Independent report

Vaccination of poultry against highly pathogenic avian influenza (HPAI): joint industry and cross-government vaccination taskforce

Published 24 July 2025

Joint industry and cross-government vaccination taskforce 

July 2025

Foreword  

As co-chairs of the joint industry and cross-government avian influenza (AI) vaccination taskforce, we are delighted to share this report. We really value and appreciate the efforts and contributions that have been put into this by so many people, including producers and veterinarians. 

Highly pathogenic avian influenza (HPAI) is an increasing concern globally and to the UK, as evidenced during recent years and again this year with outbreaks continuing well into the summer. 

This report is an important step in making sure we have available the knowledge and understanding that we need to find an effective way to protect poultry flocks from the disease. 

It remains the case that stringent biosecurity on farms is the best way to prevent infection of poultry flocks. We are therefore keen to make sure that we provide poultry keepers with all possible tools to protect their birds. This report explores the opportunities, constraints and considerations in using vaccination for this - these include trade, cost-benefit analysis, human health implications and laboratory and veterinary capacity to support. 

More information is certainly needed on what is a complex issue. This report therefore recommends a series of actions, including an on-farm vaccination trial in turkeys and exploring laboratory capacity for surveillance purposes. Defra and the Devolved Governments, working with industry, will give careful consideration to these in determining next steps. 

Mark Williams, Chairman, British Egg Industry Council

Gareth Baynham-Hughes, Director, Defra

Co-chairs of the joint industry and cross-government avian influenza vaccination taskforce

Chapter 1: Introduction 

Avian influenza (AI) is an infectious disease of birds caused by the influenza A virus. A variety of influenza subtypes can be found in wild birds, particularly in waterfowl and shore birds. Domestic poultry are especially vulnerable, and the virus can rapidly cause epizootics in flocks. In recent years, the United Kingdom (UK) has faced its most extensive and persistent outbreaks of highly pathogenic avian influenza (HPAI), particularly the H5N1 strain.   

In the UK, HPAI is controlled through measures such as early detection, culling, movement restrictions, housing measures and mandatory enhanced biosecurity. The only protection entirely within control of keepers is biosecurity, which can significantly reduce risk if stringently applied.  

There have been continued discussions on the global stage about HPAI vaccination. In December 2023, the World Organisation for Animal Health (WOAH) released a statement which recognised the need to consider vaccination as a tool for the prevention and control of avian influenza and said that use of vaccination should not be a barrier to trade in poultry and poultry products. This was reinforced in resolution 29 - Veterinary Vaccines and Vaccination. From science to action – reflections for change at the 92nd General Session in May 2025. 

Current UK policy does not permit vaccination of birds against HPAI (except in zoos in England and Northern Ireland (NI)) either for disease prevention or as a disease control response. This is because vaccinated birds can still become infected, shed virus, and transmit the virus to other birds, mammals and humans, which introduces surveillance complexities and trade barriers. 

The potential benefits of HPAI vaccination are being considered in several countries experiencing similar challenges to the UK. In Europe there are ongoing trials of candidate vaccines in Italy and the Netherlands. France has implemented a mandatory preventative HPAI vaccination programme for commercial ducks. Some countries, such as Mexico, China, Egypt, and Vietnam, use vaccination more routinely. South Africa recently announced it is progressing a national HPAI vaccination strategy, and several countries have set up taskforces to look at vaccination in poultry.  

In the UK, the joint industry, cross-government ‘avian influenza vaccination taskforce’ (the Taskforce) was established to explore the position and make recommendations for the potential use of vaccination of poultry as a preventative measure against HPAI in the UK. The work of the taskforce is essential to ensure the UK is aligned with the evolving global position, and has an up-to-date, evidence-based policy on HPAI vaccination. 

The Taskforce’s interim statement, published 7 March 2025, outlined the current policy and rationale regarding the use of HPAI vaccination in the UK. This report builds on the interim statement, providing a more detailed analysis, including consideration of current policy across the UK, the legislative framework for vaccination and regulatory processes for authorisation, factors to consider in selecting a vaccine, analysis of relevant trials, and consideration of factors which would impact recommendations on vaccination strategy in the UK, such as trade, cost and benefit. 

Current policy (chapter 2) across the UK is not to allow vaccination, other than in zoos in England and NI. However, existing legislation across all four Governments allows for vaccination under emergency or preventive plans. No new legislation would be required to enable vaccination. The Veterinary Medicines Directorate (VMD) is responsible for authorising vaccine use in Great Britain (GB), and in some cases in NI. This could be full, provisional or emergency use – each of which requires consideration of vaccine safety, quality and efficacy (chapter 3). Three vaccines are currently authorised for use in GB and NI

Careful consideration must be given to the key success criteria for vaccines in the UK, in context of different vaccine technologies (chapter 4). These criteria include efficacy, DIVA compatibility (the ability to differentiate infected from vaccinated animals), practical deployment challenges and surveillance needs. Vaccination trials have been completed in France, the Netherlands, Germany and Italy (chapter 5). These trials have tested a range of vaccine types across different poultry species and production systems. Some vaccines showed promising results in reducing virus shedding and transmission, particularly when used in combination. However, responses varied by species and vaccine type. 

Meeting international surveillance standards (chapter 6) agreed by the World Organisation for Animal Health (WOAH) and mandated by the European Union (EU) would be essential for any vaccination programme. Modelling work has been undertaken by the Animal and Plant Health Agency (APHA) on effective surveillance strategies, such as testing dead birds. However, there are significant gaps in veterinary and laboratory capacity that would need to be addressed to meet these requirements. Even if met, vaccination could impact UK poultry exports (chapter 7). There is significant uncertainty around how trading partners, particularly the EU, the United States and the Middle East, would respond to the introduction of vaccination. Even limited or trial-based vaccination could trigger export restrictions. To maintain trade under any future vaccination programme, early engagement with key markets will be essential. 

Additional considerations before vaccinating poultry (chapter 8) include public health, food safety, insurance and biosecurity. While vaccination poses minimal food safety risk, it could affect consumer confidence unless clear communications are provided. Existing challenges around availability of insurance could be compounded, particularly as vaccination is not a replacement for good biosecurity practices, which remain the most effective tool for preventing disease spread. 

Under current assumptions, a vaccination programme would offer poor value for money overall if every flock were to vaccinate (chapter 9). An outbreak would have to be approximately 100% larger than the 2022 to 2023 outbreak and approximately 600% larger than the 2020 to 2021 outbreak in order for the benefits of avoiding an outbreak to start outweighing the costs of intervening through vaccination. However, this varies by species – in particular ducks and geese, where value for money is expected to be high, and turkeys where, under more severe outbreak scenarios, the benefits are expected to outweigh the costs.  

There are 3 main vaccination strategies which could be implemented (chapter 10):

  • maintaining the current policy and only allowing vaccination in zoo birds
  • use of emergency vaccination based on risk assessment and agreed trigger points
  • allowing preventative vaccination either nationwide or within targeted geographic regions or species groups

Significant uncertainties remain and the Taskforce cannot make a final recommendation without more evidence. Whilst supporting the principles of vaccination, the Taskforce will work towards addressing these evidence gaps before publishing a final recommendation in summer 2026. Actions include exploring a targeted turkey vaccination trial, proactive engagement with trading partners, and work to build surveillance and laboratory capacity.

Chapter 2: Current policy and legislative framework 

This chapter details the current policy and legislative requirements which govern the use and implementation of HPAI vaccination within the UK. This includes consideration of EU legislation as well as the legislative framework of each of the devolved governments. 

Current policy 

Within the UK, vaccination against HPAI is currently only permitted for birds in zoos in England and NI. This is the case whether the purpose of vaccination is disease prevention or as a disease control response. As HPAI is an exotic disease to the UK, a disease which is not usually present, the primary approach is to detect any incursion early and stamp out disease quickly. 

Preventative vaccination in poultry is recognised as a potential disease control measure and authorised H5 specific vaccines are available in the UK (chapter 3). However, the decision to permit the use of such vaccinations is complex and would require a change in UK policy. To fully understand the scope for change or implementation of vaccination strategies, it is essential to examine the legislative framework that underpins and enables these policy decisions. 

Current UK legislative framework 

The legislative framework for avian influenza vaccination across the UK is shaped by a combination of assimilated EU legislation and domestic regulations, including devolved instruments. While routine vaccination is currently prohibited throughout the UK, each nation has legal mechanisms in place to authorise vaccination in response to specific disease risks. At the UK level, the policy is underpinned by the principle that vaccination should only be used strategically, either as an emergency response or as a preventive measure where justified by risk assessments. 

Cross-cutting legislation 

The main piece of legislation in GB governing animal disease is the Animal Health Act (AHA). This confers on ministers broad powers to make secondary legislation to prevent the spread of disease. In England and Wales, section 16 provides powers to mandate vaccination in response to exposure, infection risk, or presence in an infected area (for instance a protection zone declared under avian influenza legislation). In Scotland, section 16 provides powers for the Scottish Ministers to mandate vaccination if they think fit. 

Several legislative instruments apply across GB and form a critical part of the regulatory environment for avian influenza vaccination: 

Before vaccines can be placed on the market, they must undergo a rigorous marketing authorisation process overseen by the Veterinary Medicines Directorate (VMD). This process ensures that all veterinary vaccines meet strict standards for quality, safety, and efficacy. However, in emergency situations, such as a significant outbreak of HPAI, there are legal provisions that allow for the use of unauthorised vaccines. These may be deployed if specific conditions are met and a thorough risk assessment supports their use. 

In GB, vaccine authorisations are governed by the Veterinary Medicines Regulations 2013 (as amended), while in NI, the applicable framework is Regulation (EU) 2019/6. These regulatory regimes provide the foundation for ensuring that any vaccine used, whether authorised or under emergency provisions, is subject to appropriate oversight. Details of the authorisation process are in chapter 3. 

Country-specific legislation  

England 

In England the most significant relevant legislative instrument is The Avian Influenza (Vaccination) (England) Regulations 2006 (VRs), which regulate AI vaccination of birds other than zoo birds. Regulation 5 provides that no person may vaccinate such a bird against AI except where required or licensed by the Secretary of State.

The VRs enable 2 key vaccination pathways: 

1. Emergency vaccination (reg. 6) may be implemented in designated zones, or individual premises, where a significant and immediate threat of AI spread is identified through a risk assessment and an Emergency Vaccination Plan (EVP) is published. EVPs are defined in reg. 2 and must meet the criteria set out in Article 53(2) of Directive 2005/94 (as it existed upon EU Exit). 

2. Preventive vaccination (reg. 7) may be either licensed or mandated, in zones or individual premises, where a Preventive Vaccination Plan (PVP) is in place and risk assessments indicate exposure. PVPs are defined in reg. 2 with reference to Art 56 of Directive 2005/94, which sets out similar criteria as apply to EVPs

Supporting measures (regs. 8–9) allow the Secretary of State to impose controls on vaccine use, administration, and identification of vaccinated birds within vaccination zones or licensed premises. 

There are 3 additional relevant pieces of legislation in England. These are: 

Scotland 

Scotland’s legal framework is set out in the Avian Influenza (Slaughter and Vaccination) (Scotland) Regulations 2006. This statutory instrument generally prohibits vaccination unless required by Scottish Ministers. Regulation 11 provides that no person may vaccinate such a bird against AI except where required by Scottish Ministers in accordance with Regulation 12 or 13, or done under the authority of a licence from Scottish Ministers under the Specified Animal Pathogens (Scotland) Order 2009 or an animal test certificate granted by the Secretary of State under The Veterinary Medicines Regulations 2013.

This enables 2 key vaccination pathways requiring vaccination: 

1. Emergency vaccination (reg. 12): Scottish Ministers must, if they consider it necessary to reduce the risk of the spread of avian influenza, declare an emergency vaccination zone or serve notice on individual premises, where a significant and immediate threat of AI spread is identified through a risk assessment and an Emergency Vaccination Plan (EVP) is published. EVPs are defined in reg.2 and must meet the criteria set out in Article 53(2) of Directive 2005/94 (as it existed upon EU Exit). 

2. Preventive vaccination (reg. 13): Scottish Ministers must if they consider it necessary to reduce the risk of the spread of avian influenza, declare vaccination zones or serve notice on individual premises, where a Preventive Vaccination Plan (PVP) is published and risk assessments indicate all or certain areas of Scotland, types of poultry husbandry or types of poultry or other captive birds are exposed to the risk of avian influenza. PVPs are defined in reg. 2 with reference to Art 56 of Directive 2005/94, which sets out similar criteria as apply to EVPs

Supporting measures (reg 15): Scottish Ministers in a declaration or notice require the vaccination of poultry, other captive birds or any specified category of poultry or other captive bird in accordance with instructions issued by them. It also has the effect that no poultry, other captive birds or their products can be moved within, into or out of a zone, or into or out of premises except under licence.   

There are 2 additional pieces of legislation in Scotland of relevance to HPAI and vaccination. These are: 

Regulation 5 provides for the Scottish Ministers to require vaccination of susceptible birds in zoos if they think necessary. 

Wales 

In Wales, it is the Avian Influenza (Vaccination) (Wales) (No. 2) Regulations 2006 (the V(W)R) which provides the framework for regulation of AI vaccination of birds (other than zoo birds) in Wales. The V(W)R largely mirror the corresponding legislation in England. Regulation 5 of the V(W)R prohibits vaccination of such birds against AI unless required or licenced by the Welsh Ministers.

