The Veterinary Surgeons Act 1966 (VSA) reforms are being framed by the Royal College of Veterinary Surgeons as modernization, and it seems that some proponents of complementary and alternative medicine (CAM) are welcoming the proposals in good faith. I would agree that there does need to be some regulation of CAM in that people can seemingly do a weekend course, get a certificate, and set themselves up as a practitioner all too easily. I regularly see bad advice being posted on social media with no consequences should somebody follow it. It doesn’t help the animals, the owners or those of us who are CAM veterinarians.
The problem is that this trust in the what the RCVS are saying is totally misplaced. There is plenty of evidence already that indicate which direction the RCVS has been and is travelling in respect to CAM, not least the revised statement on CAM they issued in November 2017. For the same people who protested against that to think the RCVS is now intending to embrace CAM with open arms is incredibly naïve in my opinion and flies in the face of all the evidence as I shall set out below.
The subtext to the VSA revision is a regulatory consolidation that could severely restrict CAM within veterinary practice under the guise of “evidence-based reform.”
An analysis of what is proposed, taking into account the RCVS’s consistent stance that CAM lacks evidence-based validity and the effect that the proposed shift from a criminal to a civil standard in disciplinary proceedings, has potentially serious implications for the professional freedom of MsRCVS and paraprofessionals.
Intended changes to the Veterinary Surgeons Act 1966
The VSA reform is set to redefine the structure of veterinary regulation in four broad areas:
1. Creation of a unified veterinary team
The reform seeks to legally recognize the “wider veterinary team” encompassing veterinary nurses, paraprofessionals, and certain non-veterinary specialists. On the face of it, this sounds like the recognition for CAM that CAM practitioners have sought for a long time. Jumping into bed with the RCVS is fraught with danger and once done, it will be far more difficult, if not impossible, to separate away than to get a divorce!
Paraprofessionals will likely be legally required to register with the RCVS under the new framework in order to work with animals in the UK, granting the RCVS control over their scope of practice. The concept of “reserved activities” would replace the original Act’s blanket ban on non-vets treating animals without veterinary permission with defined permissions for specific procedures.
2. Formalization of regulatory powers
The reforms would significantly expand the RCVS’s statutory powers, giving it explicit authority to define what constitutes “veterinary work”, decide which activities may be delegated and by whom, and regulate “fitness to practise” and impose sanctions without needing criminal-level proof. It begs the question as to who decides on the definition of “fitness to practise”, and if the RCVS, how can they determine that in modalities they have no experience in or knowledge of?
3. Reclassification of veterinary misconduct
In terms of taking disciplinary action, the RCVS would move from a criminal (“beyond reasonable doubt”) to a civil standard (“balance of probabilities”) in disciplinary matters which is a much lower threshold of proof which from their perspective would be much easier to prove.
“Failure to adhere to evidence-based principles” could be interpreted as professional misconduct, particularly for those practicing CAM.
4. CAM clarification and restriction
The RCVS continues to maintain that most CAM lacks sufficient evidence of efficacy and has repeatedly issued position statements asserting that only therapies supported by “robust scientific evidence” are acceptable under professional conduct. Given their refusal to accept any scientific evidence in support of homeopathy, probably the most accepted of CAM modalities, it doesn’t bode well for the rest.
The revised Act is likely to codify this stance, empowering the RCVS to restrict or prohibit CAM modalities, demand justification rooted in institutional science rather than clinical outcome or owner consent, and potentially exclude unqualified CAM paraprofessionals from legal practice altogether.
For MsRCVS who practise CAM
There are a number of implications for vets who practice CAM, with the highest implications for those who use CAM treatment exclusively, although we use both conventional and CAM approaches to assess a patient.
1. Erosion of clinical autonomy
The proposed shift in the disciplinary standard from “beyond reasonable doubt” to “balance of probabilities” means that even minor deviations from orthodox practice could result in disciplinary action.
A vet offering acupuncture, homeopathy, herbs or whatever, even with client consent, could be accused of acting “outside the evidence base” and sanctioned more easily than before.
