THE IRISH BLUE CROSS
Submission on the General Scheme of the
Dog Breeding Establishments (Amendment) Bill 2026
1. Introduction
The Irish Blue Cross welcomes the Government’s commitment to improving welfare standards for dogs kept in commercial dog breeding establishments (DBEs). We support the overall direction of the General Scheme and, in particular, proposals intended to strengthen breeding controls, staffing, traceability, veterinary treatment and enforcement.
The Irish Blue Cross works at the frontline of animal welfare and regularly sees the broad consequences of poor breeding practices which not only impacts the dogs themselves but also on their owners and our teams who must step in and treat them. Our veterinary teams encounter dogs affected by congenital defects, inherited diseases, chronic orthopaedic conditions, neurological disorders and behavioural problems associated with poor breeding and welfare practices, including inadequate early socialisation.
Families purchasing puppies from DBEs reasonably expect that those puppies have been bred and reared in conditions that support their physical and behavioural welfare. The Irish Blue Cross is concerned that some of the proposed requirements may be difficult to verify in practice, unless they are supported by clear standards, reliable records, centralised traceability and consistent inspection and enforcement.
Our recommendations therefore focus on ensuring that welfare requirements are not only stated in legislation but are measurable, traceable and enforceable.
2. Key Recommendations
- Redefine DBEs so that the legislation cannot be avoided by operating below the current numerical threshold.
- Introduce a cap of 30 breeding dogs per DBE.
- Provide for a staff-to-dog ratio of 1:10 covering male dogs, female dogs and puppies, with appropriate contingency for staff absence.
- Limit a breeding female to four litters over her lifetime, with no extension beyond four litters.
- Define ‘breeding’ clearly and apply the relevant controls to male stud dogs as well as female dogs.
- Require a minimum age of 24 months before breeding and a maximum breeding age of seven years, without an extension by veterinary certificate.
- Prohibit further breeding after one Caesarean section.
- Make parentage and mating information centrally traceable through microchip records and a national database.
- Set clear, measurable requirements for socialisation, habituation and exercise, supported by records and inspection evidence.
- Provide prospective purchasers with relevant veterinary history and reliable information about a puppy’s origin and parentage.
- Require the biological mother to be shown interacting with the puppy.
- Establish a centralised register of puppy sales and a national DBE register that is publicly accessible online and regularly updated.
- Standardise inspections requiring at least two inspectors at each inspection, centrally record inspection findings and make the findings publicly available.
- Increase minimum penalties as well as maximum penalties so that enforcement has a meaningful deterrent effect.
3. Recommendations
3.1 Definition of a Dog Breeding Establishment
The General Scheme does not change the existing DBE definition. The Irish Blue Cross recommends: “Premises which dogs (male and female) are kept, not less than 3 of which are: (a) more than 4 months old, and (b) capable of being used for breeding purposes.” A revised threshold would reduce the scope for establishments to fall outside the regulatory framework because of the number of dogs kept.
3.2 Cap of 30 breeding dogs
Having a smaller number of dogs on a Dog Breeding Establishment (DBE) licence does not guarantee that the dogs will receive a higher standard of care, attention, or socialisation. The quality of care depends on how the establishment is managed, the experience and commitment of the owner and staff, and the amount of time and resources devoted to the dogs.
However, a smaller number of dogs may provide some practical benefits. It can mean that the owner is less reliant on the dogs as their sole source of income and may therefore be better placed to prioritise individual care rather than operating at a higher volume. A smaller population can also make it easier to provide individual attention and appropriate socialisation, although this should not be assumed solely from the number of dogs.
There may also be potential health benefits to maintaining a smaller dog population. Scientific evidence indicates that high-density housing, overcrowding, close contact between dogs and increased animal turnover can increase opportunities for the transmission of infectious diseases, particularly respiratory infections. Lower numbers may therefore reduce the level of crowding and contact between animals and make effective hygiene, cleaning and disease-control measures easier to maintain. However, the actual risk of disease will also depend on factors such as ventilation, hygiene, vaccination, quarantine and biosecurity practices.
A smaller number of dogs may also contribute to a quieter environment, with less cumulative barking and noise. This can be beneficial for the dogs’ welfare, particularly where dogs are housed in close proximity to one another. However, the level of noise will ultimately depend on the layout and management of the establishment, as well as the individual dogs.