As with the England VRs, there are 2 key vaccination pathways: 

1. Emergency vaccination (reg. 6): where a risk assessment identifies significant and immediate threat of AI spreading within, or into, Wales, the Welsh Ministers must decide whether emergency vaccination is necessary to reduce the risk of the spread of AI. This can either be within an ‘emergency vaccination zone’ covering all or part of Wales, or within any individual premises by notice served on the occupiers. If an Emergency Vaccination Plan (EVP) is published, the declaration or service of notice must be in accordance with the provisions of that plan. EVPs are defined in reg.2 of the V(W)R, and must contain at least the information set out in Art. 53(2) of Directive 2005/94 as it had effect in EU law immediately before implementation period completion day (‘IPCD’ - 11pm on 31 December 2020), but as read with the modifications in reg. 2(3) of the V(W)R

2. Preventive vaccination (reg. 7): where a risk assessment indicates that any poultry or other captive birds in any part of Wales are exposed to a risk of AI and a Preventative Vaccination Plan (PVP) has been published, the Welsh Ministers may grant a vaccination licence in accordance with that PVP. Where the Welsh Ministers consider it necessary to reduce the risk of the spread of AI, they must mandate preventative vaccination either within a ‘preventative vaccination zone’ covering all or part of Wales, or within any individual premises by notice served on the occupiers. PVP are defined in reg. 2 of the V(W)R and must contain at least the information set out in Art. 56(2) of Directive 2005/94 as it had effect in EU law immediately before IPCD, but as read with the modifications in reg. 2(4) of the V(W)R

Supplementary provisions: 

Regulations 8 and 9 of the V(W)R set out the measures that the Welsh Ministers may impose within a vaccination zone, within a premises that is subject to a vaccination notice, or in relation to a vaccination licence (including controls on vaccine type or use, sampling and record keeping, movement or release of birds, and such like). 

Regulation 10 contains the measures that apply where an emergency vaccine zone is declared, or emergency vaccine notice is issued, before an EVP has been published. 

Other Welsh legislation (largely corresponding to regulations in England) has relevance to AI prevention and control and vaccination, including: 

  • The Avian Influenza and Influenza of Avian Origin in Mammals (Wales) (No 2) Order 2006 contains broad measures and powers for the Welsh Ministers to prevent/ control of AI (including power to declare protection zones, surveillance zones, prevention zones and such like, and implement control measures). Vaccination measures will be considered alongside other control measures as part of broader disease control strategies. 
  • The Avian Influenza (Preventive Measures) (Wales) Regulations 2006 contains (among other measures) a prohibition on vaccination of zoo birds in Wales against AI unless required or licenced by the Welsh Ministers, and includes provisions as to vaccination, and restrictions/provisions relating to movement and/or surveillance of vaccinated zoo birds. 
  • The Avian Influenza (H5N1 in Wild Birds) (Wales) Order 2006 contains measures and powers for the Welsh Ministers to prevent/control of AI in wild birds. Measures include controls of poultry and other captive birds within wild bird control areas. Vaccination measures may be considered alongside such control measures as part of broader disease control strategies. 
  • The Diseases of Poultry (Wales) Order 2003 – AI is a “designated disease” as defined in reg. 3 of this Order. This Order makes provision in relation to control measures for designated diseases, including provision for Welsh Ministers to require, by notice, vaccinate of any species of poultry with a designated area. 

Northern Ireland  (NI)

Northern Ireland’s framework is set out in The Avian Influenza (Vaccination) Regulations (Northern Ireland) 2007. Regulation 5 provides that no person may vaccinate any bird against AI except where required by an inspector or under the authority of and in accordance with the conditions of licence granted by DAERA. This prohibition does not apply to: 

Northern Ireland permits the vaccination of zoo birds under specific eligibility criteria and authorisation. The Department of Agriculture, Environment and Rural Affairs (DAERA) may authorise both emergency and preventive vaccination based on risk assessments. 

The following pieces of legislation also have relevance to HPAI and vaccination in NI

  • The Avian Influenza (Preventive Measures) Regulations (NI) 2007, Regulation 7 provides that if there is a risk disease will be transmitted to zoo birds, vaccination is permitted under the authority of a licence. Vaccination must be carried out in accordance with the preventative vaccination plan (PVP) approved by the European Commission under Article 5 of Commission Decision 2007/598/EC concerning measures to prevent the spread of highly pathogenic avian influenza caused by influenza A virus of subtype H5N1 to birds kept in zoos and approved bodies, institutes and centres in the member states.  
  • the Avian Influenza and Influenza of Avian Origin in Mammals Regulations (NI) 2007. Part II sets out preventive measures to reduce the risk of the transmission of avian influenza and provides for surveillance for the disease.  

Under the Windsor Framework, NI remains aligned with certain EU legislation. This means any changes to vaccination policy in NI would need to comply with EU standards.  

EU legislative framework 

As announced at the UK-EU Leaders’ Summit on 19 May 2025, the UK and EU have agreed to work towards establishing a common Sanitary and Phytosanitary (SPS) Area. This is achieved through UK agreement to keep our SPS rules in line with those of the EU. The ambition is to reach an agreement that reduces administrative burdens for traders by meaningfully streamlining SPS checks and certification, while upholding the UK’s commitment to ensure its biosecurity is protected within this future framework. This agreement will therefore have implications for UK controls on avian influenza. 

In the EU, under the Animal Health Law (Regulation (EU) 2016/429), EU member states (MSs) are allowed to use vaccination as a tool to prevent or control certain listed diseases (including HPAI), provided that a risk assessment is conducted (as set out in Article 46(2)) and the vaccination is deemed appropriate or necessary for effective disease management. Commission Delegated Regulation (EU) 2023/361 lays down specific rules for EU MSs on the use of vaccines, including in poultry or captive birds to prevent or control the spread of HPAI. It also sets the conditions under which vaccinated birds, and their products may be moved, including requirements for post vaccination surveillance. 

A key difference is that EU legislation includes detailed, binding requirements for post-vaccination surveillance, particularly under Delegated Regulation 2023/361, which are essential for maintaining trade and disease-free status. The UK does not currently have equivalent provisions in place. Chapter 6 investigates the surveillance aspect of legislation in more detail.  

Consideration of legislative and regulatory changes in future HPAI vaccination strategy 

For the UK Government or any of the devolved governments to allow AI vaccination, whether on a limited basis such as in specific zones or sectors, as a trial, or more broadly, this could likely be achieved using the legal powers that are already in place. The current legislative framework across the UK nations is designed to accommodate vaccination where justified by risk, so no new laws or amendments would be required. 

However, any such policy shift would need to be supported by robust surveillance systems (chapter 6) aligned with international standards, including the ability to satisfy DIVA requirements. Clear vaccination plans would also need to be developed and shared with key trading partners to maintain market access and ensure continued compliance with WOAH guidance.

Chapter 3: Vaccine authorisation 

Before vaccines can be used as part of any HPAI control strategy in the UK, it is essential to understand the processes that determine which vaccines are available and under what conditions they can be used. This chapter explains the different routes through which vaccines may be authorised or permitted for use, including full and exceptional marketing authorisations, the role of cascade, and emergency use provisions. It also outlines the specific vaccines currently authorised in the UK. Together, these elements form the foundation for understanding how vaccine availability is regulated and how this informs policy decisions on their use. 

Marketing authorisation 

The VMD is the UK competent authority for the regulation of veterinary medicinal products (VMPs). It is responsible for the assessment of marketing authorisation applications submitted by the veterinary pharmaceutical industry to authorise and make available good quality, safe and efficacious VMPs in the UK, including veterinary vaccines. 

A marketing authorisation is required to place a VMP on the relevant UK markets for sale and supply. A GB marketing authorisation is required for GB. An NI, or an EU centralised marketing authorisation is required for NI. Any person intending to manufacture, import, possess, distribute, sell, supply and use veterinary vaccines for HPAI must first consult the relevant competent authority on the current vaccination policies, as these activities may be prohibited in its territory pursuant to national legislation and policy.  

Before a VMP can be placed on the UK market a large package of quality, safety and efficacy data undergoes a rigorous independent scientific assessment by expert assessors at the VMD to ensure the product meets the required UK and relevant international standards. 

Quality: the data on quality have to provide proof of consistency and safety of ingredients from which the product is made, inform on shelf life, storage conditions and such like. Rigorous assessment of data on quality and subsequent manufacturing site inspections ensure that all batches of the product are manufactured consistently to high quality standards. Quality is the foundation of any assessment for safe use and efficacy. 

Safety: the vaccine must be shown to be safe to use by not causing unacceptable side-effects or harm for the animal being treated, the person administering the vaccine or the environment, and for food producing species, the consumer. Where necessary, specific warnings are added to the product literature which, when followed, will minimise the risk of any known potential adverse reactions following administration of the product.  

Efficacy: vaccines should perform as manufacturers claim they do when used according to the authorised Summary of Product Characteristics (SPC) for each individual product and this should be supported by the data provided in the application. 

The VMD will assess the risks associated with the particular vaccine product and consider these in light of the benefits of use. If the benefits outweigh the risks, the VMD will issue a marketing authorisation. This could be a full marketing authorisation, or a provisional marketing authorisation. 

A full marketing authorisation is granted where data are provided to satisfy all aspects of the dossier concerning quality, safety and efficacy and that these fully meet the legal requirements. 

At the conclusion of the assessment process, the SPC of each vaccine approved by the VMD will be evidence-based and supported by the specific quality, safety and efficacy data provided for the individual products.

The SPC provides a clear and unambiguous description of the approved conditions of use including:

  • target species and sub-category
  • minimum age of administration
  • specific claims or indications (for example, reduction or prevention of clinical signs, mortality, viral excretion and transmission)
  • onset and duration of immunity
  • interactions and use with other veterinary medicinal products
  • special warnings for each target species (including information on influence of maternally derived antibodies on efficacy)
  • special precautions for use (including information on spread, excretion)
  • adverse reactions
  • amounts to be administered and administration route
  • primary and revaccination schedule
  • withdrawal periods
  • information on identifying infected birds in vaccinated populations (meaning DIVA compatibility)
  • shelf life and conditions for storage

A provisional marketing authorisation (PMA) may be granted by the VMD where there is no fully authorised product available in the UK to prevent or treat a particular condition, and to help address an urgent situation such as a threat of an outbreak of a new or re-emerging infectious disease with the potential for severe impact on animal or public health (VMR 2013, as amended Schedule 1 Paragraph 26). This may be granted based on a reduced data set which does not meet all the requirements of a full marketing authorisation but where it is demonstrated by the applicant that the benefit of the immediate availability on the market of the vaccine outweighs the risk inherent in the fact that certain quality, safety or efficacy documentation has not been provided.

PMAs are intended only to exist in the short term, are reviewed annually, and are subject to the requirement that the applicant subsequently generates and provides the complete data required to obtain a full marketing authorisation. The PMA expires once the full marketing authorisation is granted. For NI Article 25 of Regulation (EU) 2019/6 has a similar provision. 

Cascade use of vaccines  

Veterinarians may, in the absence of a suitable authorised veterinary or human medicine in a UK territory, use the ‘cascade’ system. This allows the import of medicines authorised elsewhere in the world under a Special Import Certificate (SIC), or in exceptional circumstances, the use of inactivated autogenous vaccine prepared from pathogens obtained from animals on a specific farm or unit and used for the treatment of that animal or animals in the same farm or unit.

For SICs, the VMD would require information on and assess the quality and safety of the product. In the case of autogenous vaccines, information on and assessment of details of the new pathogen of interest by way of a variation to the existing manufacturer’s licence will be required. However, there is an unequivocal preference to have access to vaccines with a marketing authorisation. 

Emergency vaccine use 

In the event of a serious epizootic disease such as HPAI where there is no suitable medicinal product, the Secretary of State may permit in writing the administration of immunological veterinary medicinal products without any form of marketing authorisation and may publicise any permit as the Secretary of State sees fit. 

Vaccines permitted for emergency use are often referred to as unauthorised veterinary vaccines for use in emergency situations. The data usually requested under standard conditions may not be available for such vaccines, meaning compliance with the requirements of VMR 2013, as amended (or Regulation (EU) 2019/6) for a marketing authorisation is not possible.

In such situations the VMD will assess the quality, safety and efficacy data and identify any potential risks arising from data gaps. This assessment is then shared with the relevant policy decision makers and authorities in the various territories in the UK who will decide whether to permit the use of the unauthorised vaccines in response to the emergency situation. 

There is an unequivocal preference to have access to vaccines with a marketing authorisation which are supported by a complete or more complete package of quality, safety and efficacy data according to their legal basis.  

Authorised vaccines available in GB and NI 

Currently only the following vaccines are authorised for use in GB and NI:

  • Vectormune HVT-AIV Concentrate and Solvent for Suspension for Injection for Chickens
  • Innovax-ND-H5 Concentrate and Solvent for Suspension for Injection for Chickens
  • Nobilis Influenza H5N2 Emulsion for Injection for Chickens

These are approved either under a PMA in GB or Article 25 of Regulation (EU) 2019/6 in NI to UK and EU standards. For detailed information on these authorised vaccines please refer to Annex A.

Additional information about individual VMPs authorised in GB and NI, including their SPC and public assessment report (which provide information on the manufacture of the vaccine and the scientific studies that were assessed to support the safety and effectiveness of the product), is available on the VMD Product Information Database - Home

All other candidates which currently hold an authorisation do so elsewhere in the world and most have not been developed according to UK or EU regulatory and technical requirements since previously vaccination against avian influenza was prohibited in these regions. In these cases, compliance of the marketing authorisation dossier with the UK requirements for authorisation are not known. Information on these vaccines can found in Table B.1 Annex B. 

Any adverse events that occur in animals, humans and the environment during use of HPAI vaccines are recorded and reported to VMD and the manufacturers via normal veterinary pharmacovigilance.

The purpose of pharmacovigilance is to protect animal health and to ensure the balance of benefits and risk remains favourable. Further information can be found at Pharmacovigilance of Veterinary Medicinal Products in Great Britain.

Chapter 4: Vaccine methodology and availability 

There are a large number of different vaccines available for HPAI. Each of these has different strengths, limitations and features. In selecting vaccines to control or prevent infection of HPAI, key criteria to be taken into account include efficacy, DIVA compatibility, and practical deployment challenges across diverse poultry systems. While no single vaccine currently satisfies all the UK’s requirements, a combination approach tailored to different production types may offer a practical solution. 

Vaccine technologies 

Vaccines have been widely used to protect against a range of avian influenza subtypes in many parts of the world. These vaccines have principally been used in Asia, Africa, the Middle East and Central America but due to the global expansion of H5 HPAI viruses in recent years there is increased usage, and coupled with expanding vaccine technology platforms, more options are now available to those seeking to use vaccination as part of a HPAI threat mitigation and disease control strategy. The choice of vaccine technology will be influenced by the disease epidemiology and host species to be protected, as well as the subtype of HPAI being protected against. 

