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Inside the UK’s animal testing licensing system

Shocking footage has revealed the suffering of animals harmed by toxicity testing in UK laboratories – tests that are regulated and licensed by the Home Office.

Animal testing in the UK is not governed by the Animal Welfare Act 2006, but by a different law: the Animals (Scientific Procedures) Act, also known as ASPA. This law is what we call ‘permissive’ meaning that it allows the infliction of “pain, suffering, distress and lasting harm” on living animals.  

In practice, this means that a beagle, rabbit or any other animal in a laboratory can be treated in ways that would be illegal elsewhere. 

A closer look at the licensing system reveals serious gaps in how harm is assessed and approved.

To carry out animal testing in the UK, three types of licenses are required: 

  • Personal license for the individual conducting the experiment 
  • Project license for the experiment itself 
  • Establishment license for where the experiment will be conducted 

Breeders or ‘suppliers’ of animals to laboratories must also hold an establishment license.  

Licenses are issued by the Home Office through their Animals in Science Regulation Unit (ASRU). ASRU inspectors: 

  • Review applications
  • Request revisions or clarifications 
  • Approve or reject licenses 
  • Conduct audits of facilities 

Once approved, these licences legally authorise the use of animals in science for up to 5 years, before needing to be renewed. 

Inspectors are supposed to carry out a harm-benefit analysis (HBA). This process weighs the harm to animals against the expected benefits of the experiment. 

A Home Office advice note explains that licenses should only be granted once harms, benefits, and likelihood of success have been fully assessed, including consideration of the “3Rs” (replacing, reducing or refining the use of animals).  

While the HBA has been described as the cornerstone of animal research regulation, others have found that regulation failed to safeguard animals from severe suffering or ensure that only beneficial, rigorous research was conducted.  

Service licenses – also known as “multiple generic” licenses – are among the most controversial. The tests shown in shocking new footage is likely to have been conducted under this type of license.  

Unlike standard project licenses, service licenses: 

  • Cover broad programmes of work rather than specific experiments
  • Do not require the same level of information to be provided to inspectors, for example the exact substance that is being tested 

This raises serious concerns. If the details of what is being tested are not known, then it is impossible to accurately assess either the harms or the benefits. If a HBA cannot be completed, then licenses should not be granted. 

In 2019, we voiced our concerns to the Home Office, who confirmed that a harm-benefit analysis is “not done on individual experiments” and that the names of individual substances may not be known when a project is evaluated. 

Clearly, this undermines the very foundation of any harm-benefit analysis and leaves animals vulnerable to immense suffering. 

A 2024 report by the Animals in Science Committee examined the use of primates under service licenses and found: 

  • These licenses account for the majority of primate use in UK laboratories 
  • Many lacked clear explanations of why primates were ‘necessary’ 
  • Details about re-using animals were often missing 
  • There was a lack of scrutiny around the scientific value of substances being tested 

The report concluded that: 

  • There are significant gaps in regulatory oversight 
  • It is unclear how a meaningful harm-benefit analysis (HBA) can be conducted under these licenses 

This is especially concerning given that primates are considered “specially protected” by law – if primates are vulnerable to regulatory failings, then what about less ‘popular’, less protected animals like rats and mice? 

This cruelty is regulated by the Home Office, who issue licenses for animal testing.

The UK’s licensing system is presented as robust and ethical; animal testing framed as a “necessary evil”. But the use of service licenses reveals the system is failing. It’s a system where approvals can be granted without full transparency of what ordeals animals will face – or what benefits, if any, will result.  

If harm cannot be properly measured and benefits cannot be clearly defined, the ethical justification of animal testing falls apart. 

Tell your MP it's time to end animal testing

We're calling on the Government to suspend all new tests, conduct a full review of existing licenses, and deliver on its promise to end animal testing.

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