On Tuesday 27th January 2026, Defra launched a consultation on potential reform of the Veterinary Surgeons Act, and what future veterinary legislation could look like.

We recently held a Q&A discussion to help veterinary nurses digest the purpose and content of this consultation, which generated some excellent questions amongst the audience. Unfortunately, we didn’t have time to answer them all, so this blog will address the questions which were still outstanding.

If you have any further questions, please refer to the Frequently Asked Questions available via the Defra consultation page. Alternatively, please feel free to contact us at bvna@bvna.co.uk.

Q1: My current largest barrier is that I am feeling quite out of my depth to fully feel like I am contributing to the consultation in the most useful way, like you said it is a once in a lifetime opportunity. This session has been really useful, but I do have worries about the way I word things, and aware of some conscious biases I have. What would your top tips be to get started?

Answer from Natasha Widdowson (Defra): Here are my top tips for completing the consultation:

  • Download the PDF version of the consultation so you can mull over the information and your answers
  • Please don’t worry too much about your language – lots of the questions are multiple choice/radio buttons, which is a really valuable contribution. If you want to add comments, please do – but don’t worry too much about language, we have a great team to do the coding

Q2: How were registered veterinary nurses (RVNs) working within different areas of the profession represented in BVNA’s activity as a key stakeholder in this process?

Answer from BVNA: The main stakeholder groups which fed into Defra’s ‘sprint’ process were BVNA alongside BVA, RCVS, Veterinary Schools Council, and Government Veterinary Services.

At the outset of the sprint work, we recognised that it would be essential to draw on experience from a range of RVNs, both including and outside of BVNA Council, to enable as much representation from across the profession as possible.

We therefore assembled a BVNA member working group, which has been focusing on the Veterinary Surgeons Act (VSA) reform and supporting us with composing our views, in parallel to the sprint work leading up to the consultation. We invited all interested BVNA members to put themselves forwards to take part in this group, and sought to include a diverse range of RVNs, working in and out of practice, and within different practice types, and across different species. This resulted in a working group of around 12 RVNs, which was pulled together around January 2025 and has been part of the process throughout the work with Defra so far. This working group will also be supporting us with compiling our response to the consultation.

Q3: Are you able to advise how a reformed VSA will impact the specific tasks that RVNs are legally allowed to carry out?

Answer: We know that Schedule 3, which currently determines the “acts of veterinary surgery” which can be carried out by RVNs, can be difficult to interpret confidently by both vets and veterinary nurses. This therefore had led to a general underutilisation of RVNs’ skills due to a lack of confidence in what can or cannot be delegated. It is also inflexible, meaning that the RVN role and scope of practice cannot evolve without significant legislative change.

Under Defra’s proposals, the regulator would have the ability to determine the scope of practice for all of the professions it regulates, with any changes being made subject to a later consultation process. Consequently, under new legislation it could be possible for the scope of practice of the RVN role to be expanded, dependent on appropriate training and qualifications. As some examples, this could have the potential to lead to the development of an advanced practitioner or nursing prescriber role.

At this stage however, it is difficult to advise on very specific tasks. Primary legislation (which is what is being addressed within this consultation) would only be concerned with the principle of the regulator setting the regulated professions’ scope of practice. The inclusion of any additional specific tasks within the RVN role would then become a secondary process for the regulator at a later stage.

Q4: Will the VSA reform lead to potential future regulation for patient/veterinary care assistants?

Answer: To answer this question, we firstly need to address why regulation of allied veterinary professionals (AVPs) is being considered, and then whether patient/veterinary care assistants would meet the criteria of an AVP.

Under these proposals, “veterinary acts” are considered to be activities carried out by veterinary professionals which would be protected in law – meaning only those holding a “license to practice” would be legally allowed to carry out these activities, within their scope of practice.

AVPs are professionals other than veterinary surgeons and veterinary nurses, who commonly carry out what are considered to be “veterinary acts” within their typical work. Examples of AVPs include musculoskeletal practitioners, equine dental technicians and cattle hoof trimmers. Currently, these professions are unregulated, and Defra’s proposals include the potential for AVPs to come under regulation in future.

In accordance with the proposals, the scope of practise for all veterinary professions including AVPs would in future be determined by the regulator, i.e. the regulator would have the ability to determine which “veterinary acts” could legally be carried out by each profession.

As patient/veterinary care assistants do not currently carry out “veterinary acts” they are considered lay members of the veterinary team, and therefore do not meet the threshold for regulation.

Q5: If the ‘alternative’ governance structure was to go ahead, how much would this cost (to the government/public) compared to Defra’s ‘proposed’ structure?

Answer: The costs of regulation would be for the regulator to determine; however, any fees that they raise will need to be subject to consultation and on the basis of cost recovery. These would be set out in a corporate strategy (usually every 3 to 5 years).

Under either of the proposals there will undoubtedly be a change in the current fees and the current fee structures, but money raised from business licences should be used for business activities and money raised from professional licences should be used for regulation of the professionals.

For the proposed structure, there would undoubtedly be some upfront costs to the regulator, which could be funded through current reserves and “paid back” by subsequent income from fees. The activities under both the regulation and professional leadership arms would then be costed by the regulator and fees charged accordingly.

Under the alternative structure, again there would likely be some upfront costs and then costings of ongoing costs, which would be paid for by fees. Government would not have any involvement with the setting up of a leadership body. The structure and activities, and therefore cost, of this would be decided by the individual veterinary professions.

The Defra consultation is available to access directly here; https://consult.defra.gov.uk/reform-of-the-veterinary-surgeons-act/consultation/.

Find out more about how BVNA is ensuring your voice is heard in VSA reform; https://bvna.org.uk/project/veterinary-surgeons-act-reform/