The number of dogs should therefore be considered as one factor when assessing an establishment. A lower number should not be treated as a guarantee of better care or socialisation, but it can provide conditions that make individualised care, effective disease control and a quieter environment more achievable.
3.3 Staffing ratio
The General Scheme proposes a minimum of one full-time equivalent staff member per 20 breeding bitches. The Irish Blue Cross recommends a ratio of one staff member to 10 dogs, covering male dogs, and female dogs. The ratio should be enforceable and should include contingency arrangements for sickness, annual leave and other staff absences. The introduction of the staffing ratio should not be subject to further delay. Human interaction is imperative to the socialisation and development of dogs intended to become safe family pets.
Given that staff would be responsible for feeding and exercising each dog, cleaning and maintaining their environment, and meeting their wider welfare needs, a staff-to-dog ratio of 1:20 raises significant concerns about the ability to provide adequate socialisation and habituation.
This concern is particularly acute where dogs are being bred, as the number of animals requiring care will increase when puppies are present. Consequently, a ratio of one staff member to 20 dogs could result in a substantially higher number of animals being dependent on each staff member, making it difficult to provide sufficient individual attention, positive human interaction, exercise, socialisation and habituation.
3.4 Lifetime number of litters
The General Scheme proposes a maximum of six litters, with the possibility of extending the limit from four to six on veterinary certification. The Irish Blue Cross recommends a maximum of four litters with no option to extend. If any extension beyond four litters is retained, the legislation should include an objective veterinary health assessment tool and clear criteria for suitability for breeding.
3.5 Definition of breeding
The legislation should define ‘breeding’ so that there is no ambiguity as to whether it refers to conception, pregnancy or whelping. The definition should also apply to male stud dogs.
3.6 Breeding frequency
The General Scheme proposes a maximum of one litter per year. The Irish Blue Cross recommends a defined recovery period of between 12 and 18 months to allow recovery from pregnancy and restoration to full health. Breeding frequency should be recorded and centrally traceable. Each puppy’s record should include the microchip numbers of its biological parents.
3.7 Minimum breeding age
The General Scheme proposes no breeding under 12 months. The Irish Blue Cross considers 12 months too young because a dog is not fully mature at that age. We recommend a minimum breeding age of 24 months. This provides a single clear standard across breeds rather than requiring separate age categories for different breed sizes.
3.8 Maximum breeding age
The General Scheme proposes no breeding above eight years, with an extension possible by veterinary certification. The Irish Blue Cross recommends no breeding above seven years and does not recommend that this limit be extendable by veterinary certification.
3.9 Caesarean sections
The General Scheme proposes no breeding after two Caesarean sections. The Irish Blue Cross strongly recommends that a dog should not be bred after one Caesarean section, given the physical risks associated with repeat Caesarean sections. Any veterinary certification framework should reflect this restriction.
3.10 Inbreeding and parentage
The proposed explicit prohibition on inbreeding should be supported by a reliable system for recording biological parentage. The biological parents should be recorded against each puppy’s microchip record. A central database should record matings and puppies delivered and should allow proposed matings to be assessed against at least three generations of recorded ancestry and a yes/no response generated.
3.11 Socialisation and habituation
The General Scheme proposes a legal duty to adequately socialise and habituate dogs. The Irish Blue Cross recommends that the legal requirement be tied to clearly specified standards, including the Collated DBE Standards (provided to the Dog Control Stakeholder Group), and supported by records and appropriate video evidence. Compliance should be monitored and enforced through inspections. Relevant information should also be made available to prospective purchasers so they can make informed decisions.
3.12 Exercise
The requirement to provide adequate exercise should similarly be linked to clear standards, supported by records and appropriate video evidence, and subject to inspection and enforcement. Relevant information should be available to prospective purchasers.
3.13 Veterinary treatment and veterinary history
The General Scheme proposes an explicit legal requirement for veterinary treatment. The Irish Blue Cross recommends that prospective purchasers should also have access to relevant veterinary information before purchasing a dog and that the purchaser should receive the dog’s full veterinary history on transfer.