In effect, clinical judgement may be side-lined by compliance with orthodoxy and guideline/protocol medicine which is largely how medical doctors now work. We only have to see how some excellent doctors such as Dr Sarah Myhill are constantly under threat and attack from the GMC (46 times to date) to see the direction the RCVS would seek to follow. They’re looking to bring the RCVS in line with the GMC regarding on the “balance of probability”, so why wouldn’t they follow the GMC in terms of how they implement it?!
2. De facto suppression of CAM
The ongoing position that CAM is “not evidence-based” essentially predetermines that its practice is non-compliant with professional standards.
The RCVS could use the Act’s expanded authority to redefine “acceptable practice” such that CAM treatments become legally or disciplinarily untenable, thereby functionally banning them without explicitly outlawing them.
Practitioners could face sanctions and/or reputational damage simply for offering integrative options.
3. Administrative overreach
The centralization of authority under the RCVS means that MsRCVS are answerable to a self-policing institution with no external oversight, operating on subjective determinations of what qualifies as “evidence.” The fact that the RCVS knowingly and wilfully puts itself above the law by refusing to recognise the obligation of veterinarians to prescribe CAM in preference to allopathic treatments on organic farms is an indication that the RCVS already engages in administrative overreach.
The proposed VSA reforms place all CAM veterinarians under chronic threat of regulatory intimidation which discourages innovation or individualised medicine. I can envisage a situation where a vet recommends euthanasia over CAM to protect themselves rather than what is best for the patient. That is not acceptable.
4. Insurance
The Veterinary Defence Society (VDS), as the dominant professional indemnity insurer for the UK veterinary profession, already plays a quasi‑regulatory role by shaping what forms of practice it considers “defensible.” Its position closely shadows the RCVS stance on what is deemed “evidence‑based.” So even before the proposed reforms to the VSA, there has already been a kind of soft suppression of CAM through insurance policy and risk‑management mechanisms for a number of years.
The VDS makes it explicitly clear that cover is contingent upon the practitioner acting “in accordance with accepted professional standards” - a phrase it interprets largely by reference to the RCVS Code of Professional Conduct.
When the RCVS states that CAM “lacks sufficient evidence of efficacy,” the VDS follows suit. This means a vet who undertakes CAM therapies does so at their own professional risk unless insured separately to cover their CAM work, although there is nothing to stop other insurers follows the VDS lead which would make it impossible to be insured for CAM. With vet fees so high, insurers will look to whatever means possible to reduce their risk.
Although the VDS is technically a mutual insurer, not a statutory body, its discretionary power over pay-outs has the same regulatory effect as a legal prohibition thereby making it de facto regulation by underwriting. The consequences of disciplinary action for using a CAM therapy, may be that you find yourself uninsured and potentially uninsurable. If you’re uninsured, you can’t lawfully practise. Insurance limitations could effectively establish an economic ban on non‑orthodox approaches.
The VDS has historically raised red flags about:
Homeopathy, herbalism, and certain forms of acupuncture.
Chiropractic or osteopathic manipulation performed by untrained individuals.
Ozone therapy, MMS/ClO₂, and unlicensed nutraceutical regimens without documented justification.
Even therapies such as herbal, phototherapy, nutritional detoxification, etc.) may fall into this “no cover” category if defended purely on clinical experience rather than peer‑reviewed trials, or practitioners may be limited to only using CAM alongside pharmaceuticals which rather negates the reason why most people choose CAM. It also compromises pharma medications that have never been trialled in combination with CAM and potentially creates an adverse reaction as a direct result of the actions of the RCVS. In those situations, the adverse reaction would be blamed entirely on the CAM regardless of what part it actually played.
Under the proposed civil standard the RCVS would be able to discipline a practitioner for CAM practice merely on the likelihood that, in their view, it wasn’t evidence-based. Once sanctioned, the VDS could refuse defence or pay-out because the disciplinary finding itself becomes “proof” of misconduct by civil standard.
The VSA reform and insurance policy to follow suit synergizes to constrict the legal and financial defensibility of CAM practice entirely.
Essentially, after reform, a single adverse finding, even on shaky grounds, could trigger automatic insurance denial, creating career-ending consequences for any MsRCVS who steps outside the orthodoxy.
