Correspondence

Response to the Animals in Science Committee’s report 'Strengthening leading practice in the animals in science sector'

Published 6 October 2026

Lord Hanson of Flint
Minister of State for the Home Office
2 Marsham Street
London
SW1P 4DF

www.gov.uk/home-office

30 September 2026

Dear Sally,

Response to the Animals in Science Committee’s Report, Strengthening leading practice in the animals in science sector

Thank you for the Animals in Science Committee’s report, Strengthening leading practice in the animals in science sector, published in January 2026 in response to the Home Office’s November 2024 commission. I am grateful to the Committee for its detailed consideration of the evidence and for its constructive recommendations.

The report provides a clear framework for identifying and assessing emerging practices, supporting their wider adoption where the evidence is sufficiently strong, and considering whether they should ultimately inform expected standards. This will support the Government’s commitment to the Replacement, Reduction and Refinement of the use of animals in science, the 3Rs, while improving animal welfare and maintaining effective regulation of scientifically justified research.

Since the report’s publication, Home Office officials have worked with the Animals in Science Regulation Unit (ASRU), the National Centre for the Replacement, Refinement and Reduction of Animals in Research (NC3Rs) and the Department for Business, Innovation, Science and Trade (BIST) to consider how the recommendations could be implemented in practice. This engagement has helped to develop actions in response to the recommendations that are coherent, deliverable and aligned with related activity across the animals in science portfolio.

The Government accepts seven recommendations in full, three in principle and one in part, as set out in Appendix 1. We will:

• Strengthen expectations for establishments’ application and oversight of the 3Rs;
• Develop a structured framework for identifying and assessing emerging practices;
• Consider how licensing, assurance and incentives can encourage the adoption of leading practice;
• Commission further work on leading practice in replacement; and
• Consider how the research and funding landscape can support the development and wider adoption of effective practices.

Where the Government proposes a modified approach, this is to maintain clear responsibilities, avoid duplication and ensure that any new expectations have an appropriate evidential and legal basis. These adjustments are intended to achieve the outcomes sought by the Committee while preserving proportionate and effective regulation.

The Home Office will work with the Committee, ASRU, the NC3Rs and other partners to take these actions forward. Taken together, these actions will support the wider adoption of leading practice, strengthen animal protections and maintain robust oversight of high-quality, scientifically justified research.

Thank you again for the Committee’s important contribution.

Yours sincerely,

Lord Hanson of Flint

Appendix 1

The Government’s Response to the Animals in Science Committee’s recommendations in Strengthening leading practice in the animals in science sector

The Government accepts seven recommendations in full, three in principle and one in part. Implementation will be guided by the following principles:

• Alignment with the Government’s Replacing Animals in Science strategy and related cross-government activity;
• Clear responsibilities across the Home Office Animals in Science Regulation Policy Unit (ASRPU), the Animals in Science Regulation Unit (ASRU), the Animals in Science Committee (ASC), the National Centre for Replacement, Refinement and Reduction of Animals in Research (NC3Rs), the Department for Business, Innovation, Science and Trade (BIST), UK Research and Innovation (UKRI) and other partners;
• A proportionate, evidence-led approach that reflects the diversity of regulated work;
• Integration with existing licensing, assurance and policy improvements wherever possible; and
• Recognition of the role of funding in developing, validating and scaling leading practice across the 3Rs.

Implementation Plan

1. The Home Office and the Department for Science, Innovation and Technology should provide a commission (e.g. to the ASC) focused on what leading practice in replacement might look like, including for establishments specifically, in the context of the cross-government strategy.

The Government accepts this recommendation.

• The Home Office and BIST, which has incorporated the relevant functions of the former Department for Science, Innovation and Technology, will develop a commission on driving leading practice in replacement, including at establishment level.
• BIST is leading the establishment of the Alternative Methods Expert Committee (AMEC), following a commission to the ASC to advise on its remit, governance and ways of working.
• The respective roles of the ASC and AMEC in undertaking this commission will be agreed with BIST, taking account of the ASC’s advice.
• Home Office and BIST officials will work together to align this commission with delivery of the Government’s Replacing Animals in Science strategy.
• This action will be completed in the first half of 2027.

