DEFRA is listening and enforcement is evolving
It’s clear that DEFRA are listening when it comes to enforcement.
The last major update in May 2025 had a significant impact on how licensing is applied. That update focused heavily on improving consistency across local authorities ensuring inspectors are properly trained and supported by a veterinary professional.
Since then, we’ve seen a noticeable shift. More licensed breeders are being asked for structured policies, clearer evidence and stronger justification for how they meet the conditions of their licence.
The April 2026 update builds on that direction.
It doesn’t introduce new legislation, but it does provide more clarity for inspectors particularly around grey areas like preventative healthcare, record keeping and overall accountability.
This is DEFRA continuing to close the gap between what the law says and how it is consistently enforced.
Below, we break down the key updates on what the guidance now says and how that compares to the previous version.
1. Preventative Healthcare Plans
Previous guidance:
The regulations required a preventative healthcare plan, but the guidance gave very little detail on what this should include. In practice, this led to inconsistency with some breeders having structured plans, while others relied on general veterinary input or reactive care. This lack of clarity also contributed to ongoing debates around vaccination protocols, particularly in relation to the use of Lepto 4.
Updated guidance (April 2026):
The guidance now clearly defines what a preventative healthcare plan should include, such as vaccination, parasite control, weight monitoring and body condition scoring. It also reinforces that the plan must be agreed with a vet and implemented in practice.
What this means:
This is a move from “having something in place” to being able to demonstrate a structured, preventative approach to health.
2. Vaccination vs Titre Testing
Previous guidance:
Vaccination has always been a key part of preventative healthcare, with inspectors routinely expecting to see vaccination records as evidence.
Where the guidance was less clear was in how alternative approaches, such as titre testing, should be assessed. This led to variation between local authorities, particularly where breeders were working with vet-supported non-vaccination protocols.
Updated guidance:
Vaccination continues to sit within preventative healthcare expectations, and inspectors will still expect to see evidence of disease control as part of a vet-led health plan.
The key addition within the updated guidance is the clearer clarification under section 9.4 — that a veterinary certificate of a valid titre test may be accepted instead of a booster vaccination, and that the decision to vaccinate or titre test remains with the licence holder, supported by their vet.
This is an important distinction. The guidance does not mandate vaccination, but it does require a clear, evidence-based approach to disease prevention, with both vaccination and titre testing recognised as valid options where appropriately supported.
In practice, this is likely to bring existing tensions into sharper focus. A number of breeders are choosing not to use Lepto 4, while many veterinary practices continue to recommend it as the standard protocol. With limited availability of alternatives such as Lepto 2, this can create challenges when agreeing a preventative healthcare plan that satisfies both breeder preference and local authority expectations.
What this means:
Breeders using titre testing are not breaking the law and are supported within the guidance, but they must be able to clearly evidence their approach through a vet-agreed, documented preventative healthcare plan.
As expectations around consistency increase, alignment between breeder, vet and licensing authority becomes critical in how this is interpreted and applied in practice.
3. Breeding Bitch Record Keeping
Previous guidance:
The guidance now reinforces the need for detailed records, including number of matings, age at mating, number of litters, dates of birth and caesarean history.
All of this can be easily recorded and evidenced within the Digital PawPrint, helping breeders demonstrate compliance in a structured and inspection-ready format.
What this means:
Inspectors are increasingly looking for data-driven evidence, not just general records written the night before a inspection. They want quality assurance and date stampted data with Breeders showing clear breeding histories for each dog.
4. Rehoming and Lifecycle Responsibility
Previous guidance:
Responsibilities around the long-term welfare of dogs, including rehoming and end-of-life decisions, were already clearly set out within the regulations and supporting guidance. Breeders were required to make appropriate arrangements for dogs no longer used for breeding and to ensure their welfare needs continued to be met.
Updated guidance (April 2026):
The updated local authority guidance does not introduce a new requirement, but it places greater emphasis on the need for breeders to clearly evidence lifecycle responsibility in practice and to be able to demonstrate this at any point during an inspection.
This is where having structured systems in place becomes increasingly important. Tools like the Digital PawPrint and Policy Assistant are designed to help breeders document, manage and evidence these responsibilities in a consistent and inspection-ready format.
