Complaints and redress in veterinary services

Executive summary

Veterinary services are an essential service for the millions of households who have a treasured family pet, but there is considerable evidence that the market is not working well for consumers. High recorded levels of consumer harm and competition concerns have led to the Competition and Markets Authority conducting a market investigation.

A particular issue appears to be that consumers can find it difficult to make a complaint and seek redress when things go wrong. According to the government’s most recent economy-wide study of consumer detriment, the market has the third lowest rate of positive resolutions to detrimental experiences, with just 31% of people receiving what they asked for or more. This compares to an average positive resolution rate of 52% across all sectors.

To understand why there are problems with complaints and redress in this market, and how it could be improved, we conducted primary research with pet owners to explore their experiences. We surveyed 1,009 pet owners who have experienced some kind of problem with their vet or vet practice in the past two years. We also conducted 14 qualitative interviews with pet owners who have made a complaint, recruiting a mix of those who had complained to their practice only and those who escalated their complaint by using the Vet Client Mediation Service or contacting the Royal College of Veterinary Surgeons. 

Our findings are that:

• More than half (57%) of the c.1,000 pet owners who experienced an issue in the past two years did not make a complaint. Consumers are deterred from complaining for various reasons: many simply think they will not be successful, whilst others are concerned about how it will impact their relationship with the practice, or simply do not know how to go about complaining.
• A large minority of the pet owners we surveyed who had complained were dissatisfied with the handling and/or outcome of their complaint: 31% and 35%, respectively.
• Even if they are dissatisfied, very few pet owners escalate the complaint to mediation or the Royal College of Veterinary Surgeons, with many lacking confidence that it will be successful or simply not knowing how.
• When pet owners do want to escalate a complaint they find the current options available are often inadequate:
  • Mediation can be helpful for some, but relies on voluntary participation and cannot successfully resolve all complaints, depending on the nature and complexity of the case. Further, pet owners are sometimes unaware of the service at the time that it would be most useful.
  • The RCVS ‘raise a concern’ process has very high thresholds for investigating and progressing a complaint, leaving pet owners feeling dismissed and that the process is biased in favour of veterinary professionals.
  • Using the court system is rarely, if ever, seen as a viable option due to the associated costs and a low perceived likelihood of success.

Overall, there is strong evidence that the current complaints and redress system in the veterinary sector is insufficient. This is a cause of consumer harm and a contributory factor to high levels of consumer discontent with veterinary services.

Which? believes a range of interventions need to be made to create a fit-for-purpose enforcement and redress system for consumer rights in this sector. 

To improve the public enforcement of consumer rights and protections:

• The government needs to update the regulatory framework to allow regulation at a practice level rather than solely at individual professional level. This would better reflect the way that the modern veterinary market works, with prices and policies (including complaints) often determined by practice management and not individual professionals. Updated regulation should set out clear duties that ensure vets and veterinary practices act in consumers’ interests. 
• The government should ensure that the regulator for veterinary services is sufficiently equipped to independently enforce consumer law as it relates to the provision of veterinary services, including issues such as unfair commercial practices. The regulator needs to have appropriate expertise, powers and sanctions to incentivise compliance and allow for effective, proportionate enforcement that will drive improvements and higher standards in the market.

To support the private enforcement of consumer rights and protections:

• As part of reforms to the regulatory framework, veterinary practices should be required to have a written complaint process based on specified criteria to ensure consistency in how complaints are defined, handled and signposted. This will enable consumers to understand how to make a complaint and what to expect.  
• Given the complex nature of veterinary care and the significant expenses involved for consumers, there also needs to be a more comprehensive and mandatory alternative dispute resolution (ADR) scheme for when issues cannot be resolved at the practice level. This needs to be clearly signposted to consumers and build on the current mediation service, but it should also ensure that the scheme has the ability to investigate and adjudicate complaints, and to enforce its decisions. We therefore recommend that an ombudsman scheme be introduced to deal with complaints relating to veterinary services for pets. 

Introduction

The market for veterinary services has received considerable public scrutiny following evidence that it may not be working well for pet owners. Government research has indicated a high level of consumer harm in the market, with one in nine people who purchased vet services in 2020-21 suffering a detrimental experience at an estimated average value of £143 per incident. Which?’s research found concerns about the transparency of prices and business ownership, and fears from consumers that their pets were being over-treated. In response to concerns, the Competition and Markets Authority (CMA) opened a market investigation in 2024 exploring issues including the information and choice provided to consumers, price transparency, concentrated local markets that could lead to weakened competition and potential overpaying for treatments and medication. 