Vaccine technologies can be broadly separated into 4 types, each with its own advantages and disadvantages dependent on the desired characteristics of a vaccination programme. These are:

  • inactivated or killed virus vaccines
  • virus-vectored vaccines
  • subunit or recombinant protein vaccines
  • nucleic acid vaccines

Inactivated or killed virus vaccines

Inactivated or killed virus vaccines are usually produced from whole viruses which are inactivated and administered with an adjuvant (for example, alum) that boosts the immune response to the inoculated material. Adjuvants are required for inactivated (killed) vaccines, as the vaccines themselves are inert. In principle they can be administered to any host species/production type. They are often produced locally and may be made specifically to match currently circulating virus in the region of relevance. 

The largest H5 vaccination programme is in China which uses inactivated vaccines. Frequent updates to the Chinese H5 vaccines have been made over many years (currently on a 14th vaccine strain). Vaccine strain yields can be enhanced by creating a hybrid virus (referred to as reverse genetics (RG)) that contains the hemagglutinin (HA) / neuraminidase (NA) genes of the desired strain into a virus backbone that has high replication characteristics in production such that production costs are minimised and production systems can be standardised. 

Inactivated vaccines are relatively cheap to produce; can be applied to multiple hosts; can easily be adapted to field viruses, to take account of change in field strains that might compromise vaccine efficacy; and have well-defined licensure processes. However, multiple doses (at least 2) are generally required for good antibody responses and protection from challenge; they cannot be mass applied, even in the hatchery; they lack a DIVA option (because they are made with whole virus); they can be less effective where Maternally-Derived Antibodies (MDAs) exist; and as they are injectable, they require individual bird handling for vaccination. 

Virus-vectored vaccines

Virus-vectored vaccines are vaccines that use a heterologous viral vector to deliver genetic material (H5 RNA) to the birds’ host cells enabling expression of HA protein or antigen to elicit an immune response including induction of humoral and cell mediated immunity. These vaccines use a surrogate virus as a vector to which a target gene is inserted. For HPAI these contain an H5 gene that can be matched to circulating field viruses. Multiple delivery vectors are available (and are routinely used in other poultry vaccination programmes) including Turkey Herpesvirus, Avian Paramyxovirus type 1 and Fowlpox. 

As viral vector-based vaccines are replication competent, they imitate natural infection and induce potent cell mediated immune responses. This results in both humoral and innate immunity being stimulated, resulting in the release the release of cytokines and co-stimulatory molecules that produce a strong adjuvant effect. This type of vaccine has been increasingly used in vaccination. 

Advantages of virus-vectored vaccines include: they are relatively cheap and easy to standardise; they can be adapted and updated to relevant antigens as field viruses evolve and emerge; they can be administered by mass application including at the hatchery; they satisfy DIVA requirements as they only express a single protein from the target pathogen (ELISA tests can detect immunity to virus nucleoprotein or matrix produced in natural infection but lacking in vectored vaccines); and both field and laboratory-based efficacy in European trials have been demonstrated (see chapter 5).

However, they may have host specificity depending on the background vector used for delivery of the target antigen, meaning that the basic virology of the vector may influence replicative ability in different systems. This may impact upon utility in different production species. Natural immunity to the virus vector within the target population may compromise effectiveness of vaccination as might MDAs in species where prior vaccination against other pathogens may impact on subsequent HPAIV vaccination.

Subunit or recombinant protein vaccines

Subunit or recombinant protein vaccines are vaccines that contain purified parts of the virus that are antigenic, typically the H5 HA protein for HPAI that can elicit a protective immune response.

Subunit vaccines can be made from dissembled viral particles in cell culture or by recombinant DNA expression using plasmids meaning, baculovirus.  

These types of vaccines have the advantage that, they do not have any of the concerns relevant to killed or viral vectored vaccines, they can be rapidly adapted to emerging threats, they are DIVA compatible (since the vaccinated bird only produces immunity to the HA and not other virus proteins induced in natural infection) and they can be administered to multiple hosts or production types.

Disadvantages include that there is less knowledge for field application (note the French duck vaccination programme uses one vaccine of this type), they are not replication competent and hence generally only stimulate humoral immune responses and they can be relatively expensive to produce. Additionally, depending on the target antigen they may not reflect the true structure of the mature protein and they are most commonly injectable, so individual bird handling is required. Lastly, they generally require booster doses for adequate protection.

Nucleic acid vaccines

Nucleic acid vaccines use genetic material from a disease-causing pathogen (meaning H5 HPAI virus) to stimulate an immune response against it. Depending on the vaccine, the genetic material could be DNA or RNA; in both cases it provides the instructions for making a specific protein from the pathogen, which the immune system will recognise as foreign protein. Once inside host cells, the nucleic acid is used by the cell’s own protein-making machinery and to generate proteins, which then are trigger an immune response.

Since the COVID-19 pandemic there has been a substantial increase in the use of nucleic acid-based vaccines, especially those that utilise mRNA or self-amplifying RNA approaches to generate antigens H5 HPAI virus. 

These types of vaccines have the advantage that they do not have any of the concerns relevant to killed or viral vectored vaccines and can be rapidly adapted to emerging threats, they have very good safety profiles, are DIVA compatible (since the vaccinated bird only produces immunity to the gene provided in the nucleic acid construct), and can be administered to multiple hosts or production types.

However, disadvantages include a paucity of data supporting their use in veterinary applications, they are not generally replication competent and hence typically only stimulate humoral immune responses although self-amplifying RNA (saRNA) vaccines have been developed, depending on the target antigen they may not reflect the true structure of the mature protein, they are most commonly injectable requiring individual bird handling, and they generally require booster doses for adequate protection although some platforms achieve good antibody induction following a single administration.

Key criteria and considerations 

In addition to considering the technology as outlined above, key criteria should be used to distinguish between HPAI vaccines and determine the best for use within the UK. These criteria are: 

  • efficacy of vaccination to confer protection against circulating strains of HPAI. This can be considered as the ability to prevent infection, a reduction in clinical signs or a reduction in shedding from vaccinated but infected individuals. Evidence of efficacy is generally achieved through challenge studies where large infective doses are administered to vaccinated animals and a reduction in clinical signs and shedding is demonstrated. This approach does not indicate that the vaccine confers absolute protection from infection. 
  • duration of immunity, which describes how long neutralising antibody responses last after vaccination
  • age and method of application which considers the appropriate age for vaccination and how the vaccine is administered
  • antibody based differentiation between naturally infected and vaccinated animals (DIVA)
  • handling to include all aspects of handling and distribution including cold chain requirements
  • species coverage which indicates which species the vaccine is effective in or licensed for use in
  • maternal antibody production and interference. This refers to both the transfer of protective antibodies from vaccinated mothers to offspring and the potential interference of these antibodies with vaccine efficacy. 
  • the overall cost of the vaccine including production, distribution, purchase and administration
  • ease of updating, that is how quickly and easily the vaccine can be modified to address emerging strains
  • marketing authorisation (chapter 3) 

The most important considerations are toleration by target species, efficacy, duration of immunity, age, method of application and DIVA potential. If a vaccine does not deliver against these, it is unlikely to be viable in the UK, either because it cannot be effectively deployed in real-world poultry production systems or it would not satisfy fulfilment of any legislation for surveillance requirements. Surveillance requirements associated with vaccination programmes are explored further in chapter 6. 

Assessment of available vaccines 

The Taskforce approached 4 major vaccine manufacturers represented in the UK to better understand what H5 HPAI vaccines were available in other territories. These companies were Boehringer Ingelheim, CEVA International, MSD Animal Health and Zoetis who collectively provided the product profiles for 8 potential vaccines (see Table B.1 Annex B).

The vaccines are based on a range of technologies (see above), and they vary in terms of avian influenza subtypes or origins of H5 antigens included, species and categories of animals for which they are indicated, and the specific claims made.

This diversity reflects the complexity of designing a vaccination strategy that meets the needs of the UK poultry sector. 

Some of the vaccines have been the subject of vaccination trials in France, Italy, The Netherlands and Hungary in a range of poultry species and there is therefore some practical experience of their efficacy in a field situation (see chapter 5 for more detail).

Some of these trials are ongoing especially where challenge studies are being conducted on longer-lived birds. The final results of these trials will not be available until at least Spring 2026 and therefore it is important that the outcomes of those trials are continually monitored, and the information used to help further develop policy.   

No single product fulfils all of the criteria agreed by the Taskforce as being an ideal vaccine, due to diversity in the dosing regime and species for licensed use. The UK industry has a wide variety of poultry types including:

  • short-lived (typically birds like broiler-type meat chickens raised for short periods) and long-lived chickens
  • turkeys
  • ducks
  • other species (typically birds like laying hens and breeder birds kept for longer periods)

Therefore, it is likely that a number of different vaccines would need to be made available to fulfil all requirements for all production types. A range of dosing regimens would be employed depending on the type of vaccine and type of poultry being vaccinated.  

In practice, many avian diseases are better controlled using a combination of licensed vaccines, administered as part of a structured vaccination program, particularly in longer-lived poultry production systems. However, these combinations often involve products from competing pharmaceutical companies. Manufacturers typically do not test the efficacy or safety of their vaccines when used in combination with those of competitors, and such combinations are not scientifically validated or included in the licensing process. 

Several novel vaccines are currently in development. The efficacy and practical application of these new vaccines is currently unknown but is likely to provide a wider range of options in the future. It is important that any programme of vaccination keeps abreast of emerging technologies in this space.

Chapter 5: Outcomes of HPAI vaccination trials  

The continued spread of HPAI across Europe has prompted a need to evaluate the role of vaccination as a control measure.

While vaccination has been used in some parts of the world, its application in regions with strong international trade interests, such as Europe, requires a more rigorous understanding of vaccine performance, trade implications, and surveillance compatibility.

Recent trials across multiple countries have generated valuable data on how different vaccine technologies perform in various poultry species, both in controlled settings and under field conditions. These trials are outlined in this chapter. The studies not only inform current policy considerations but also help identify critical knowledge gaps that must be addressed to support future decision-making. 

Background 

Before 2020, most countries with HPAI vaccination trials did not consider retaining viability of the poultry market for trade as a key requirement.

As such the design of vaccines and their performance characteristics were focused on outcomes, such as protecting local livelihoods and food security. Many of the vaccines used in these earlier programmes relied on conventional methodology, such as, ‘inactivated vaccines’.

However, these vaccines were not designed for use in systems requiring ongoing surveillance to track vaccine effectiveness or to demonstrate disease freedom whilst satisfying DIVA requirements. Nevertheless, some of these programmes have provided practical insights to the use of HPAI vaccination. 

Historically, a number of countries including Russia, China, Mexico, Vietnam, Bangladesh, Egypt and others have been using vaccination with inactivated killed whole virus vaccines to protect birds against avian influenza viruses. However, since 2020, the significant impact of H5 HPAI on European poultry production and wildlife has both raised the possibility of applying vaccination as a tool to protect flocks and has accelerated research into H5 vaccines.  

Recent European research has aimed to improve the evidence base of HPAI vaccine performance, while, more importantly, addressing knowledge gaps of particular relevance to the poultry sector.

This work is of high relevance to the UK industry, where any future vaccination must meet the highest of international standards using the latest science evidence base. Therefore, the European work reported and trials in progress provide important information for the Taskforce. The following summary of EU vaccination trials is not exhaustive but highlights some of the most important findings to inform the recommendations of the Taskforce.  

The EU trials were partially harmonised to ensure the necessary breadth of information was collected. They primarily focused on vaccine technologies with the potential to obtain marketing authorisation and enter the market, while addressing 2 key areas:

  • application to key production species (chicken, turkey, geese and duck)
  • DIVA compatibility

Meeting DIVA compatibility is essential for supporting the trade of birds or their products from a vaccinated population as outlined in the WOAH terrestrial code on HPAI.

In addition, parameters such as duration of immunity and reduction of transmission (both less well understood) within a vaccinated population have also been studied. Most studies focused on immunity in bio secure experimental laboratory facilities.

Valuable extensions to field based trials have been added through an active vaccination programme in rearing ducks in France; and assessment of vaccination in chickens kept on dedicated farms to measure vaccinal responses during normal production in the Netherlands.  

High level overview of EU trials 

Several scientific trials have been undertaken across different European countries. Top line outcomes for each reported study are detailed below and summarised in Annex C. Study objectives have assessed whether vaccines, when implemented under experimental or field conditions:  

  • would be well tolerated in target species and induce an immunity allowing the differentiation between infected and vaccinated animals (DIVA principle)
  • could help reduce the excretion of wildtype HPAI virus following natural infection of vaccinated birds and hence would  
  • limit the transmission of HPAI to other vaccinated birds

France: pilot study in mule ducks 

In France, a pilot study in mule ducks used the VOLVAC-B.E.S.T. AI + ND (BI) and RESPONSE AI H5 (CEVA) vaccines.

The pilot study demonstrated that both vaccines were well tolerated, induced strong antibody responses, and significantly reduced viral shedding. Aerosol transmission was prevented, and the DIVA principle was satisfied.  

France: field vaccination programme in mulard ducks 

In France, a field vaccination programme in mulard ducks used the VOLVAC-B.E.S.T. AI + ND (BI) and RESPONSE AI H5 (CEVA) vaccines.

This field vaccination programme led to active immunisation and reduced clinical signs and viral excretion. Some incursions of wild-type virus were reported, though detailed shedding data were not clear. 

 The Netherlands: trials in layer chickens 

In the Netherlands trials in layer chickens used the following vaccines:

  • Vectormune HVT-AIV (CEVA)
  • Vaxxitek HVT-IBD-H5 (BI)
  • Nobilis LPAI H5N2 (Zoetis)
  • H5 Clade 2.3.4.4b (Huvepharma) DNA vaccine
  • VOLVAC-B.E.S.T AI + ND (BI) (as a booster)

Across 2 linked trials, Vectormune HVT-AIV (CEVA) and Vaxxitek HVT-IBD-H5 (BI) vaccines consistently provided full protection against clinical disease and mortality, effectively prevented virus transmission, including to contact birds, and showed partial efficacy, blocking transmission in one group with strong antibody responses, while the H5 Clade 2.3.4.4b (Huvepharma) DNA vaccine did not prevent transmission.