The implications of this create a feedback loop of conformity and a self-reinforcing system. It’s a form of institutional hegemony by economic leverage, not open scientific dialogue.
Final analysis for MsRCVS
The current situation is that CAM vets already face economic coercion via insurance constraints unless insured by a company that does not adopt the restrictions that the VDS have.
After the reform: the legal and financial levers would become fully synchronised ensuring that only RCVS-approved, pharmaceutical-aligned, “evidence-based” practices remain viable unless there are insurers who are prepared to provide adequate insurance to practice, but no doubt at a premium, and unlikely to cover disciplinary procedures.
What’s presented as raising standards is in reality a bureaucratic filter that privileges institutional consensus over individual clinical experience. It rewards conformity and punishes curiosity - the antithesis of both science and animal welfare.
For paraprofessionals and lay CAM practitioners
1. Likely exclusion under regulatory capture
Currently tolerated non-vet practitioners such as equine massage therapists, chiropractors, and herbalists could lose their informal right to practise if the RCVS extends its statutory reach unless they embrace the regulatory requirements foisted upon them.
if the RCVS reforms proceed along their current trajectory, RAMP (Register of Animal Musculoskeletal Practitioners) and similar entities (such as AHPR and IRVAP) stand directly in the crosshairs, because they would either be absorbed, subordinated, or co-opted into the RCVS regulatory ecosystem. Bodyworkers who may already have joined and subsequently rejected joining RAMP could be forced to join and pay for the privilege. Those who do bodywork but are not recognised by RAMP and may not be allowed to join would be left out in the cold and unable to practice legally unless their training body go through whatever process would be required to gain acceptance and recognition.
All paraprofessionals would be required to hold registration, pay fees, and conform to RCVS-approved training frameworks - systems designed to ensure compliance with conventional methodology.
2. Economic and structural displacement
Many independent CAM providers, who are often self-employed, could be priced or licensed out of the market altogether.
Corporate and institutionally aligned veterinary groups would gain a monopoly on all therapeutic activity, and potentially even non-invasive ones like hydrotherapy.
3. Legal vulnerability
Once the RCVS controls the definitions of both “evidence-based” and “fit to practise,” paraprofessionals who operate outside that scope — even competently and harmlessly — become liable to prosecution or sanction.
Even anecdotal complaints or differences in clinical approach could be enough to justify sanction if the RCVS believes that CAM lacks objective evidence. This transforms the disciplinary system from protective to punitive, particularly toward those who do not conform to establishment modalities.
Broader implications of the undeclared CAM agenda
The RCVS presents its stance as purely methodological (“protecting the public through evidence-based medicine”), but in practice this would function as an ideological filter whereby only interventions developed or validated within the mainstream scientific-industrial establishment would qualify as authorised.
This aligns closely with the interests of pharmaceutical sponsors, corporate clinics, and academic partners, who have a financial and reputational interest in maintaining mainstream control of veterinary practice.
CAM therapies, being low-margin, often owner-driven, and outside IP protection, pose little commercial benefit to these institutions.
The reform thereby risks codifying institutional bias into law, effectively prohibiting non-industrial, non-pharmaceutical approaches to animal care.
Conclusion
The reforms to the Veterinary Surgeons Act 1966, while publicly justified as modernisation and safety enhancement, carry a powerful undercurrent: the consolidation of regulatory authority in the RCVS and the suppression of medical plurality.
Through embedding “evidence-based” criteria that systematically exclude CAM from legitimacy, introducing the civil burden of proof to discipline practitioners by mere probability, and extending institutional control over paraprofessionals who were previously unregulated, or self-regulated, the reform risks creating a closed veterinary system where innovation, holistic care, and independent thought are subordinated to bureaucratic orthodoxy without clinical freedom.
Veterinarians would cease to be professionals and become mere technicians with diagnostics replaced by AI and vets used solely for animal handling and administering medications.
There is a DEFRA public consultation that I encourage all UK animal owners in favour of CAM to submit their views on the proposed VSA reform to.
https://consult.defra.gov.uk/reform-of-the-veterinary-surgeons-act/consultation/
