https://consult.defra.gov.uk/defra/trail-hunting-consultation/

Sector Impact Statement: Equine Welfare, Employment and Associated Businesses

Executive Summary

This submission sets out the British Equine Veterinary Association’s (BEVA) evidence on the potential impacts of the proposed prohibition on trail hunting for equine welfare, employment within the veterinary and allied professions and businesses associated with equestrian activity. BEVA does not comment on the policy intent of the proposed legislation.

Sector evidence cited to this consultation indicates that over 6,000 horses are kept primarily for hunting, with associated costs estimated at up to £86 million per year, and that hunting-related activity contributes around £100 million annually to the rural economy, supporting veterinary services, farriery, transport, feed supply and fallen stock provision.

Given the scale and concentration of horses and services involved, BEVA highlights the importance of a full impact assessment of any ban on the availability of veterinary and other equine services, the rural economy and rural society.

BEVA’s interest

BEVA represents veterinary surgeons and nurses providing care to horses, ponies and donkeys across the UK. Its interest in this consultation relates to equine welfare outcomes and the operational resilience of veterinary and allied professional services, rather than the policy rationale for the proposals.

Scale and economic exposure

Evidence submitted by equestrian organisations indicates that thousands of horses are kept primarily for hunting‑related activity and that this activity supports a significant network of rural businesses, including equine veterinary practices and allied professional services. The concentration of horses and services linked to a specific activity is highly relevant when considering the indirect welfare, employment and business impacts caused by legislation leading to sector changes.

Equine welfare considerations

From a veterinary perspective, the principal welfare risk associated with sector disruption is that, where large numbers of horses are maintained for a single activity, sudden removal of that activity will have a negative impact on the availability of routine veterinary care, alongside other animal health care services (e.g. farriery) and increased reliance on reactive welfare interventions. These risks are well recognised in previous structural changes affecting the sector.

Impact on employment and services

Equine and mixed veterinary practices, particularly in rural areas, commonly operate on portfolio and seasonal demand models. Material changes affecting horse populations in specific regions will impact:

1. the viability of some equine ambulatory services;

1. recruitment, retention and workload of some equine veterinary and allied professionals; and

1. The demand for, and therefore availability and access to, allied services such as farriery, transport and fallen stock provision.

These services form part of an interconnected rural employment base, and reductions in activity may have wider workforce implications beyond individual businesses.

Transition and mitigation

BEVA considers that the impact of any prohibition on horse welfare, rural employment and the availability of equine veterinary and allied services must be assessed prior to any legislation being passed. This may allow mitigations to be put in place.

Conclusion

BEVA’s evidence relates to equine welfare, employment, and business continuity within the veterinary and equestrian sectors. Given evidence that thousands of horses and a substantial rural workforce may be indirectly affected, BEVA highlights the importance of recognising sector scale and assessing the wider animal welfare, economic and social impact of any prohibition. BEVA would welcome continued engagement to support these aims.

Medicines and Medical Devices Act 2-Year Report 2026: Questionnaire

Please provide views on The Veterinary Medicines (Amendment etc.) Regulations 2024

Legal Background (A12/A13)

We would ask for a commitment to an interim update once EU agreements are finalised, rather than waiting for the next annual review cycle.

Stakeholder Notifications (A52, A53, A56)

There is a sensible existing commitment that Defra will inform national stakeholder organisations, but this assumes that the relevant Defra team maintains a current and appropriate contact list of the appropriate species / industry stakeholders. It would be important to recognise, for example, that the BVA’s reach into equine veterinary practices would be very small by comparison to BEVA’s reach and the same would be true about the NFU’s reach into the equestrian community compared to the combined reach of the BEF and BHS...

Mass-Messaging (A61, A62, A63)

The communications system relies on RCVS, Improve International and livestock keeper databases. Horse owners are a large, dispersed population that sits largely outside these systems, and the plan does not acknowledge this gap or explain how equine keepers would be reached rapidly in an outbreak. The mandatory equine passport and microchipping system provides a framework that could be directly relevant in an outbreak. This is particularly relevant in light of the active work on uprating the digital equine identification system.