In the second, longer-term field study, both Vectormune HVT-AIV (CEVA) and Vaxxitek HVT-IBD-H5 (BI) were tested and reduced virus shedding, though not completely. Only the Vaxxitek HVT-IBD-H5 (BI) + VOLVAC-B.E.S.T AI + ND (BI) booster regimen reduced transmission to below threshold levels (R<1), with no mortality and limited shedding.

All HVT-based vaccines demonstrated DIVA compatibility and were suitable for hatchery administration.

The Netherlands are also currently undertaking a vaccine trial using Innovax-ND-H5 (MSD) in rearing layers although results are not yet available. 

 Germany: trials in fattening geese 

In Germany, trials in fattening geese used the following vaccines:

  • RESPONSE AI H5 (CEVA), VOLVAC-B.E.S.T AI + ND (BI)
  • Vaxigen (Reverse Genetics based inactivated vaccine- Avimex)
  • KNewH5 (recNDV- Avimex)
  • Nobilis LPAI H5N2 (Zoetis)

Serological responses were used to guide challenge with only the RESPONS AI and Zoetis H5N2 vaccinated birds being challenged. These 2 vaccines provided full clinical protection and reduced viral excretion. Importantly, where other trials assessed detection of nucleic acid when assessing shedding this study attempted virus isolation from swabs and no live virus was recovered from vaccinated and subsequently challenged birds. 

Italy: trials in turkeys 

In Italy, trials have been undertaken in turkeys with a variety of vaccine formulations, but the full results are currently unavailable. Preliminary anonymised data suggest that a heterologous prime boost strategy with 2 different vaccines is optimal. A single shot of one HVT based vaccine assessed also appeared to give good level of protection from challenge. The full evaluation of these trials, including the vaccines used and approach taken are still awaited. 

Summary

European trials completed to date have demonstrated a range of responses to vaccination in different species subjected to vaccination according to a broad range of regimens.

Understanding responses to different vaccination regimens in different species is complex and requires further assessment. Current trials have demonstrated a utility in application of some of the currently available vaccines although a better assessment of modern innovative vaccines in the veterinary sector is warranted.

Outputs from trials in Italy are eagerly anticipated as they have applied vaccination trials to turkeys, a sector that is attractive for potential vaccine deployment in UK.

Chapter 6: Surveillance 

Effective surveillance is essential to support HPAI vaccination, as vaccinated birds can still be infected with and transmit the virus through excreted material without showing clinical disease.

This chapter outlines the need for enhanced surveillance to detect virus circulation in the face of vaccination, meet international standards, and maintain trade. It summarises current UK practices, international requirements, and APHA’s modelling work, which highlights the effectiveness of dead bird testing.

It also addresses key capacity challenges in veterinary and laboratory services. Together, these elements form the foundation for a surveillance strategy that is scientifically sound, operationally feasible, and internationally compliant. 

HPAI vaccine and surveillance 

Vaccinated birds can still become infected with HPAI, shed virus, and transmit the virus to other vaccinated or unvaccinated birds. In such cases, birds may appear healthy with mild or absent clinical signs, making detection through passive surveillance difficult. Therefore, a robust surveillance strategy is essential for the early identification of any naturally occurring HPAI infections in vaccinated birds, and to provide reassurance that wildtype virus is not circulating within the population. 

An effective surveillance programme for vaccinated birds is required under the WOAH terrestrial code. It is also likely to be a requirement for maintaining international trade in poultry and poultry products.  

Surveillance is the systematic and ongoing collection, analysis, and interpretation of data related to animal health to inform decision-making, and actions aimed at protecting animal and public health, as well as facilitating international trade. It involves monitoring trends, detecting diseases or emerging threats, and providing data for risk analysis.

There are 2 categories of surveillance: 

  • passive surveillance: relies on actions initiated by the observer (poultry keepers and private veterinary surgeons) after detecting clinical signs of the disease, increased mortality or changes in production rates
  • active surveillance: collects data according to a pre-defined plan and it is initiated by the investigator

Current surveillance for HPAI in the UK comprises passive and active surveillance (the annual poultry survey). Additional surveillance components would be required in vaccinated flocks to ensure prompt detection and to provide confidence in freedom in the absence of disease. 

Any surveillance strategy will need to adhere at least to the minimum requirements set out in the WOAH terrestrial code and in EU legislation (under the upcoming SPS agreement), both of which are detailed below. 

Although there are other countries that have vaccinated for HPAI (for example, China, Indonesia, Vietnam), examining their surveillance strategies was considered outside the scope of this report, as their distinct epidemiological contexts likely render those approaches unsuitable for the UK (chapter 5).  

 World Organisation for Animal Health guidance

World Organisation for Animal Health (WOAH) guidance and the WOAH terrestrial code (chapter 4.18) requires undertaking surveillance in flocks vaccinated against avian influenza virus (AIV) to ensure the absence of virus circulation. The testing must be repeated at an appropriate frequency. The code also requires evidence of the effectiveness of the vaccination programme, and this evidence must be gathered during surveillance activities, through assessment of antibody responses.

The following outcomes should be part of the evaluation: 

  • vaccination coverage stratified by species, age, geographical location and type of production system
  • population immunity measured by testing, stratified by species, geographical location and type of production system
  • frequency and severity of side effects 
  • reduction of incidence, prevalence or impact of the disease

WOAH advise that a comprehensive surveillance programme to assess the effectiveness of vaccination would entail the collection of blood samples for the detection of antibodies from vaccinated birds alongside swabbing of birds to exclude infection with naturally circulating viruses.

The sampling plans should consider the characteristics of the vaccines used and requires: 

  • testing a number of live birds per epidemiological unit at fixed timepoints; as well as 
  • sampling and testing dead or diseased birds to assess potential reasons behind morbidity or mortality events and rule out natural infection

EU surveillance requirements 

The EU requirements for surveillance in vaccinated flocks are of particular relevance to the UK. The EU is a key trading partner and, as noted in chapter 2, under the planned SPS Agreement with the EU, we would keep our SPS rules in line with those of the EU’s; therefore we would need to adhere to at least this minimum standard to continue trade. 

Delegated Regulation (EU) 2023/361 sets out the requirements for the different vaccination strategies and the related disease surveillance. There are 3 defined vaccination strategies in article 7 of the Delegated Regulation (EU) 2023/361: 

Emergency suppressive vaccination: implemented in response to an outbreak to control its spread. Only birds that will be killed can be vaccinated under this strategy. 

Emergency protective vaccination: applied in response to a change in the risk of introduction of HPAI. This strategy must be applied in a pre-defined geographical area – the vaccination zone – that must be surrounded by a peri-vaccination zone, where vaccination is not allowed but where surveillance must also be implemented. Vaccines that rapidly confer an appropriate level of immunity would be required. 

Preventive vaccination: to prevent disease introduction and or spread; to maintain freedom and to prevent the economic losses associated with an outbreak when there has not been a prior change in risk. This strategy could be used to target those species or production systems at higher risk of introduction. 

The minimum surveillance requirements differ for each vaccination strategy, and are summarised as follows: 

Emergency suppressive vaccination

There are no surveillance requirements. Animals are vaccinated to be culled as soon as possible. 

Emergency protective vaccination

In both the vaccination and the peri-vaccination zones, surveillance must be established. Reinforced clinical and laboratory surveillance in all vaccinated establishments during the recovery period (28 days after the last vaccine inoculation). This requires collection of samples for virological testing from 60 birds per epidemiological unit (meaning house) every 2 weeks throughout the recovery period. This would allow the detection of disease if present at >5% prevalence with a 95% confidence. Once the recovery period has ended, the requirements of surveillance during and after preventive vaccination apply for as long as an establishment keeps vaccinated birds. 

Preventive vaccination

The requirements where preventative vaccination has taken place are firstly, enhanced passive surveillance in the vaccinated establishments by weekly testing of a representative sample (that is at least one from each epidemiological unit) of dead or moribund birds collected within one week. Secondly, active surveillance by an official veterinarian (OV) every 30 days at vaccinated establishments, to include clinical examination, including a check of production and mortality records and laboratory surveillance by way of collection of samples for virological testing from 60 birds per epidemiological unit (meaning house) to allow the detection of disease if present at >5% prevalence with a 95% confidence.

UK surveillance strategy – modelling work 

Any surveillance programme should be established in accordance with WOAH, EU regulation and the evidence gathered by each country to suit the poultry production systems, the population distribution and the risk factors of the country. This section sets out the work that APHA is currently undertaking to assess the effectiveness of different surveillance strategies in the UK

The European Food Safety Authority (EFSA) opinion concluded that: the strategies based on testing dead birds have a higher probability of early detection of HPAIV than strategies based on testing live birds; and that the effectiveness of the surveillance increased with repeated sampling over time. Several options were identified by EFSA as effective at early detection (and confidence in freedom) for both emergency protective and preventive vaccination.

We have tested the performance of different surveillance strategies (testing dead birds only, testing live birds only, or a combination of both testing regimes) in ducks using GB 2022 to 2023 outbreak data, and conducted a sensitivity analysis to assess the impact of testing at flock versus farm level; varying flock size; variable case fatality rate. Our preliminary results showed that testing each flock (house) is effective regardless the number of flocks per premises or flock size, and that testing at farm level fails to achieve the desired threshold for detection. 

Our preliminary results regarding chickens and turkeys (using GB outbreak data to parameterise our model) agree with EFSA in that testing of dead birds at regular intervals outperforms testing live birds. Many effective surveillance strategies were identified considering factors such as flock size and the uncertainty in the effects of vaccination. We assessed surveillance on flocks of only partially protected birds, which would be the largest of outbreaks in vaccinated populations. It is worth noting that for our estimates, disease would still spread in populations with 70% fully protected and 30% partially protected birds. 

Several surveillance regimes have been identified as satisfactory for early detection of HPAIV. For chickens and turkeys, testing up to 10 dead birds per house every week achieved early detection in 99.97% of the model simulations in the shortest median time after introduction of infection in a flock, compared to other testing regimes. For ducks (and geese by extrapolation) preliminary work suggests that testing up to 10 dead birds per house per week also represents the best performing surveillance strategy for early detection, however, this work is pending completion. 

Additionally, sampling live birds at pre-determined timepoints after vaccination will be required to monitor the performance and effectiveness of the vaccination campaign. For this purpose, 20-30 live birds per farm will be required to be blood sampled at each timepoint; the timepoints must be defined according to the vaccine regimen used.  

To implement the surveillance requirements set out here, there would need to be sufficient veterinary and laboratory capacity. This following section discusses the challenges and mitigations in implementing this. 

Veterinary capacity 

EU legislation on surveillance requires it to be an official veterinarian (OV) who does ‘active surveillance’ at vaccinated establishments (for example, clinical examination, collection of samples). APHA has approximately 11,000 OVs authorised at any time and some of these have very successfully supported the delivery of HPAI outbreak work over the last few years. This resource remains available through APHA’s veterinary delivery partners (VDPs).

If all 800 seasonal turkey producers in the UK were to vaccinate, under the EU standard surveillance requirements that would be 4 visits per farm or 3,200 additional vet visits, noting that all birds would need to be examined. 

In April 2025, there were 30,709 practicing vets in the UK (RCVS). The Royal College of Veterinary Surgeons (RCVS) released workforce modelling, which indicated that in clinical practice supply as a proportion of demand would raise to 91% in 2032 and 99% in 2035. In government service, supply is likely to be 78% of demand by 2032. 

The Department for Environment Food & Rural Affairs (Defra) officials are actively engaging with key stakeholders to review opportunities for reform of the Veterinary Surgeons Act. Part of these reforms are intended to ensure all veterinary professionals are regulated – which would enable a wider range of veterinary professionals (not just veterinary surgeons) to support with capacity. 

Laboratory capability and capacity 

Defra is the central competent authority for the designation of diagnostic laboratories for animal health in the UK under the Official Control Regulations (‘The OCR’)

The OCR sets out a comprehensive and consistent risk-based regime of official controls across the entire agri-food chain.

It defines 2 different categories of laboratories at which official activities and other official activities can be undertaken: 

  • National Reference Laboratory (NRL) – the most senior laboratory for a given pathogen, providing expertise and advice to Defra and the Devolved Governments, diagnostics for notifiable diseases, and training and standardisation of the relevant official laboratories 
  • Official Laboratory (OL) – undertake official activities, including sample analysis as necessary for trade, surveillance, or other testing requirements, under the guidance but not control of an NRL

All diagnostic testing for pathogens or antibodies to them in scope of the OCR must be undertaken at either the NRL or an OL designated for a relevant purpose. The activities of laboratories designated as OLs are typically associated with diagnostic testing for ‘other official activities’ which as defined by the OCR and in relation to animal health include: 

  • activities aimed at verifying the presence of animal diseases
  • preventing or containing the spread animal diseases
  • eradicating animal diseases
  • granting authorisations or approvals
  • issuing official certificates or official attestations 

All diagnostic testing undertaken in relation to avian influenza vaccination is therefore in scope of the OCR and must be undertaken at either the avian influenza NRL located at the APHA Weybridge Laboratory, or another suitably designated OL

Whilst the avian influenza NRL at the APHA Weybridge has the capability it does not and will not be able to provide the diagnostic testing capacity to facilitate the surveillance required to support avian influenza vaccination at scale. 

At the time of publication there are no OLs designated for avian influenza. However, in preparation for more viable avian influenza vaccines becoming available, Defra have conducted an expression of interest exercise to gauge both interest and the capacity and capability of private laboratories to be designated as an OL for avian influenza for the purpose of diagnostic testing in relation to avian influenza vaccination. 

The exact nature and requirements of any OL designation will be highly dependent on the nature of the diagnostic testing to be undertaken which will be influenced by the both the vaccine being utilised and the surveillance programme required. Further details on the steps that need to be taken when pursuing designation as an OL for avian influenza virus diagnostic testing can be found in Annex D.