A particular issue that the CMA is exploring is the efficacy of current arrangements for pet owners to make complaints and seek redress when something goes wrong. Access to an effective complaints and redress system is a crucial aspect of a well-functioning consumer market. It can improve quality in the provision of services, encourage compliance with regulatory rules and give consumers confidence to engage in a market. However, the system does not appear to be working well in veterinary services. According to the government’s most recent study of consumer detriment in the UK economy, veterinary services has the third lowest rate of positive resolutions to detrimental experiences of any sector, with just 31% of people receiving what they asked for or more. This compares to an average positive resolution rate of 52% across all sectors. 

To better understand why there are problems with complaints and redress and how it could be improved, we have conducted mixed methods research with pet owners. The research comprised an online poll of 1,009 pet owners who had an issue with their vet in the past two years and 14 qualitative interviews with pet owners who have raised a complaint about a vet. We explore the experience of these pet owners - from choosing whether to initiate a complaint to deciding to escalate their complaint beyond practice level, and their experience of the complaints process at each step. 

Using this research, we consider the reasons why the current enforcement and redress landscape within the market is inadequately serving consumers and what a fit-for-purpose system could look like. Our recommendations focus on both improvements to the availability of private redress mechanisms and reforms to the regulatory system to ensure that vet practices are subject to adequate requirements to deal appropriately with complaints. 

The report begins with consideration of the current arrangements for complaints and redress. The next section provides a detailed methodology and then the results of both the online poll and qualitative interviews are presented. The final section discusses the findings and sets out our recommendations for change.

Current arrangements for complaints and redress

To provide context for our research, this section briefly sets out the current complaints and redress landscape in the veterinary market. This includes the current expectations of how practices should deal with complaints, as well as the options consumers have for escalating a complaint when it is not resolved at a practice level. 

Many sectors have options available to consumers, such as independent ombudsmen or some other kind of Alternative Dispute Resolution (ADR) scheme, for situations in which complaints cannot be resolved directly with a business. In veterinary services, pet owners can use a mediation service called the Vet Client Mediation Service (VCMS) or raise a concern with the Royal College of Veterinary Surgeons (RCVS), the regulator of veterinary professionals. The RCVS sets out codes of conduct for veterinary professionals - one for veterinary surgeons and one for veterinary nurses (henceforth known collectively as the Code) - and it also operates a Practice Standards Scheme, although participation by practices is voluntary. Consumers may also seek redress through the court system, although in most circumstances this is a last resort.

Complaints handling at the practice level

As with most markets, when a pet owner wishes to complain about a veterinary practice or professional, the first port of call is to complain directly to the practice itself. The largest chains of vet practices mostly have published complaints processes that give approximate timelines and set out a number of stages allowing for escalation of complaints (see examples from CVS and Medivet). There are also examples of similar processes set out online by independent practices (see examples from Millennium Vets and Ystwyth Vets). In other cases, the information published online by practices simply asks customers to contact the practice manager without information on what can be expected during the complaint process, though more detailed information may be available offline. 

The RCVS sets out some expectations of complaints procedures in its Code for veterinary professionals and its voluntary Practice Standards Scheme. The Code states that complaints should be dealt with “promptly, fully and courteously”, and the Practice Standards Scheme states that practices should have a written complaints procedure including timescales for a response. The RCVS does not however attempt to take a prescriptive approach to what a complaints procedure should look like and, given that the RCVS cannot regulate practices, it has no mechanism for ensuring that complaints are dealt with appropriately.

Good complaints procedures benefit both pet owners and vet practices because a complaint resolved directly by the practice should be much less time consuming and costly to deal with than those escalated beyond the practice. However, there will always be some complaints that cannot be resolved by a practice, in which case consumers need options for escalating a complaint. 

Raising a concern with the Royal College of Veterinary Surgeon

Pet owners can ‘raise a concern’ about a veterinary surgeon to the RCVS. The RCVS has a multi-stage investigation procedure, which considers whether there is a ‘realistic prospect’ that the incident could amount to serious professional misconduct. If there is, the case may be progressed to a disciplinary committee, which can result in the veterinary surgeon being suspended or struck off. However, the RCVS will only deal with the most serious concerns, including:

• Very poor professional performance where there are serious departures from the standards set out in the RCVS Code of Professional Conduct
• Fraud or dishonesty
• Criminal convictions or cautions
• Physical or mental health problems affecting ability to work

The RCVS does not deal with complaints about fees, customer service or those related to negligence, which are common issues experienced by pet owners according to both this research and our previous research on consumer harm in the market. In any case, many of these issues will be determined at the practice level and the RCVS regulates individual professionals only.