Lessons Identified (A298–A302)

A302 commits to compiling a Lessons Identified Report but makes no commitment to publishing it. We would ask that this commitment is made explicit — it is straightforward good governance and consistent with the transparency referenced in the ministerial foreword.

Part B — Preparedness

On exercises (B20), we support the suggestion that the plan be updated to reflect PAC recommendations. On the Outbreak Preparedness Indices (B59–B64), we would ask that these are shared and discussed with relevant industry stakeholders. Those organisations may be well placed to identify practical improvements, and transparency here would strengthen broader confidence in preparedness.

Executive Summary of BEVA response

Consultation: Reform of the Veterinary Surgeons Act 1966

The British Equine Veterinary Association (BEVA) broadly supports the Government’s proposals to reform and modernise the Veterinary Surgeons Act 1966. The current legislation no longer reflects the realities of modern veterinary practice, the wider veterinary team, or the evolving structure of veterinary businesses, particularly in context of what is now a very broad industry offering animal healthcare provision. Reform is therefore necessary to safeguard animal welfare, strengthen public confidence, and ensure a sustainable veterinary workforce.

Key BEVA Positions

1. A modern regulatory framework for the whole veterinary team and all animal healthcare providers
BEVA supports a unified licensing system covering veterinary surgeons, veterinary nurses, and allied veterinary professionals (AVPs)/animal healthcare providers. Bringing currently unregulated roles—such as equine dental technicians, musculoskeletal practitioners, barefoot trimmers and behaviourists—into statutory regulation is essential to close welfare and accountability gaps and improve public protection. Furthermore, the inclusion of other regulated animal healthcare providers, for example, farriers and suitably qualified persons (SQPs; registered animal medicines advisors) within the same overarching regulatory framework would promote greater coherence, consistency, and clarity across the animal health sector.

2. Clear scopes of practice and title protection
Legal protection of professional titles and clearly defined scopes of practice will improve transparency for animal owners and allow safe delegation within veterinary teams. This will support more efficient use of skills across the workforce while maintaining high welfare standards.

3. Proportionate regulation of veterinary businesses
BEVA strongly supports the introduction of mandatory regulation for veterinary and animal healthcare businesses. Regulation should be risk-based, proportionate and outcomes-focused, ensuring accountability at organisational level without imposing unnecessary burdens—particularly on small businesses, equine ambulatory and rural practices. Regulation must not be duplicated, for instance by the new regulator, Veterinary Medicines Directorate (VMD) and/or Health and Safety Executive (HSE).

4. A modern, supportive fitness-to-practise system
BEVA supports moving to a fitness-to-practise model based on current impairment, aligned with other UK healthcare regulators but proportionate to the risk posed. The system should prioritise public protection while enabling remediation, ensuring fair processes, clear decision-making guidance and strong safeguards around interim orders and timeliness.

5. Governance reform and independent oversight
BEVA supports reform of regulatory governance to improve transparency, independence and accountability. This includes:

• We consider that maintaining a Royal College that regulates offers broader opportunities at a lower cost than a Split Model.
• independent appointments and lay parity on regulatory boards
• transparency of regulatory finances
• external oversight similar to the Professional Standards Authority (PSA) model.

Implementation priorities

While supporting the direction of reform, BEVA emphasises that implementation must:

• remain proportionate and risk-based
• recognise the distinct characteristics of equine healthcare provision, particularly ambulatory work and small businesses common in this sector
• avoid workforce disruption through appropriate transitional arrangements
• ensure regulation covers all providers delivering animal healthcare, including remote and allied services, and those visiting from overseas.

Overall view

BEVA believes reform of the Veterinary Surgeons Act presents a once-in-a-generation opportunity to modernise veterinary regulation. If implemented carefully, the proposed changes can strengthen animal welfare protections, improve consumer confidence, support the veterinary workforce and ensure the regulatory framework is fit for the future.

