The Institute of Licensing (IoL) has submitted a comprehensive response to DAERA’s Consultation on Proposed Animal Welfare Policy Reforms in Northern Ireland, strongly supporting the direction of travel across all four policy areas and calling for clearer structures, stronger safeguards and properly resourced enforcement.
The consultation covers the regulation of rescue and rehoming organisations, dog licence fee increases, a ban on aversive training devices, strengthened microchipping requirements for dogs, and a call for evidence on mandatory microchipping of cats.
Support for licensing rescue and rehoming organisations
The IoL “fully supports proposals to bring rescue and rehoming organisations into scope for licensing purposes”, noting that similar reforms are already in place or progressing in Scotland, England and Wales. The response highlights the need for minimum standards, competent staffing, and appropriate accommodation, particularly as many animals—often including pregnant bitches—require long‑term care.
The IoL recommends:
Including cats within the “five or more” licensing threshold.
Ensuring DAERA, not district councils, acts as the licensing authority to maintain consistency with existing NI animal licensing functions.
Amending several proposed licence conditions to clarify responsibilities, strengthen welfare safeguards and ensure proper training, hygiene and enrichment standards.
The Institute also stresses that any new licensing regime must be properly funded, with fees and potential new burdens funding enabling effective inspection and enforcement.
Inflationary increase to dog licence fees
The IoL supports the proposed inflation‑linked increase, describing the fees as “minimal compared with the costs of dog ownership”. It recommends introducing an automatic annual index‑linked uplift to avoid long periods without review.
However, the response warns that:
High levels of concessionary or free licences limit councils’ ability to recover costs.
Any additional responsibilities—such as licensing rescue centres—must not be placed on councils without appropriate funding, particularly given the withdrawal of DAERA’s annual contribution to the Animal Welfare Service in 2023.
Ban on aversive training devices
The IoL strongly endorses banning electric shock collars, choke collars and prong collars. Citing evidence from the British Veterinary Association that such devices cause “stress, pain and fear”, the Institute argues there is no justification for their use when humane, reward‑based training is effective.
The response notes that bans already exist or are progressing in Wales, England and other jurisdictions, and that Northern Ireland should remain aligned with wider UK and EU standards.
Strengthening microchipping requirements for dogs
The IoL supports:
Requiring owners to update microchip details within a set timeframe (e.g., 14 days).
Mandatory breeder registration on microchip databases.
Microchipping before eight weeks of age, with allowances for illness or other mitigating circumstances.
These measures are seen as essential for accountability, traceability and responsible ownership.
Mandatory microchipping of cats – call for evidence
The IoL highlights significant benefits, including improved reunification, theft prevention, and clarity for local authorities and charities dealing with strays. It notes that microchipping is already mandatory in England.
Challenges identified include:
Difficulty enforcing compliance due to cats’ roaming behaviour.
Fragmentation across more than 20 microchip databases.
Resource pressures on local authorities.
Public awareness gaps and cost barriers for some owners.
The IoL recommends exploring a unified database, ensuring adequate enforcement resources, and recognising that cats should be chipped later than dogs (around 20 weeks) due to developmental differences. It also argues that microchipping should only be carried out by veterinary professionals.