Chapter 7: Trade 

General trade considerations 

The WOAH guidance states that vaccination for HPAI should not be a barrier to safe international trade in poultry commodities, if both vaccination and surveillance initiatives are properly implemented. Despite this, concerns about potential impacts on international trade continue to limit use of vaccination in many areas globally. 

The UK poultry sector exports a diverse range of products, including poultry meat and meat products, eggs and egg products, as well as breeding stock such as hatching eggs and day-old chicks. The introduction of a vaccination programme could potentially impact the export of all these categories, affecting both vaccinated and unvaccinated products depending on trading partners’ policies. 

If HPAI vaccination is to be permitted, the UK will need to provide information and assurances to trading partners. Assurances would need to include evidence of an effective surveillance programme, demonstrating that vaccination is not simply masking infection which could spread through trade in poultry commodities, and that vaccinated animals and products are meeting international safety standards. 

Even with these assurances, some trading partners may adopt a precautionary approach and introduce restrictions on some exports of vaccinated and unvaccinated poultry, poultry products or both, such as import bans, additional testing, or certification requirements. These measures may be temporary or long-term, depending on the partners’ risk tolerance and regulatory framework.  

Even if vaccination were restricted to one region, it is likely that trade from the entire territory of GB or indeed the UK could be affected by trade restrictions. This is because many trading partners treat GB or even the UK as a single epidemiological unit and may not recognise internal regionalisation for the purposes of trade. As a result, restrictions could be applied uniformly across all regions, regardless of whether vaccination is being practiced locally. 

NI has a separate epidemiological status to GB under the Northern Ireland Protocol and may not be subject to the same restrictions and vice versa. However, movements of poultry and poultry products between GB and NI could still be impacted, particularly if vaccination status influences eligibility for onward export to the EU or other international markets. 

Some existing UK Export Health Certificates (EHCs) contain clauses which will prevent their use if HPAI vaccination is permitted. These would require renegotiation with the competent authorities in the destination countries. The government will work to avoid trade restrictions as far as possible in the event that preventative HPAI vaccination is to be permitted and will seek to reverse any restrictions that may be applied. This is likely to take time to achieve and may ultimately be unsuccessful in some cases. 

The benefits of HPAI vaccination will need to be weighed against the potential loss of some export opportunities, at least in the short term. Importantly, the sectors that benefit most from HPAI vaccination may not be the same as those most affected by trade restrictions. An example could be if free range meat birds are vaccinated, trade restrictions could still be placed on high genetic merit poultry breeding stock even though they are not vaccinated. 

EU trade considerations 

The EU does not prohibit the import of meat from animals vaccinated against HPAI. However, it requires that any vaccination programme fully complies with the conditions outlined in Annex XIII of Delegated Regulation (EU) 2020/692. While there is some flexibility regarding exports of products of animal origin (POAO), this does not extend to live animals. In the case of slaughter poultry, requirement II.2.5(a) of the model health certificate explicitly states that birds must originate from flocks that have not been vaccinated against HPAI, with no provision for derogation. 

To maintain trade with the EU, any UK vaccination programme must be formally approved under EU legislation by submitting a vaccination plan. Without this approval, products from vaccinated animals are not certifiable and cannot be exported. Certification requirements explicitly state that approval of the vaccination plan is a legal prerequisite for trade. Once a vaccination plan is approved and supported by appropriate surveillance, trade with the EU should be able to resume without additional barriers. Surveillance requirements are likely to apply specifically to establishments practicing vaccination, rather than across the entire sector. 

The UK has previously applied restrictions on imports from EU countries initiating vaccination programmes. For example, when France began vaccinating production ducks, their vaccination plan did not initially meet UK certification requirements. GB has recently lifted restrictions on French poultry and products exported to GB following an audit and approval of their amended vaccination and surveillance plans. 

Rest of World (RoW) trade considerations 

The UK poultry sector exports a wide range of commodities beyond the EU. Some of these markets have explicit restrictions on imports from countries using HPAI vaccination and current EHCs prohibit trade if vaccination is in use. Even where EHCs do not explicitly mention vaccination, trading partners may impose restrictions unilaterally in response to perceived risk. In addition, even countries that use vaccination could impose an initial blanket ban, and restrictions might stay in place for months while they carry out their own risk assessments. 

A UK vaccination programme could affect all poultry-related exports, including meat, eggs, and breeding stock. Restrictions may apply across the entire sector, even if only one species or one region is vaccinated.  

NI and GB movements 

Poultry and associated products regularly move in both directions between GB and NI and may then be exported onwards to the EU or rest of the world. A decision to implement vaccination (outside a trial) in poultry in GB and not in NI would have repercussions for the movement of both. 

On-farm trial implications 

The UK may seek to conduct scientific field trials, for example where birds are vaccinated under normal husbandry conditions and then moved to be challenged with live virus in National Reference Laboratory (NRL) high-containment facilities.

There is no guarantee that trading partners would draw a distinction between this and general authorisation of vaccination, but it would be an opportunity to understand potential implications of HPAI vaccination on trade. Potential restrictions could follow and some EHCs could be affected.

This could be mitigated by approaching relevant trading partners with a clear vaccination plan and protocol for the trial, in advance of any field trial commencing. 

The risk of reactive trading restrictions may be reduced if partners are properly informed and consulted in advance, and if they can be reassured there is no possibility that products of vaccinated poultry are being exported. This could require structures to be set up to contain the products either for destruction or solely domestic markets, for example through the use of special marks. This approach has been taken by some trading partners who are undertaking or considering trials.

Chapter 8: Other considerations 

Public health and food safety  

When considering a policy change to allow vaccination against HPAI in the UK, it is essential to assess the potential public health implications alongside animal health and food safety considerations. HPAI is a zoonotic disease, meaning it can spread from animals to humans. Any intervention that alters the dynamics of virus transmission, such as vaccination, must be carefully evaluated to ensure it does not inadvertently increase risks to human health or compromise the effectiveness of surveillance and control measures. 

Consideration should be given to the potential for vaccine escape and virus mutation. These implications may reduce efficacy of any vaccine in humans and poultry, increasing the potential risk of zoonotic transmission and the possibility of virus evolution towards person-to-person transmission.  

Vaccination, if implemented, will reduce the incidence of HPAI in poultry, thereby lowering the risk of worker exposure. For example, there have been very few human cases of HPAI H7N9 in China since they started vaccinating poultry with the H5/H7 vaccine in 2017 (with zero human cases since April 2019)[footnote 1].

However, vaccinated birds may still become infected and shed the virus without showing clinical disease, allowing the virus to circulate undetected in vaccinated flocks. This subclinical transmission poses a risk to workers. To mitigate this risk, any vaccination strategy must be supported by robust, enhanced surveillance systems that target all vaccinated flocks (not just those exhibiting clinical disease) and can differentiate infected birds from vaccinated ones. 

From a food safety perspective, the VMD marketing authorisation takes food safety into account. When withdrawal periods are specified for veterinary medicinal products (VMPs), including vaccines, poultry keepers are prohibited from supplying or selling poultry for slaughter for human consumption unless the withdrawal period has expired. Confirmation that the withdrawal periods have been observed must be declared on Food Chain Information (FCI) that accompanies poultry to slaughter. Food Business Operators (FBOs) must evaluate the FCI and submit it to the Food Standards Agency (FSA) or Food Standards Scotland (FSS). Official veterinarians (OVs) will verify the information and take appropriate actions if discrepancies are either detected or suspected. 

For UK consumers, avian influenza poses a very low food safety risk. Advice from FSA and FSS remains that properly cooked poultry meat, poultry meat products and eggs from vaccinated birds are safe to eat. In this context, no additional labelling or marketing is required on meat or products from vaccinated birds. 

Insurance   

Insurance plays an important role in helping poultry keepers manage the financial risks associated with HPAI outbreaks, including losses from culling, business interruption, and recovery costs. Currently, only a few insurers offer any form of avian influenza cover. Any change in vaccination policy should therefore consider how it may affect the availability, affordability, and structure of insurance across the sector. Strengthening access to insurance can also support the sector’s ability to recover more effectively from outbreaks, contributing to improved resilience. 

If vaccination of poultry becomes widespread and is shown to be effective, this may attract more insurance providers into the market, increase competition, and potentially reduce premiums for poultry keepers. However, there is also a risk that some producers may assume vaccination alone provides sufficient protection and choose not to purchase insurance, which could reduce demand for cover. 

Insurers have indicated support for the strategic introduction of vaccination in specific poultry sectors – in particular, turkeys, ducks, and game birds. These sectors represent subsectors of the poultry industry where avian influenza insurance is often unavailable, leaving producers and growers without adequate financial protection in the event of an outbreak. These sectors face disproportionate levels of risk due to their rearing environments and longer production cycles, making them particularly vulnerable to the severe impacts of HPAI.

In this context, HPAI vaccination, when implemented alongside robust surveillance and DIVA-compliant testing, could serve as a practical risk mitigation measure. It offers the potential to reduce mortality, limit viral spread, and enhance overall sector resilience, while also improving confidence among producers.  

Insurance providers will need confidence in the effectiveness of vaccines, particularly in their ability to protect against new or evolving strains of the virus. A key concern will be whether vaccines remain effective if the virus mutates. This uncertainty could influence both the availability and pricing of insurance. Clear communication will be needed between government, industry and insurance providers. 

If more insurance providers enter the market, or existing providers extend cover to vaccinated birds, improved access to insurance could also unlock investment and diversification opportunities for poultry businesses. Some poultry keepers have previously avoided expanding or entering new markets due to the lack of insurance cover for HPAI

Biosecurity  

Vaccination may influence behaviours and outcomes that should be considered when developing policy.

One concern is that the introduction of vaccination could lead to reduced investment in on-farm biosecurity and contingency planning, particularly if farmers perceive vaccination to be fully protective. Services such as those provided by biosecurity and livestock protection companies, which support biosecurity reviews, contingency planning, and outbreak response, while valuable, can be costly and may be deprioritised by farmers.

It will be important to reinforce that vaccination is a complementary tool, not a substitute for robust risk reduction practices. Should biosecurity practices worsen, this would reduce the long-term resilience of the sector to avian influenza and other diseases in the future. 

Gamebirds 

The game bird sector poses unique challenges for any vaccination strategy, primarily due to the nature of the birds being released into the wild. This transition introduces additional considerations not typically encountered in other poultry sectors. 

Vaccination at the in-ovo or day-old chick stage is technically feasible for game birds. However, it is often more labour-intensive, as most game bird hatcheries are too small to justify automated systems and rely instead on manual methods. Despite their limited number, the few game hatcheries that are large enough to support automation represent a significant portion of the sector’s capacity – estimated at between 50 and 75%. 

Although often deemed farmed for disease control purposes, game birds are still essentially wild and the stress and welfare implications of handling them, unless absolutely necessary, are a major consideration. In most rearing systems, the labour requirement for additional handling is also substantial. If a booster dose is required to achieve adequate protection, the most practical time to administer it would be during the routine catching process prior to release. At this point, the birds are already being handled. For pheasants, this occurs between 6 and 9 weeks of age; for English or grey partridges, between 10 and 12 weeks; and for red-legged partridges, between 12 and 18 weeks. Once released, further vaccination is not possible. 

Duration of immunity is crucial to understanding the likely success of vaccinating gamebirds. 

Breeding game birds are either ‘overwintered’ (retained from the previous year’s production as captive birds until the following breeding season) or ‘caught up’ from the wild.

The former offers much greater control over health status and bloodlines and is favoured by most game bird keepers, despite being more expensive. However, the recent severity and persistence of HPAI outbreaks have highlighted the increased risk associated with overwintering.

As a result, there may be a shift toward using more caught up birds to reduce exposure to HPAI. If vaccination is able to mitigate this risk, it could significantly influence practices across the game bird sector. 

For trade purposes, game meat is often from wild shot rather than kept birds. This would make it difficult to guarantee meat or meat products were from un-vaccinated birds. In addition to the considerations in chapter 7, the potential trade implications of vaccination on this sector should be considered.

Chapter 9: Cost-benefit analysis 

Summary 

This chapter investigates how cost-effective a UK HPAI vaccination programme would be. This assessment is done by estimating the benefits – to industry and government – of avoiding a HPAI outbreak; and the cost of delivering vaccinations and surveillance in line with current EU standards. A comparison of these costs gives the potential value for money (VfM) that a vaccination programme can provide if it mitigates the impacts of an outbreak. An intervention is deemed to deliver positive VfM if the benefits of the intervention outweigh the costs. This analysis quantifies the costs in monetary terms as far as possible; it is acknowledged that the impacts captured are not complete. 

The analysis finds that to break even the package of vaccination and current EU surveillance would need to stop an outbreak >100% larger than the 2022 to 2023 outbreak every year (an equivalent >600% larger than the 2020 to 2021 outbreak). This implies that vaccination and current EU surveillance represent poor VfM for the industry. 

The value for money (VfM) case worsens when considering that: 

  • the benefits of intervention are only obtained if an outbreak is avoided. Whilst outbreaks are increasing in frequency, there is no guarantee that one will occur every year.  
  • vaccines are not expected to provide sterile immunity and therefore it is possible that vaccinated birds could become infected and transmit HPAI within the flock. Under current legislation, these would be considered to be outbreaks and therefore not all disease costs would be avoided. Avoiding an outbreak would also require high vaccine uptake rate, achieving that uptake is unlikely under voluntary schemes and may require mandates or strong regulatory incentives, which should not be expected unless vaccines are mandated[footnote 2].  
  • the current EU surveillance cost estimates are based upon APHA labour and resource rates[footnote 3]. However, the real-world delivery cost could be higher, given APHA faces significant surveillance resource constraints. This means that in practice the private sector would be required to deliver large scale surveillance, which is expected to cost more. 
  • vaccination reduces the efficacy of passive surveillance. Vaccinated animals are less likely to display clinical disease, therefore it takes longer to identify positive cases and implement wider reactive measures. Increased EU surveillance aims to mitigate the impact of this, but the net impact is uncertain. 