What this means:
Licensing has not expanded in scope, but it is now being applied more rigorously.
What was previously expected as part of general welfare is now something inspectors are far more likely to ask for, assess, and expect evidence of.
Licensing is no longer just about breeding it now clearly includes full lifecycle responsibility. However, this is where challenges starts to emerge. Under the higher standards, there are limits on the number of dogs permitted per staff member and premises. While these limits are designed to protect welfare, they can create unintended problems. For example, breeders are sometimes contacted by rescues to assist in rehoming dogs they originally bred. In some cases, taking that dog back could push them beyond their licensed capacity and effectively preventing them from helping.
This creates a difficult position for licensed breeder acting in the best interests of a dog’s welfare as they will be constrained by the very system designed to protect it. In some situations, the only practical option may be to operate at a lower star rating to allow for greater flexibility. Our advice would be to create a section in the policy that highlighs this issue and ask for a sign-off from your council, hoping that licensing officers can demonstrate practical flexibility to ensure that good welfare decisions are not inadvertently restricted.
5. Separation of Activities on Premises
Previous guidance:
The requirement to manage risks associated with different activities on the same premises has always been embedded within the guidance, particularly in relation to disease control, hygiene and animal welfare. This included expectations around appropriate separation where necessary to protect animals.
Updated guidance (April 2026):
The updated local authority guidance provides clearer direction on this point, stating that breeding activities should be kept separate from other animal-related activities, ideally within separate buildings or clearly defined areas.
What this means:
This is not a new requirement, but a clearer expectation of how separation should be demonstrated in practice.
For breeders operating mixed-use setups, such as those breeding both dogs and cats or combining breeding with other licensed activities, this may require a more structured approach to how separation is managed, documented and evidenced.
In practice, this is likely to reduce variation between local authorities, but may also lead to closer scrutiny of premises where multiple activities take place.
6. Higher Standards and Breeding Limits
Previous guidance:
Higher standards and breeding limits were already clearly defined within the 2018 regulations and supporting guidance. This included expectations around age at breeding, number of litters, caesarean sections and overall health considerations, with higher standards linked to the star rating system.
Updated guidance (April 2026):
The updated local authority guidance does not introduce new breeding limits, but it reinforces how these should be assessed and evidenced as part of the inspection process, particularly in relation to record keeping and individual dog histories.
What this means:
Breeders should expect greater scrutiny of breeding records, with inspectors more likely to review full histories for each dog, including breeding frequency, age, health outcomes and interventions such as caesarean sections.
Having a structured system in place makes this significantly easier to manage and evidence. Within the Digital PawPrint, this information can be recorded and tracked through the dog’s diary and welfare tabs, creating a clear, consistent history that can be demonstrated during inspection.
This is less about new rules, and more about ensuring that existing limits are clearly documented, traceable and consistently applied across local authorities.
7. Business Test and Licensing Thresholds
Previous guidance:
The business test relied on HMRC badges of trade and is often misunderstood by everyone and inconsistently applied.
Updated guidance (April 2026):
The guidance reinforces that individuals can still be classed as a business depending on their activity, regardless of structure, and highlights indicators such as advertising, frequency of sales and profit.
A common misconception is that breeding from a home environment means you are not operating commercially. In reality, the setting is not the determining factor it’s the level and nature of the activity.
For example, a breeder operating from a domestic property, advertising multiple litters per year, selling puppies at market rates, and generating a consistent income from those sales may still meet the definition of a business under the regulations even without a dedicated facility.
In many cases, these are well-run setups in good environments, often in affluent areas, but the key point remains the same: commercial activity is defined by behaviour, not by whether it takes place in a home or a purpose-built premises.
What this means:
We are likely to see more consistent identification of unlicensed breeders operating commercially.
Final Thoughts
The April 2026 update is not about introducing new rules it’s about removing ambiguity.
For years, one of the biggest challenges in licensing has been inconsistency. Different councils interpreting the same rules in different ways.
This update is a clear step towards standardisation.
Inspectors now have clearer guidance.
Which means breeders need clearer evidence.
If you can demonstrate what you do, why you do it, and how it meets welfare requirements, you remain in control of your licence.