2.

2i. All licence holders, AWERB members and those involved in frontline animal work should be expected to meet minimum continuous professional development (CPD) requirements specifically in relation to the 3Rs, and the completion of this CPD should be documented and recognised by the establishment.

2ii. ASRU should make expectations of minimum CPD requirements clear and audit against this.

The Government accepts this recommendation in principle, subject to further policy consideration of the detailed approach to continuous professional development and its role within assurance activity.

• The Home Office’s Training and Development under the Animals (Scientific Procedures) Act 1986 (ASPA) guidance sets an expectation that licence holders and others undertaking relevant roles maintain their competence through CPD, including in relation to the 3Rs.
• The Home Office recognises the value of clear expectations for CPD, but considers that requirements should reflect the differing roles, scientific contexts and associated training needs across establishments. Therefore, rather than create a uniform set of minimum requirements, which would not provide the flexibility needed to address these differences effectively, the Home Office supports an approach under which establishments ensure that effective, tailored training measures are in place, and that this can be demonstrated to the Home Office.
• ASRU will recommend that establishments develop and maintain effective and proportionate arrangements for CPD relating to the 3Rs, documented as part of their wider strategy for implementing the 3Rs under recommendation 3. Further detail will be developed and communicated to establishments during 2027.
• Evidence of effective CPD arrangements may contribute to an establishment’s evidence of leading practice and to consideration of any recognition or incentives developed under recommendations 7 and 10. The intended role of CPD arrangements within assurance activity will be developed and communicated before implementation.

3.

3i. All licence holders should demonstrate how they implement the 3Rs and support leading practice:

• a. Establishment licence holders should ensure there is a strategy including annual goals on how they will implement the 3Rs principles in their establishment and record these outcomes.

• b. Project licence holders should define, and make explicit in licences, their process for changing practices as new best practice and expected standards become available.

• c. AWERBs should retrospectively assess the progress against the 3Rs during their reviews and share learning more widely.

3ii. ASRU should be auditing against these processes for assurance that standard conditions are being met.

The Government accepts this recommendation in principle, subject to further policy and operational consideration of the detailed approach to establishments’ 3Rs strategies, project licence applications and assurance activity.

• The Government supports the objective of strengthening how establishments demonstrate and review their application of the 3Rs, but considers that the detailed mechanisms and regulatory expectations should be developed through further policy and operational work before implementation.
• ASRU will recommend that establishments maintain a proportionate strategy for implementing the 3Rs. Further detail, including suggested annual priorities, arrangements for relevant CPD and approaches to reviewing progress, will be developed and communicated during 2027 and incorporated into relevant assurance activity by the end of 2028.
• Evidence of an effective 3Rs strategy is likely to contribute to an establishment’s evidence of leading practice when the criteria and any associated incentives under recommendations 7 and 10 have been developed.
• The Home Office will revise the project licence application process so that applicants explain how they will review and, where appropriate, update their practices as evidence and expected standards develop. Any changes will be subject to an appropriate assessment of their impacts, and the timing of actions will be aligned with the changes following the NC3Rs review of the project licence application form.
• The Home Office recognises the importance of Animal Welfare and Ethical Review Bodies (AWERBs) in driving leading practice. Under ASPA, AWERBs must follow the development and outcome of projects, and identify and advise on elements that could further contribute to the 3Rs.
• ASRU will reinforce the requirement that AWERBs consider progress in applying the 3Rs when undertaking relevant project review activity and encourage appropriate sharing of learning. This action will be completed by the end of March 2027.

4. ASRU should commission the NC3Rs to develop a generic set of criteria to enable organisations to determine when the evidence base for an emerging practice is sufficiently strong to be considered ready for broader implementation, leading to it becoming the expected standard.

The Government accepts this recommendation.