The costs associated with the vaccine and surveillance package, for preventive vaccination, are assumed to fall on industry. However, the benefits of avoiding an outbreak are shared by both industry and government. For government, this comes from 2 main routes: spend on resource for outbreak responses, including surveillance and testing functions; and compensation to keepers following culling orders. For industry, outbreak costs include: animal losses not compensated for; responding to housing measures and the associated production losses; managing infected sites; and trade restrictions. 

The analysis outlined here includes a simplified breakdown of costs by avian production groups, to understand the variation in VfM conclusions for each. Ducks and geese provide consistently good value for money, significantly higher than other production groups. Turkeys provide VfM in 2 out of 3 outbreak scenarios considered, and breeders provide VfM in the largest outbreak scenario modelled. Subgroups within each broad production group may deliver VfM; for example, seasonal turkeys have higher value than non-seasonal turkeys and so vaccinations are more likely to offer VfM. These conclusions do not reflect the potential negative trade implications that vaccinating a single production group could have for other production groups. 

Analytical assurance: Medium 

An Analytical Assurance Statement is a short summary of the level of assurance that can be attributed to a piece of analysis that forms part of the decision-making process. 

This analysis draws upon data from previous outbreaks and estimates associated with vaccination and further surveillance. The modelling relies upon over one hundred inputs and assumptions, based upon the best available data guided by expert opinion from within the Taskforce. All assumptions are set out in Annex E1. Switching values analysis has been conducted to account for the uncertainty present. Further sensitivity analysis has been used to test the most influential assumptions and found they have limited impact on the conclusions of the analysis.  

Scope of the cost-benefit analysis 

The cost-benefit analysis compares the cost of an outbreak with the cost of a package of interventions, including vaccination and EU surveillance measures (chapter 6). These measures aim to reduce the likelihood and scale of an outbreak. However, for simplicity, the modelling assumes all costs of an outbreak would be avoided if vaccinations and EU surveillance measures were employed. Therefore, the estimated benefits should be treated as an upper bound. 

This analysis assumes that preventative vaccination is carried out on commercial premises. Due to data limitations, some premise types (for example, game shoots and zoos) and non-commercial premises are not currently included in the analysis.  

In line with the HMT Green Book[footnote 4] guidance: all costs and benefits are assumed to be additional relative to a Business-as-Usual scenario involving ‘no vaccination’; and impacts have been assessed using a switching values analysis and we have compared 1 and 10-year appraisal periods, adjusted using a future discount rate of 3.5%. All costs and benefits are presented in 2025 prices.  

Benefits of intervention: outbreak costs avoided 

HPAI outbreak costs represent the potential benefits that can be achieved by implementing a fully effective vaccination and EU surveillance scheme. The scale of a potential future outbreak is difficult to estimate, with the last 4 administrative periods (1 October to 30 September) having, 24 (2020 to 2021), 157 (2021 to 2022), 206 (2022 to 2023) and 6 (2023 to 2024) infected premises being detected. To date there have been 65 infected premises between 1 October 2024 and the 15 July 2025.

To address this, the analysis creates a cost breakdown from each of 3 previous outbreaks, to provide a reasonable range of potential outbreak costs: 2020 to 2021 (low scenario), 2021 to 2022 (central scenario) and 2022 to 2023 (high scenario). Switching values analysis is then used to forecast how large future outbreaks would have to be for the VfM case to change. 

Monetised benefits 

The direct benefit of vaccination and EU surveillance is the avoided or reduced scale of cost from future HPAI outbreaks. The analysis monetises the costs from outbreaks, as set out in Table 1. This table also states the level of confidence in the assessment of each impact, this relates to confidence the impact is being correctly captured, and the inputs are accurate. 

The analysis includes 9 monetised outbreak costs and are listed as follows: 

  • animals lost 
  • secondary cleansing and disinfection  
  • housing measures 
  • movement restrictions 
  • trade restrictions 
  • compensation to keepers  
  • government staff 
  • operational 
  • surveillance 

Annex E2 sets out the level of assurance of each of these monetised impacts. These vary from low to high. 

Distributional impact of disease costs 

Significant costs are incurred by the owners of infected premises. These include: the direct impact of birds lost through the virus and those culled as part of the disease control measures; and the cost of secondary cleaning and disinfection to make the site suitable for return to normal operation.  

In addition to those keepers that have infected poultry, those that fall within the disease control zones are also financially impacted. Keepers in this group, including those on infected premises, have limited ability to move livestock and restock farms. Wider industry will also be affected by any trade restrictions placed on UK producers following an outbreak. This will most notably limit exports until countries accepting regionalisation start accepting goods from uninfected areas. This is estimated to take about 4 months. 

Some outbreak costs are also borne by the government, who reimburse keepers for the processing and loss of culled healthy poultry. Additionally, this modelling captures the cost of government staff involved in responding to the outbreak and maintaining necessary surveillance. 

Modelling outputs 

A summary of the outbreak costs from this analysis are presented in Table 1. Further details of the inputs and assumptions can be found in Annex E1. 

Housing measures costs represent the largest share of costs in the low and central scenario. This is driven by the fact that this modelling assumed that most UK premises spent between a third and half of the outbreak years under housing measures. It is likely that this is an overestimate since certain regions and premises may have been exempt from these housing measures.  

The central estimate for housing measure costs is higher than the high estimate. This is because, whilst the 2022 to 2023 outbreak was larger overall (leading to much higher levels of culling and compensation), the housing measures lasted slightly less time than in the 2021 to 2022 outbreak (4.9 months in a year compared with 5.1 months). This leads to a marginally higher housing measures cost for the central outbreak scenario. 

In the high outbreak scenario, the largest costs come from the poultry lost. This is unsurprising since the 2022 to 2023 outbreak is the largest on record and led to a large number of cases with culling of infected premises. 

The level of variance of poultry lost is very high. This varies by 15% to 160% of the central estimate. By contrast housing measure costs are clustered much more tightly, varying by 70% to 95% of the central estimate. This is a consequence of poultry lost being much more highly influenced by the overall vulnerability of premises to outbreak (which was highest in 2022 to 2023) whereas housing measures are enforced as a blanket measure irrespective of the scale of the outbreak. Within the analysis housing measure vary in how long they are enforced for.

Table 1: Summary of outbreak costs across a range of 3 scenarios, £million
 Impact                 Affected stakeholder            Low scenario (£millions)  Central scenario (£millions)   High scenario (£millions) 
Animals lost                          Cost to infected premises           £3        £20         £52        
Compensation from government                 Cost to infected premises           -£2        -£12          -£44        
Secondary cleaning and disinfection  Cost to infected premises           £1        £9         £12        
Housing measure costs                Cost to premises in disease control zones  £25      £36         £34        
Trade restrictions                   Cost to wider industry           £16      £16         £16        
Compensation to farmers               Cost to government              £2       £12         £44        
Government staff                      Cost to government             £2       £14         £20        
Operational                          Cost to government             £2       £13        £36        
Surveillance                          Cost to government             £0        £2         £2         

Non-monetised benefits 

The analysis of non-monetised benefits focuses on direct impacts to government and industry. There are additional indirect benefits derived from avoiding HPAI outbreaks. 

Wider impact on businesses that are not poultry holdings but may be affected through the supply chain, such as abattoirs and egg packers, have not been monetised in this analysis. Whilst not the core stakeholders and decision makers, this analysis acknowledges this as an important impact. The analysis has not monetised these due to a lack of reliable and robust data to analyse the costs to these businesses. This is partially corrected by overestimating the trade production shock and the analysis still captures the impact that informs industry decision making. More details on this are given in Annex E2. 

This modelling has been unable to capture the costs of business disruptions. These are faced by businesses that, due to imperfect markets, may not be able to re-stock and return to full production levels after disinfecting their farm and returning to disease-free status. In these cases, impacted businesses face a loss of revenue that is not covered by government compensation. Due to analytical constraints, it has not been possible to quantify these impacts in this appraisal, however, future analytical work could attempt to draw on data from insurance markets to estimate the likely scale of these effects. 

Additional non-monetised effects include the welfare improvement for keepers and poultry, along with a broad range of long-term benefits, such as reduced economic scarring and improved food security. Due to a lack of available data, and the difficulty of robustly attributing vaccination to these impacts, they have not been monetised at this stage. 

Costs of intervention 

The costs of intervention are derived from the cost of vaccination and the cost of complying with additional surveillance requirements (chapter 6). The cost of both preventative vaccination and EU surveillance are assumed to be borne by industry, given the benefits of vaccination are primarily realised by industry. 

Monetised costs 

The monetised costs of intervention include the costs associated with vaccination as well as the costs of EU standard surveillance. 

Table E2.2 in the annex summarises these and sets out the associated assurance levels. 

Vaccination costs 

Vaccination costs are made up of cost of administration time and costs of vaccine materials. The cost of vaccination materials has been estimated based on assumptions collated and verified with the Taskforce (Annex E1). Costs of vaccine materials vary depending on whether a follow up booster is used and the development stage at which vaccine is administered. 

The costs associated with time to administer vaccines varies depending on whether the vaccine is administered at the same time as other vaccines or separately. Vaccinating for HPAI separate to other vaccinations is likely to create inefficiencies which would increase the cost of farmer time per bird.  

The use of a follow up booster may increase disease suppression of HPAI within birds (chapter 4). However, only certain categories of poultry are kept for a sufficiently long period to benefit from this protection. The modelling assumes a 1.9% of turkeys, breeders and ducks have a second dose of vaccine to represent this booster. 

The cost of vaccine materials is most affected by the amount of vaccine dosage required. Vaccine dosage required varies depending on whether vaccination is given in day old chicks or in ovo (inside the egg). For breeders, vaccinating in ovo will require twice the dosage, as they must vaccinate all eggs while only female birds are kept. For breeders therefore, vaccinating in ovo is approximately 8p, instead of 4p per bird. 

Industry may prefer in ovo vaccination since handling costs are understood to be lower. Due to data limitations, this modelling has not been able to assess the relative handling costs of in ovo vaccination compared to day-old. Therefore, in ovo vaccination is always estimated as being more expensive within this analysis. For further details see Annex E3. 

Time costs associated with administering vaccines varies depending on whether the vaccine is administered at the same time as other vaccines or separately; it is assumed that vaccinating for HPAI separate to other vaccinations creates inefficiencies which increase the cost of keeper time per bird. 

This modelling has assumed that the lowest cost option is selected in both cases, as shown in Table 2, meaning that day old chicks are vaccinated in combination with other vaccines being administered. A full breakdown of the inputs informing these cost estimates is given in Annex E1. Additionally, Table E3.1 in Annex E3 shows the upper-bound vaccination costs.  

This analysis has assumed that the lowest known cost option is selected for both time and materials costs – that day old chicks are vaccinated in combination with other vaccines being administered. A full breakdown of the inputs informing these cost estimates is given in Annex E1. Additionally, Table E3.1 in Annex E3 shows the upper-bound vaccination costs.

Table 2: Total cost of vaccination, rounded to the nearest £million

Production system      Dosage cost (£millions)      Delivery cost (£millions)      Total cost (£millions)    
Broilers                          £100                           £88                              £188                        
Turkeys                           £1                             £1                              £1                          
Laying hens                       £4                             £4                               £8                          
Breeders                         £1                             £1                               £2                          
Ducks                             £1                             £0                               £1                          
Undefined                         £1                             £0                               £1                          
Total cost                      £107                           £94                              £201                        

Table 2 shows that the total cost of vaccination varies significantly by production system. Given that the per bird cost is relatively consistent, the costs associated with each production system are primarily determined by the number of birds. 

The cost of administering the vaccine per bird reduces slightly as flock sizes increase. As a result, broilers, which have relatively large flocks, make up approximately 95% of the birds captured in the modelling and approximately 90% of vaccination costs.  

Vaccination of all commercial poultry in the UK is therefore estimated to cost a minimum of £200 million each year.

EU surveillance 

Analysis of current EU surveillance for HPAI is based on the requirements outlined within chapter 6. Vaccines reduce passive surveillance efficacy. Because vaccinated poultry are less likely to display clinical signs it takes longer to identify positive cases and implement wider reactive measures, increased EU surveillance aims to mitigate the impact of this. 

Current EU standard surveillance requires monthly vet visits to premises and weekly samples sent by keepers for testing for each epidemiological unit. The vet visits would involve a PCR and serology test for 60 birds from each epidemiological unit, whilst the weekly sample requires 10 dead birds to be sent for testing per epidemiological unit. These are referred to as the ‘current’ requirements within the analysis. 

In line with the surveillance chapter of this report, the burden of this surveillance could be reduced with limited impact on the surveillance sensitivity. The proposed alternative would remove the requirements for monthly serology tests, whilst keeping the weekly PCR sampling of epidemiological units. This reduces the cost through removing an additional testing process. It is assumed that the benefits (of an outbreak avoided) remain the same in both scenarios. These are referred to as the ‘proposed’ requirements within the analysis and are in line with the surveillance requirements set out in the section on UK surveillance strategy in chapter 6. 

When estimating the benefit-cost ratios, detailed in the final section, this analysis uses the proposed and more cost-effective proposal for the estimate of proposed EU surveillance cost. 

Within this analysis, the costs of surveillance are estimated by combining: 

  • the materials and time per epidemiological unit (for example sampling paraphernalia) 
  • the number of epidemiological units per premises
  • the visit duration per premise (for example, travel time per premise) 
  • the number of premises 

Under the current EU surveillance requirements, the monthly cost per epidemiological unit is estimated to be £1350. The majority of this is made up of variable costs, such as testing materials (including swabs, gloves and bio bottles for sending swabs, approximately £800). By applying APHA’s proposed surveillance model, these costs fall to approximately £800 per epidemiological unit. These estimates are based upon current APHA laboratory costs (Table E1.2 details the assumptions used)[footnote 5] the Taskforce would need to understand the cost implications if moved to the private sector. 

The level of surveillance required for each premise, and therefore the associated costs, will scale with the number of epidemiological units and the proportion of the year for which flocks are stocked on the premises. The analysis takes an epidemiological unit average for each production system, assuming an average across all production systems of 4 units per premise. Seasonal turkeys have the fewest (2), and game breeding premises (captured within the ‘undefined’ category) the most (17). Most premises have flocks present for 6-12 months of a year, with seasonal turkeys and some game bird premises active for fewer months of the year. 

