fitness to practise requirements, and appropriate transitional arrangements.
The first professions for regulation will be:
The next tranche will include:
Possible further AVPs for regulation:
Whilst CCAB Certification recognise that not all AVPs can have regulation changed over simultaneously, we find the lack of certainty/commitment regarding regulation of the clinical animal behaviour sector disappointing and will campaign for this to become a certainty in our ongoing discussions with DEFRA and the RCVS/regulator.