3.14 Verification of the biological mother
The General Scheme provides that a dog under six months should not be shown to a prospective purchaser unless the biological mother is present and also shown, subject to specified welfare exceptions. The Irish Blue Cross recommends that the puppy should be shown interacting with its biological mother, unless there is a welfare risk to either dam or puppy. Simply presenting an adult dog as the mother does not, in itself, provide a purchaser with a reliable means of verifying the relationship. If the mother is deceased, this should be recorded on the central microchipping database. The central database should also include photographs of each dog alongside its microchip number so that parentage can be more readily verified.
3.15 Notification and centralised recording of sales
The proposed criminal offence for failure to notify a local authority of a sale or transfer is welcome. However, the Irish Blue Cross recommends a centralised register of puppy sales to support traceability and enforcement.
3.16 Third-party sales and definition of premises
The restrictions on third-party sales should be strengthened. The term ‘premises’ should be clearly defined, and the Eircode of the location where each puppy was born should be recorded against the puppy’s microchip. The Irish Blue Cross does not recommend exceptions allowing third-party sales on the basis of veterinary approval.
3.17 National DBE register
The Irish Blue Cross strongly recommends a national register rather than local registers only. Where the General Scheme provides that the Minister ‘may’ direct a local authority to publish its DBE register in a particular manner, this should be changed to ‘must’. The register should be available online for public viewing and updated monthly.
3.18 Pre-registration inspection
The requirement for a mandatory pre-registration inspection is welcomed. The Irish Blue Cross recommends that this inspection should form part of a standardised national inspection framework.
3.19 Inspections and inspectorate
The frequency and standards for DBE inspections should be set out clearly. The Irish Blue Cross recommends that at least two inspectors attend every DBE inspection for health and safety reasons and to reduce the risk of intimidation. At least one inspector should, where practicable, be independent of the local authority in which the DBE is located. The number of inspectors should be proportionate to the size of the establishment so that inspections can be sufficiently thorough. Inspection findings should be digitally recorded in a centralised system, with appropriate information made publicly available to support transparency and informed purchasing decisions.
3.20 Penalties
The proposed increase in the maximum penalty from €100,000 to €250,000 is welcome. However, the Irish Blue Cross recommends that minimum penalties should also be increased so that the penalty framework provides a meaningful deterrent rather than relying principally on the maximum available fine.
4. Conclusion
The Irish Blue Cross welcomes the proposed strengthening of the regulatory framework for dog breeding establishments. The proposed changes provide an important opportunity to improve the welfare of breeding dogs and puppies and to strengthen accountability across the sector.
However, welfare standards will only deliver their intended outcomes if they can be verified, recorded, traced and enforced. The Irish Blue Cross therefore recommends that the final legislation place equal emphasis on enforceability, transparency and measurable standards.
We particularly emphasise the need for stronger breeding limits, earlier minimum breeding-age controls, restrictions following Caesarean section, robust parentage and sales traceability, clear requirements for socialisation and exercise, access to veterinary information, a national public register and a standardised, adequately resourced inspection framework.
5. Summary of Recommendations
- Redefine a DBE so that the legislation cannot be avoided by operating below the current numerical threshold.
- Limit the number of breeding dogs to 30 per DBE.
- Provide for a staff-to-dog ratio of 1:10 covering male dogs, female dogs and puppies, with appropriate contingency for staff absence.
- Limit a breeding female to four litters over her lifetime, with no extension beyond four litters.
- Define ‘breeding’ clearly and apply the relevant controls to male stud dogs as well as female dogs.
- Require a minimum age of 24 months before breeding and a maximum breeding age of seven years, without an extension by veterinary certificate.
- Prohibit further breeding after one Caesarean section.
- Make parentage and mating information centrally traceable through microchip records and a national database.
- Set clear, measurable requirements for socialisation, habituation and exercise, supported by records and inspection evidence.
- Provide prospective purchasers with relevant veterinary history and reliable information about a puppy’s origin and parentage.
- Require the biological mother to be shown interacting with the puppy, subject to clearly defined welfare exceptions.
- Establish a centralised register of puppy sales and a national DBE register that is publicly accessible and regularly updated.
- Standardise inspections and require at least two inspectors at each inspection, centrally record inspection findings and make appropriate findings publicly available.
- Increase minimum penalties as well as maximum penalties so that enforcement has a meaningful deterrent effect.