There is a significant range in the number of commercial farms within each production system. For poultry meat, this analysis uses Red Tractor and the British Poultry Council (BPC) premises numbers, which is far fewer than the ~200,000 registered poultry keepers in GB. Within the UK, there are approximately 2,000 commercial broiler farms, 2,000 commercial laying hen farms, 1,000 turkey farms, 125 breeder farms and 50 duck farms. 

Table 3 shows the total annual costs for each bird type under both surveillance scenarios. These vary between £155 and £180 million depending on the surveillance requirements that are put in place. Broilers and laying hens collectively make up approximately 70% of these costs, driven by their high premises numbers and relatively high proportion of months with flocks present.

Table 3: EU surveillance costs by bird type (£millions)
Bird type    Number of farms  Current (millions)  Proposal (millions) 
Broilers     2,040            £71                 £54                 
Turkeys      1,035            £21                 £19                 
Laying hens  1,955            £60               £54                 
Breeders     125              £15                 £15                 
Ducks        50               £1                  £1                  
Total        15,580           £180                £153                
Total intervention costs 

The estimated total monetised costs of intervention are £345 million per year. This is based on combining central estimates of the vaccination and EU surveillance costs. Figure 1 breaks down these costs. If less efficient vaccination costs are assumed, along with the current EU surveillance requirements, these costs are estimated to rise by a further approximate £200m.

Figure 1: Breakdown of intervention costs

Non-monetised costs 

There may be additional costs associated with vaccination, which have not been monetised. These include potential trade restrictions (chapter 7) and zoonotic risk (chapter 8). 

Summary of results 

This analysis finds the annual net impact of intervention for the 3 modelled outbreak scenarios to be a net loss of between £180 and £304 million. These are based on outbreak costs of between £50 and £174 million and a net cost of intervention of £345 million. If these costs were to continue over a 10-year period, this would equate to a net loss to society of between £1.5 and £2.6 billion. 

The benefit-cost ratio (BCR) shows the return for every pound spent on a project; anything below 1 means that the costs outweigh the benefits. As shown in Figure 2, the BCR ranges between 0.14 and 0.5. This means that the annual outbreak cost would have to be double that of the 2022 to 2023 outbreak for vaccination to break even on its costs. This represents poor value for money.

Figure 2: Benefit Cost Ratios for vaccination of all birds

Analysis by species 

High-level analysis of the sectoral impact has been carried out for broilers, turkeys, laying hens, breeders and ducks. For each species, the estimated cost of intervention is calculated using a methodology that mirrors the approach taken for all poultry, combining the cost of vaccination per species with the costs associated with tracking surveillance on those species. 

Whilst this analysis has a per-species breakdown of compensation data, species data on the other outbreak costs avoided was unavailable. Therefore, the total estimated benefits are scaled by the relative proportion of infected premises (IPs) for each species during previous outbreaks. For example, since 11% of premises in the 2021 to 2022 outbreak held broilers, to find the total outbreak costs to broilers this analysis multiplies the total 2021 to 2022 cost by 11%. This is a simplified approach that does not consider cross-species variation in operational, trade and movement costs. 

Vaccination activity does not just affect the vaccinated premises but also surrounding premises. Vaccines can prevent onward spread of the virus meaning that non-vaccinated species may benefit from the vaccination of other species. However, vaccination may increase the scrutiny and restrictions on trade for the whole poultry sector. The overall impact of these vaccination externalities has not been possible to capture within this analysis, reducing the strength of conclusions for vaccinating single production systems set out below. 

Results of this by-species analysis are shown in Table 4. Ducks and geese are the only species that offers high VfM across most scenarios, though turkeys offer positive Net Present Value (NPV) in most scenarios. Vaccinating all other species is estimated to deliver a net societal loss. The high VfM of ducks and geese is primarily driven by significantly lower costs of surveillance than other species, which in turn is driven by a relatively low number of epidemiological units requiring surveillance, compared to a relatively high value per bird.

Table 4: Sectoral costs and benefits (£ millions)

Production system  Total cost (intervention, £millions)  Total benefit  (outbreak cost avoided, £millions): Low  Total benefit (outbreak cost avoided, £millions): Central Total benefit (outbreak cost avoided, £millions): High Benefit cost ratio (BCR): Low   Benefit cost ratio (BCR): Central   Benefit cost ratio (BCR): High 
Broilers           £234  £5  £10  £20   0.0  0.0   0.1  
Turkeys            £21  £16  £26   £59   0.8  1.3  2.9  
Laying hens        £61  £4  £35  £37   0.1    0.6     0.6  
Breeders           £18   £10  £11  £19   0.6  0.7      1.1  
Ducks & geese      £2   £4    £17    £23   1.8   7.6  10.3 

Figure 3: Range of Benefit Cost Ratios (BCRs) across different production systems

Conclusion 

The analysis finds that overall vaccination of all poultry in the UK would likely offer poor value for money (VfM). This assessment was made by combining the monetised benefits and costs, along with a review of the identified non-monetised impacts. Given the strength of the conclusion, sensitivity analysis conducted and review of the non-monetised impacts, the conclusion of poor VfM in the monetised benefits is not expected to change. 

The analysis finds the package of vaccination and proposed EU surveillance would need to stop an outbreak approximately 100% larger than the 2022 to 2023 outbreak every year to break even. It would need to be approximately 600% larger than the 2020 to 2021 outbreak. 

Given vaccines are not fully effective at preventing outbreaks, it is unlikely the full cost savings from intervention would be realised. Similarly, there is the possibility that uptake is lower than estimated, reducing effectiveness. Therefore, this would represent worse VfM. While vaccines may remain effective for longer than assumed, this has limited potential to influence the VfM given the short time for which most poultry species are kept. 

There are several non-monetised benefits of vaccination and surveillance that were not included within the modelling. These include: the benefits of avoiding disruptions to poultry keepers in returning to business-as-usual post-outbreak; spillover impacts to non-poultry producing businesses caught within surveillance zones; the negative welfare impacts on poultry and keepers caused by HPAI and the consequential interventions required (such as culling); and the long-term regional economic impacts. 

For species-level vaccination: 

  • the relatively high value of ducks and geese relative to costs of surveillance makes them unique in providing high VfM 
  • turkeys represent the next best VfM, with a positive VfM case in most outbreak scenarios; the VfM for seasonal turkeys may be greater given their higher value, however the data is insufficiently granular to enable this level of analysis
  • vaccination of breeders can deliver a BCR slightly above 1 in the worst outbreak scenario
  • other production groups are expected to deliver poor VfM

Chapter 10: Discussion of vaccination strategy options 

In considering the future role of vaccination in the UK’s response to HPAI, the Taskforce has identified a range of vaccination strategies. These options reflect different balances of benefits, risks, and feasibility; and consider the scientific, regulatory, and operational considerations outlined throughout this report.

However, each carries a degree of uncertainty, particularly regarding vaccine performance, surveillance requirements, trade implications, and cost-effectiveness.

Importantly, any vaccination programme would need to be implemented under the control and oversight of the competent authority, to ensure regulatory compliance, animal health protection, and alignment with international standards. It must also be developed with due consideration for public health and food safety. 

Given these complexities, the Taskforce does not currently recommend that any of these strategic options are progressed at this stage. Instead, the recommendation is for further action to be taken by the Taskforce, including steps to better understand vaccination options and their applicability within the UK. Once this has been completed, the Taskforce anticipates recommending government permits vaccination of turkeys, ducks and geese; and will keep other poultry species under consideration. 

There are 3 main options for vaccination strategy in the UK. These are to:

  • maintain the current policy (only allow vaccination in zoo birds)
  • use an emergency vaccination based on risk assessment and agreed trigger points
  • allow preventative vaccination either nationwide or within targeted geographic regions or species groups

Maintain current policy 

Under this option, the UK would continue with its current approach, which prohibits the use of vaccination against HPAI in commercial poultry, except in zoos. Disease control would continue with existing measures such as culling, movement restrictions and housing measures. Additionally, enhanced biosecurity remains a key preventative measure, accessible to all poultry keepers, helping to reduce the risk of disease introduction and spread. The factors to be taken into account in considering this option are: 

Disease control: offers no opportunity to reduce the baseline risk of virus circulation or mutation, which could have long-term implications for both animal and public health. Does not generate any new evidence on vaccine performance or surveillance feasibility, leaving the UK less prepared for future changes in disease prevalence or new virus strains. 

Trade: avoids immediate changes to trade arrangements, which are currently based on a no-vaccination stance. While renegotiation may be possible, the implications are uncertain and would need further exploration. 

Surveillance: does not require any new surveillance infrastructure or additional veterinary or laboratory resources, which is particularly important given current capacity constraints. 

Cost-benefit analysis: avoids the significant costs associated with implementing a vaccination and surveillance programme, which would not offer good value for money across the sector under current assumptions.  

Other considerations: culling places considerable economic and emotional strain on farmers, maintaining current policy may be seen as withholding a viable tool for protecting animal health and farm livelihoods.

Emergency vaccination only 

This option would maintain the current prohibition on routine vaccination but allow for increased emergency use in response to outbreaks, subject to strict controls and pre-authorised protocols.  

Disease control: provides a flexible and targeted response to outbreaks without committing to a full-scale programme. However, this approach does not reduce the baseline risk of HPAI or prevent outbreaks from occurring.  

Trade: may be more acceptable to trading partners, as it would be used only in exceptional circumstances. 

Surveillance: for emergency suppressive vaccination no post-vaccination surveillance is required, reducing resource requirements. For emergency protective vaccination surveillance is still required which could put pressure on resources depending on the size on the vaccination zone. 

Cost-benefit analysis: report does not provide a detailed economic assessment of emergency vaccination as a standalone strategy.

Other considerations: emergency vaccination also requires advance planning, including vaccine authorisation, stockpiling, and training, to ensure rapid deployment when needed. Without these preparations, emergency vaccination may be difficult to implement effectively. 

Introduce preventative vaccination 

Allowing preventative vaccination against HPAI would enable the UK to act before an outbreak occurs or when risk levels increase, strengthening preparedness and resilience across the poultry sector.

Factors to be taken into account in considering this option are: 

Disease control: by reducing virus transmission, vaccination can help safeguard poultry health, protect workers in commercial environments, and support the long-term viability of farms. It also aligns the UK with international trends, where vaccination is increasingly being explored as part of comprehensive HPAI management. It must be noted there are also concerns that suppressive vaccines could mask infection, delaying detection and increasing the risk of viral mutation.  

Trade: some international partners may impose restrictions on poultry product imports from vaccinated flocks in the UK. That said, there are precedents for safe trade in vaccinated products, such as the export of duck meat from France to the UK, provided establishments meet agreed testing and certification requirements. 

Surveillance: any vaccination strategy would require a robust surveillance infrastructure, which could place additional strain on already stretched resources and would require significant increases in OV and laboratory infrastructure.

Cost-benefit analysis: economic modelling suggests that, overall, vaccination may offer limited value for money, with only certain species, such as ducks, geese and turkeys, showing a positive return on investment based on current modelling. 

There are different ways in which preventative vaccination could be implemented, each with its own set of advantages and challenges, including nationwide, regional, and sector-specific approaches. These are outlined here, along with the factors to be taken into account in considering each option. 

Nationwide vaccination 

A nationwide vaccination programme would permit vaccination across all poultry sectors and regions in the UK, either on a voluntary or mandatory basis. 

Disease control: offers the most comprehensive level of protection, with the potential to significantly reduce virus transmission and demonstrate the UK’s commitment to proactive disease control. 

Trade: would require the most extensive surveillance system of all the options, to meet WOAH and EU standards for trade across a large and diverse population of vaccinated premises. 

Surveillance: this would lead to considerable pressure on existing surveillance capacity and resources, including significantly increasing OV and laboratory infrastructure, particularly in ensuring timely detection, monitoring, and certification.

Cost-benefit analysis: overall vaccination of all poultry would offer very poor value for money. This approach would be the least cost-effective of all the options, as it is the most resource-intensive and includes species where vaccination shows the lowest return on investment. 

Regional vaccination 

A regional vaccination programme would allow vaccination only in designated high-risk geographic areas, such as where poultry density is high or outbreaks have been more frequent. 

Disease control: would limit spread of infection in high-incidence zones which would reduce virus shedding and transmission. 

Trade: if trading partners accept regionalisation, surveillance requirements may be limited to vaccinated zones, reducing the burden. 

Surveillance: surveillance requirements would be more manageable under this model, as the number of vaccinated premises would be limited to specific zones, but would still require an increase in laboratory infrastructure and OV resources.

Cost-benefit analysis: enables more efficient use of resources by focusing efforts where they are most needed, potentially achieving greater impact at a lower overall cost (although the VfM of regional vaccination has not been assessed as part of this work). It also offers a way to support the long-term viability of farms in regions that have experienced repeated outbreaks, providing reassurance to producers and investors. 

Other considerations: may lead to perceptions of inequality among producers outside the designated areas who also face risk but are not eligible for vaccination. 

Sector-specific vaccination  

A sector-specific vaccination programme would restrict vaccination to selected poultry sectors, such as ducks or turkeys, based on their relative risk profile and economic characteristics.  

Disease control: allowing vaccination in high-risk sectors would strengthen disease control by reducing virus transmission in the species most vulnerable to infection. 

Trade: impacts may also be more contained, particularly if vaccination is limited to sectors with minimal export exposure. However, this approach may still raise concerns about fairness, as producers in non-vaccinated sectors could feel disadvantaged. 

Surveillance: operationally, a sector-specific approach would be easier to manage and could be tailored to the unique needs of each sector, with more streamlined surveillance and vaccine logistics, but would likely still require an increase in available OV resource and laboratory infrastructure to support testing.

Cost-benefit analysis: while vaccination is generally considered to offer poor value for money across most poultry sectors under current assumptions, targeting those sectors that demonstrate comparatively better returns, albeit still below the threshold for cost-effectiveness, could represent a more pragmatic and proportionate use of resources. By focusing on specific sectors, more targeted benefits could be delivered while avoiding the broader costs and complexities of a nationwide rollout. 