BEVA response

We urge the Competition and Markets Authority (CMA) to revisit the recommendations presented at last year’s London Vet Show concerning the alteration of the cascade to enhance price controls. The omission of this crucial measure from the current remedies document is a missed opportunity to foster a more competitive and fairer marketplace.

We propose that under the established use licensing route, veterinarians should not be restricted from using cheaper human medications unless there is a demonstrable, clinically significant benefit of the veterinary formulation.

This approach would prevent unnecessary cost burdens on practices and clients, especially when formulations are identical or have only negligible differences. It provides a practical, forward-looking solution that has not been addressed previously and helps balance market fairness with animal welfare.

At the same time, this approach protects investment by the pharmaceutical industry into genuinely novel veterinary formulations or new products by reserving exclusivity for innovations that offer clear and clinically relevant advantages.

Following publication of the CMA report, BEVA put out the following to members (eNews April 2026)

CMA Report: Key Messages for Equine Practice

The CMA report into veterinary services is focused on companion animal practice, but there are some important implications for equine vets:

1. No direct impact for equine-only practices
The CMA remedies being developed by the RCVS won't directly impact equine-only practices, although the companion animal element of mixed practices will fall within scope.

2. Possible indirect effects via the Practice Standards Scheme (PSS)
Changes to the PSS might be expected; these could cover consumer-focused elements such as pricing transparency and client communication. These may affect PSS member equine practices and mixed practices, but there would be expected to be consultation over any future changes.

3. Changing client expectations
As systems change in companion animal practice, equine clients may begin to expect similar levels of transparency and service from their equine practices.

Summary
While the CMA report does not directly target equine practice, indirect impacts are likely.

BEVA responded with the following:

Please find below a response from the British Equine Veterinary Association (BEVA) with regards to the Issues Statement and referring to the “Cascade”:

The Cascade was initially designed to ensure continuing access to many drugs for veterinary surgeons. However, the way it has been implemented and the practical application of it has had quite the opposite affect, particularly in equine practice. The CMA will be aware that the Cascade has recently been strengthened to make a failure to comply potentially a criminal offence. In view of this, and the complexity of the legislation, many veterinary surgeons are fearful to use the full scope of the Cascade.

The Cascade has had a very anticompetitive effect and has resulted in unexpectedly high drug costs, about which the CMA have raised concerns. In 2014 Equisolon was licensed for use in horses. Equisolon was a preparation of prednisolone, a drug first approved for medical use in 1955. This was listed on the practice management system of Donnington Grove Veterinary Surgery in 2014 at a cost (to the veterinary surgery) of £80, or £13.44 per gramme of active ingredient. Prednisolone tablets (5mg) were listed on the same practice management system at a cost of £1.60 per gramme. In 2010 Prascend was licensed for “Cushings Syndrome” in horses, a preparation of the drug pergolide. Using the practice management system of Donnington Grove Veterinary Surgery this cost £150.49 for 160 1mg tablets, 94p per 1g tablet, while 1g tablets of generic Pergolide cost 35p.

There is a very simple solution to this issue. Veterinary Surgeons are specifically forbidden from using financial considerations when choosing a drug for use under the Cascade. It should be evident that this will often result in the demise of the horse - in almost all cases Veterinary Medicine is a resource limited discipline. This restriction on financial considerations should be lifted forthwith. This would allow a Veterinary Surgeon to present options to a client, exactly as the CMA is seeking. For instance, a Veterinary Surgeon would be able to offer a choice of a licensed preparation, with high standards of manufacture and testing, and some degree of security that the Drug Company might stand behind the product if there was an adverse reaction, or an unlicensed preparation at a lower cost, which might permit continued treatment of an animal when financial constraints were limiting treatment options. It should be evident that the public are already very familiar with this choice - everyone is used to choosing between, say, Weetabix or Tesco Wheat Biscuits Cereal.

The Veterinary Medicines Directorate is seeking views from stakeholders to inform future reform of the UK’s veterinary medicines regulatory framework.

Deadline 26th September 2025