• The Home Office will commission the NC3Rs to advise on generic criteria that can support establishments and other organisations in assessing whether an emerging practice has a sufficiently developed evidence base to be considered for broader implementation.
• The criteria will help identify practices that may warrant further consideration through the framework in recommendation 5; they will not, by themselves, determine whether a practice should become an expected standard. Wider scientific, technical and regulatory considerations will also be relevant.
• The work will also take account of practical dependencies affecting the development of the evidence base, including the availability of funding to demonstrate reliability, reproducibility, transferability and scalability. This will help ensure that the criteria support the progression of promising practices.
• The Home Office will commission the NC3Rs in the first half of 2027.

5. ASRU should implement a structured framework for leading practice, by which:

• a. The ASC can signal to ASRU that an emerging practice has sufficient evidence to be considered best practice and is ready to transition to the expected standard. Stakeholders in the landscape, such as the NC3Rs, will be responsible for signalling to the ASC when this is the case, and the ASC will independently review the evidence. The ASC will include a recommendation on timeframe for implementation of the new expected standard at pace, dependent on factors such as complexity and cost.
• b. ASRU will communicate the new expected standard and timescales for implementation to the regulated sector and its inspectors. Establishments are expected to demonstrate an action plan to meet any deadlines for implementation. AWERB-approved exceptions can be audited by ASRU.
• c. New expected standard is implemented by the recommended deadline. This process should include effective lines of communication about the new expected standard to establishments (including updated guidance documents).
• d. ASRU should engage effectively with regulators in the wider landscape where relevant and maintain a two-way dialogue as regulations are updated.

The Government accepts this recommendation in part, subject to further policy, legal and operational consideration of the detailed framework and the route by which any practice may become an expected or enforceable standard.

• Summary: The Government welcomes the framework proposed by the ASC and agrees with its aim of providing a structured route for emerging practices to be identified, independently assessed and, where appropriate, adopted more widely. The Home Office will work with the ASC, the NC3Rs, ASRU and other relevant stakeholders to refine the framework during 2027. Implementation arrangements and timing will be developed alongside the supporting criteria, audit arrangements and funding work.
• The role of the ASC, the NC3Rs and wider organisations: Relevant organisations will be able to signal emerging practices to the NC3Rs or another appropriate expert body for detailed consideration of the evidence base. Where the evidence is sufficiently robust, the practice may then be signalled to the ASC for independent advice on whether wider implementation should be considered. The criteria developed by the NC3Rs under recommendation 4 will support the identification of practices for consideration through the framework. The ASC will also have a role in communicating relevant advice to AWERBs. Under ASPA, AWERBs must consider advice received from the ASC.
• When newly identified practices may become enforceable: The framework will distinguish between newly identified leading practices and practices that are legal minimum standards. For example, the ASC may identify a practice that it assesses as ready for wider implementation. The practice would then be communicated to establishments, which would be incentivised and encouraged to adopt it where appropriate, but it would not yet be legally mandatory. A practice may later become a legally mandatory standard through a future update to the Code of Practice or another appropriate statutory or licensing route. In such cases, the appropriate parliamentary procedure would be followed. The route and timeframe for implementation will be determined case by case, taking account of scientific, technical, regulatory and resource considerations.
• Ownership: The Home Office’s Animals in Science Regulation Policy Unit will retain overall policy ownership of the leading practice framework and coordinate its implementation. ASRU will lead the associated licensing, audit and compliance activity. This will recognise the distinct responsibilities of the ASC and the NC3Rs, and the roles of BIST and UKRI in the 3Rs funding landscape. The Home Office will also engage relevant regulators where necessary to support a coherent approach.

6. ASRU should ensure that amendment processes for refinements are streamlined in the case of potential 3Rs benefits.

The Government accepts this recommendation.