Voluntary or mandatory 

An additional consideration for preventative vaccination is whether implementation should be voluntary or mandatory.

A voluntary approach respects farmer autonomy and may be more politically and publicly acceptable. However, with associated costs it carries the risk of low uptake, which can undermine disease control objectives and reduce the cost-effectiveness of surveillance investments. Without sufficient participation, the benefits of vaccination may not be realised, while the costs remain high.

In contrast, a mandatory approach ensures consistent uptake and maximises the potential benefits of vaccination. It also simplifies planning and resource allocation. Mandatory vaccination may face resistance from industry stakeholders and could be more difficult to enforce.

The decision between voluntary and mandatory implementation must therefore carefully weigh public health goals, economic efficiency, stakeholder engagement, and practical feasibility. 

Preferred approach 

The Taskforce considers sector-specific vaccination to likely be the most proportionate and effective approach, as it balances disease control, operational feasibility and economic impact. This is particularly relevant for ducks, geese and turkeys, where VfM is greatest. While this is the preferred option and international progress and emerging vaccine technologies offer promising prospects, the Taskforce will undertake further work and research before making a final recommendation. 

Identifying critical knowledge gaps 

Several essential knowledge gaps must be resolved before a final recommendation can be made: 

  • vaccine performance: there is limited data on how authorised vaccines perform under UK production conditions, particularly regarding efficacy, duration of immunity, and compatibility with surveillance tools such as DIVA. While European trials have shown varied responses across species and regimens, further assessment is needed to determine suitability for specific sectors in the UK. Currently, only 3 vaccines are currently authorised for use in GB and NI, and their performance should be evaluated in target sectors before broader deployment is considered. The potential for use of vaccines using a prime-boost strategy should also be explored.
  • operational delivery: the logistics of vaccine administration, including protocols and both workforce and laboratory capacity, have not yet been tested in practice
  • economic viability: initial modelling suggests potential for cost-effective deployment, but these assumptions require validation through real-world data
  • trade implications: the impact on international trade remains uncertain - engagement with trading partners is needed to understand how surveillance and certification protocols will be received
  • stakeholder response: the attitudes regarding uptake are currently unknown, yet will be critical to the success of any vaccination programme

Next steps 

To address and close these gaps, the Taskforce will lead or champion several short-term steps to be taken in advance of making a recommendation on the options outlined above. The Taskforce expects to drive these actions forward over the coming 12 months, through targeted joint working groups, subject to necessary agreements, before publishing an addendum with a final recommendation in summer 2026. 

A targeted on-farm vaccination trial in turkeys 

Turkeys are among the most susceptible poultry species to HPAI, with high mortality rates and severe clinical signs during outbreaks. During the 2022 to 2023 season, turkeys had the highest proportion of infected to uninfected premises of any species. Economic modelling suggests that turkeys offer a favourable value for money profile due to their higher per-bird value and shorter production cycles.

A targeted trial in this sector would generate UK-specific evidence on vaccine efficacy, duration of immunity, and surveillance feasibility. Given the relatively small number of turkey farms and epidemiological units, this trial would be logistically manageable and provide a valuable opportunity to test EU-aligned surveillance protocols in a real-world setting.

More information on this trial is detailed in Annex F. Birds would be vaccinated under normal husbandry conditions and then some birds would be subject to challenge in national reference laboratory high-containment facilities. 

Strengthen operational readiness through training and capacity building 

The successful delivery of any vaccination programme will depend on the availability of trained personnel. Training and upskilling opportunities will be explored for OVs to support vaccine surveillance. In parallel, a review of veterinary capacity to support HPAI vaccination will identify gaps and ensure readiness for scaled implementation. 

 Laboratory infrastructure investigation 

A detailed assessment will be completed, to determine the laboratory infrastructure required to support vaccination, including the necessary standards, the number and capacity of designated official laboratories able and willing to deliver testing, and the associated operational and financial implications. 

Conduct research to understand likely uptake among poultry keepers 

The success of any vaccination strategy will depend on uptake by poultry keepers. Research will be undertaken to assess attitudes, perceived barriers, and likely participation rates across different sectors. This will inform recommendations on future vaccination strategy and associated communications. 

Engage early with trading partners to manage trade risks 

Early and proactive engagement with trading partners will be essential. Given the uncertainty around how vaccination may affect export conditions, this engagement will aim to clarify requirements, overcome barriers, and build confidence in the UK’s surveillance and certification approach. The proposed trial would provide an opportunity for early discussion of trade considerations for HPAI vaccination.  

Evaluate the potential impact of vaccination on the game bird sector 

Further investigation into the game bird sector will be undertaken to assess the feasibility of vaccination in this sector, including the implications for surveillance, trade, and environmental release of vaccinated birds. 

Continue close engagement with public health and food safety organisations 

The Taskforce will oversee work with these organisations to fully explore public health and food safety implications of HPAI vaccination. 

Other areas to explore 

In the course of its investigations, the Taskforce has identified other areas which would benefit from further parallel investigations. These would support exploration of how vaccination could support a long-term approach to managing avian influenza both within and beyond poultry. However, much of this is beyond the remit of this Taskforce. These are outlined here. 

Explore the feasibility of vaccination in wild birds 

Although wild birds fall outside the immediate scope of this Taskforce, future work should consider the potential for vaccination in species of conservation concern. Government, in collaboration with statutory nature conservation bodies and environmental NGOs, should continue to explore the viability and considerations of vaccination in these contexts. 

Explore the feasibility of vaccination in certain captive birds and breeds at risk 

Although other captive birds and breeds at risk fall outside the immediate scope of this Taskforce, future work should consider the potential for vaccination in captive breeding populations of species of conservation concern and recognised breeds at risk.  

Leverage international research and collaborate with research institutions 

The UK should continue to monitor and engage with scientific research conducted by leading institutions such as EFSA, which are actively evaluating vaccine efficacy and surveillance strategies. Aligning with this work will help ensure that UK policy remains evidence-based and internationally coherent. 

Monitor and evaluate emerging vaccine technologies 

Several novel vaccines are currently in development, including those based on mRNA and other advanced platforms. While their efficacy and practical application remain uncertain, they may offer new options in the near future. The UK should maintain close oversight of these developments and be prepared to evaluate and adopt new technologies as appropriate.

Glossary of terms

Term Definition
Adjuvant A substance added to vaccines to enhance the body’s immune response to the provided antigen  
Antibody A protein produced by the immune system in response to the presence of a foreign substance (antigen). Antibodies specifically recognize and bind to antigens, helping to neutralize or eliminate them.  
Antigen A molecule or molecular structure that triggers an immune response, especially the production of antibodies  
AIPZ Avian influenza prevention zone (a legally mandated area established to mitigate the spread of avian influenza among poultry and other captive birds)  
Avian influenza (AI) Means a viral infection of poultry or other captive birds caused by any influenza A virus. Avian influenza viruses are subtyped according to surface proteins – haemagglutinin (HA) and Neuraminidase (NA). For wild birds there are 16 different HA types and 9 different NA types. As these viruses have 8 segments of RNA as their genome, wherever coinfection occurs there is a possibility that new viruses with a new constellation of genetic material will emerge and this gives rise to the subtype diversity seen (e.g., H5N1, H7N7, H7N9 etc). Notifiable forms of avian influenza include the subtypes containing the  H5 or H7 HA gene or those with an intravenous pathogenicity index in six-week old chickens that is greater than 1.2.  
Baculovirus An insect-specific virus used in biotechnology to produce recombinant proteins, including vaccine components, in insect cells   
Cell mediated immunity A type of immune response that involves T cells attacking infected or abnormal cells directly, rather than using antibodies   
Challenge study A type of experiment where vaccinated animals are deliberately exposed to a pathogen to test vaccine efficacy  
Cytokines Proteins that help cells communicate during immune responses, controlling inflammation and directing immune cell activity  
DNA vaccines A vaccine type that deliver genetic instructions via plasmids that must enter the cell nucleus, where they are transcribed into mRNA to produce antigens, offering stability and easier storage.   
DIVA compatibility Differentiating Infected from Vaccinated Animals —a strategy using vaccines, that enable, with concurrent use of companion diagnostics, the differentiation between naturally infected and vaccinated animals based on serological responses   
ELISA tests Enzyme-Linked Immunosorbent Assays—used to detect antibodies or antigens in a sample, commonly used in veterinary diagnostics   
Epidemiological unit A group of animals with a defined disease risk, used in disease surveillance   
Epizootic disease A disease that appears as new cases in a given animal population, during a given period, at a rate that substantially exceeds what is expected  
Haemagglutinin (HA) protein A surface protein on influenza viruses that enables the virus to bind to and enter host cells. It plays a key role in infectivity and is a major target for immune responses and vaccines   
Heterologous When used to describe vaccination regimens it applies to applying a booster vaccine that is different to the vaccine used to prime the immune system   
High pathogenicity avian influenza virus  (a) influenza A virus of the subtype H5 or H7 with genome sequences containing multiple basic amino acids at the cleavage site of the haemagglutinin (HA) gene similar to that observed for other high pathogenicity avian influenza viruses, indicating that the haemagglutinin protein can be cleaved by a host ubiquitous protease; or (b) influenza A virus with an intravenous pathogenicity index in six-week-old chickens greater than 1.2   
Homologous When applied to describing vaccination regimens it refers to using the same vaccine for both the priming and the booster vaccination   
HVT-based vaccine A vaccine using Herpesvirus of Turkeys (HVT) used as a vector to deliver antigens from other pathogens   
Humoral immunity A part of the immune system that uses antibodies produced by B cells to identify and neutralize pathogens like bacteria and viruses in body fluids   
Maternally derived antibodies Transfer of protective antibodies from mothers to offspring   
Net Present Value (NPV) The sum of all benefits, less all costs, discounted to their present value   
Notifiable disease A disease that must be reported to government authorities upon diagnosis due to its potential impact on animal or public health   
Official veterinarian (OV) Designated by the competent authority to carry out official controls and other official activities related to animal health  
Polymerase Chain Reaction (PCR) A laboratory technique used to detect the presence of specific genetic material from pathogens such as avian influenza viruses  
Plasmids Circular DNA molecules used in genetic engineering, including DNA vaccines  
Prime-boost strategy A vaccination approach where an initial dose (prime) is followed by one or more booster doses to enhance immunity   
Replication competent Refers to a virus or vector that retains the ability to replicate within host cells   
RNA (Ribonucleic Acid) A molecule that carries genetic instructions from DNA to help produce proteins. It plays a key role in gene expression and some vaccines   
RNA vaccines RNA vaccines deliver mRNA directly to the cytoplasm for immediate antigen production, acting faster but requiring ultra-cold storage due to their lower stability   
Self-amplifying RNA A type of RNA vaccine that replicates itself inside cells, potentially requiring lower doses   
Serological Pertaining to the detection of antibodies or antigens in blood serum, often used in disease diagnosis and surveillance   
Future discount rate Referred to in the Green Book as the Social Time Preference Rate (STPR), this is an estimate of the value people place on future welfare relative to their welfare today. In general people would prefer £1 to £1 in a year’s time and so we account for this preference in the using the discount rate   
Switching value analysis Switching values represent the extent to which the present value benefits or present value costs would need to increase or decrease for the VfM Category of the proposal to change   
Vaccine marketing authorisation Regulatory approval for a vaccine to be sold and used in a specific market   
Virus shedding Refers to the release of virus particles from an infected host, which can lead to transmission. Due to technical difficulties in isolating live viruses from experimental samples, detection of viral RNA (vRNA) is often used as an indicator that viral material is being excreted  

Glossary of acronyms

Acronym Definition
ACDP Advisory Committee on Dangerous Pathogens   
AHA Animal Health Act   
AI Avian influenza   
AIV Avian influenza virus   
APHA Animal and Plant Health Agency   
BCR Benefit-cost ratio   
BEIC British Egg Industry Council   
BI Boehringer Ingelheim  
BPC British Poultry Council   
DAERA Department of Agriculture, Environment and Rural Affairs   
DIVA Differentiating infected from vaccinated animals   
DM Diagnostic manual   
EFSA European Food Safety Authority   
ELISA Enzyme-Linked Immunosorbent Assay   
EVP Emergency Vaccination Plan   
FCI Food Chain Information   
FSA Food Standards Agency  
FSS Food Standards Scotland   
GFA Game Farmers Association   
HA Haemagglutinin   
HMT His Majesty’s Treasury   
HPAI Highly pathogenic avian influenza   
HPAIV Highly pathogenic avian influenza virus   
HVT Herpesvirus of Turkeys   
IBD Infectious bursal disease   
INAB Irish National Accreditation Board   
IPCD Implementation Period Completion Day   
LPAI Low pathogenicity avian influenza   
MD Marek’s disease  
NA Neuraminidase   
ND Newcastle disease   
NPV Net present value   
NRL National Reference Laboratory   
OCR Official Control Regulations   
OL Official Laboratory   
OV Official veterinarian   
PCR Polymerase chain reaction   
PMA Provisional Marketing Authorisation   
POAO Products of animal origin   
PVP Preventive Vaccination Plan   
RCVS Royal College of Veterinary Surgeons   
RG Reverse Genetics   
SAPO Specified Animal Pathogens Order   
SIC Special Import Certificate   
SPC Summary of product characteristics   
SPS Sanitary and Phytosanitary   
STPR Social Time Preference Rate   
UKAMM UK Agricultural Market Model   
UKAS United Kingdom Accreditation Service   
VMD Veterinary Medicines Directorate   
VMP Veterinary medicinal product   
VMR Veterinary Medicines Regulations   
WOAH World Organisation for Animal Health  
  1. “Cull plus vaccination”—a strategy adopted in China for highly pathogenic avian influenza control 

  2. Sok J, Fischer EAJ. Farmers’ heterogeneous motives, voluntary vaccination and disease spread: an agent-based model. Eur Rev Agric Econ. 2020;47(3):1201–1222 

  3. APHA laboratory test prices - GOV.UK 

  4. The Green Book, HM Treasury, 2022 

  5. APHA Scientific Tests – laboratory test prices