• ASRU will review the project licence amendment process to identify opportunities to streamline the process for amendments that deliver clear 3Rs benefits, while maintaining appropriate regulatory scrutiny.
• ASRU will complete this review as part of the wider work arising from the NC3Rs review of the project licence application process and communicate its conclusions by the end of 2027. Any implementation timetable, including changes to ASPeL or supporting operational processes, will be set after the review and aligned with relevant digital priorities.

7. ASRU should collaborate with the NC3Rs, ASC, and other stakeholders (as appropriate) to develop criteria, including positive indicators of cultural traits, against which establishments are assessed for leading practice. ASRU should utilise its existing audit programme to assess leading practice against the criteria that have been developed.

The Government accepts this recommendation.

• The Home Office will work closely with the NC3Rs, the ASC and other relevant stakeholders to develop and agree the criteria to assess the systems establishments use to develop, adopt and share leading practice by the end of 2027, taking account of cultural traits as appropriate.
• ASRU will introduce assessment against the agreed criteria through the audit portfolio by the end of 2028 and communicate how the criteria will be used in advance. The criteria will be distinct from compliance criteria, and absence of evidence against them will not, of itself, constitute non-compliance.
• Evidence of meeting the criteria will inform consideration of any regulatory incentives developed under recommendation 10.

8. ASRU should consider implementing annual thematic improvement areas to drive focused progress. The theme should be determined in consultation with the NC3Rs and the ASC.

The Government accepts this recommendation.

• ASRU will consider how thematic activity could be incorporated into the audit portfolio by the end of 2028 to support focused examination of selected areas relevant to the 3Rs and leading practice.
• ASRU will communicate the purpose and scope of each theme, including whether it concerns compliance assurance or non-mandatory improvement and learning.
• The frequency and scope of thematic activity will be determined through audit planning, taking account of the available evidence, proportionality, operational capacity and engagement with relevant stakeholders as appropriate.

9. ASRU should collect data related to progress in the 3Rs. This should include evidence from licence holders of their engagement with the 3Rs in the previous five years, including a meaningful reflection on their progress and learnings and what they have done to promote this more widely. This should also include data collected upon expiration of a licence as to whether the licence holder will be applying for a new licence and, if not, the reasons for this.

The Government accepts this recommendation in principle, subject to further policy and operational consideration of the scope, purpose, proportionality and method of any additional data collection.

• The Home Office supports the collection of additional data on progress in the 3Rs, particularly where this can inform delivery of the Government’s strategy to replace animals in science.
• In 2027, ASRPU and ASRU will assess the scope, purpose and justification for any additional data collection, before deciding whether, when and how to implement it. The timing of changes will be aligned with the wider review of the project licence application form.
• ASRU will also develop a method for collecting information when a project licence expires on whether a further application is expected and, where appropriate, the reasons why not. The implementation date will be set after the proposal has been considered alongside the review of the NC3Rs’ report on project licensing improvements.

10. ASRU should consider appropriate regulatory incentives for establishments assessed to be demonstrating leading practice.

The Government accepts this recommendation.

• ASRU will assess options for proportionate regulatory incentives for establishments that provide strong evidence of leading practice, including evidence that they meet the criteria developed under recommendation 7.
• ASRPU will engage relevant stakeholders, with support from ASRU, to ensure that the options are appropriate for the animals in science sector and capable of supporting behavioural change.
• Policy and options development will be completed during 2027. Subject to an assessment of the legal basis, proportionality, operational impact and stakeholder views, implementation of any agreed incentives will be completed by the end of 2028.

11. Department for Science, Innovation and Technology should consider how funding schemes can support the implementation of leading practice across the whole framework, including both the development of emerging practices and the building of the evidence base of their effectiveness.

The Government accepts this recommendation.

• The Government recognises the importance of funding in developing emerging practices and building the evidence base.
• Led by UKRI, and in partnership with BIST, further work will be undertaken through 2027 to consider how the research ecosystem can continue to support and promote leading practice across the 3Rs through existing strategic and funding processes.
• This work will consider opportunities within existing funding arrangements and wider policy levers, including relevant activity under the Government’s Replacing Animals in Science strategy.