Vet Client Mediation Service (VCMS)

The VCMS administers the only Alternative Dispute Resolution (ADR) available to pet owners. It is funded by the RCVS and has been running since 2017. The scheme is delivered by Nockolds Solicitors, who also deliver the Optical Consumer Complaints Service (OCCS).

The VCMS is a mediation service for pet owners who have not been able to resolve a complaint with their veterinary practice. It is free to use for the consumer. The VCMS can deal with any complaint that does not reach the high RCVS threshold of serious professional misconduct. 

In contrast to compulsory ADR schemes in other markets, the VCMS is voluntary, and so a practice must agree to its involvement in a complaint. The VCMS’s 2022-23 Annual Insight Report stated that 72% of practices accepted the invitation to participate in mediation. For the optician’s mediation service run by the same solicitors, service providers are required to let customers know that this service is available if they wish to complain. However, this is not the case in the veterinary market.

Methodology

Qualitative interviews

We conducted 14 qualitative interviews in August-September 2024 with pet owners who have complained to or about their veterinary practice. 

Excluding legal action, the channels available to pet owners to make a complaint and seek redress are: the practice itself, the RCVS and the VCMS. We attempted to recruit a mix of respondents who had used these channels. In the final sample:

• seven had complained directly to their vet practice only;
• the other seven had complained to the RCVS, or at least attempted to, and of these three contacted the VCMS (even if they did not ultimately use mediation).

We particularly wanted to understand the experiences of pet owners who had complex complaints and had taken their complaint further than just their vet practice. Since this is a hard to reach sample, we recruited through a number of channels. The majority of respondents were recruited via a targeted sampling approach using our internal omnibus survey of current and former Which? members. Our Which? Combo panel has over 30,000 participants. We put a question on an omnibus to the full panel asking whether they had experienced complaining to a veterinary practice, or via other channels like the VCMS and RCVS, to identify potential participants.

We also interviewed a pet owner who contacted us directly following our earlier work on the veterinary market, and a further three referred by this individual (to boost the numbers who had experienced using the RCVS complaints channel).

Online survey

Following the qualitative interviews, Yonder on behalf of Which? conducted an online poll in October 2024 of 1,009 pet owners who have experienced a problem with their vet in the past two years. The problems people had experienced included issues with the quality of treatment, prices, bills, customer service, the way treatment options were presented and so on.

The purpose of the survey was to understand:

• The types of problems most often faced 
• Satisfaction with complaints handling when a formal complaint has been lodged
• What, if any, barriers there may be to complaining among those who did not complain.

We screened 4,320 pet owners to achieve a sample of 1,009 pet owners who had experienced an issue in the past two years, giving an incidence of 23% in the past two years, or 17% in the past year.

The consumer experience of complaining and seeking redress

This section sets out our findings on the consumer experience of veterinary complaints processes, from deciding whether to raise a complaint when an issue is experienced, to the experience of doing so through the available channels. Specifically we cover:

• Choosing whether to initiate a complaint, and barriers to doing so;
• The experience of complaining at a practice level;
• Choosing whether to escalate a complaint beyond practice level and the barriers to doing so;
• The experience of escalating a complaint, specifically the experience of:
  • Using mediation through the VCMS;
  • Raising a complaint with the RCVS.

Choosing whether to initiate a complaint

The online survey found that the issues relating to pricing were the most common cause for complaining, with 53% saying their issue was related to excessive pricing and 27% saying the price was higher than they were told. Pricing aside, 23% said they had an issue related to the quality of treatment, 22% with customer service, and 16% with the information presented to them about treatment options. One in ten (11%) said there had been a mistake in the treatment or care of their pet.

 Figure 1: Issues with pricing were the most commonly experienced among pet owners

Not all pet owners who experience some kind of problem with their vet or vet practice go on to make a complaint about the issue. Of the 1,009 pet owners surveyed who experienced an issue in the past two years, more than half (57%) did not make a complaint.

To some extent the likelihood of making a complaint is related to the nature of the complaint. Although excessive pricing was the most common issue experienced by pet owners in our survey, only 39% of people who experienced this complained (against an overall average of 43%). People were most likely to complain if they were charged the incorrect price (61%), while 50% made a complaint if they were dissatisfied with the quality of care / treatment. However, that still leaves a substantial proportion of pet owners choosing not to complain regardless of the nature of the issue.

Some pet owners who chose not to complain said that this was because the issue was not serious enough (17%), or that the issue was resolved without the need for a complaint (18%). In these cases, it may be that there is no unmet need for a resolution. However, nearly two-fifths (38%) were put off by thinking that their complaint would not be successful, whilst a third (33%) were worried about falling out with their vet, and 16% did not know how to complain. This indicates that in many cases, there are barriers that prevent consumers from complaining when they might otherwise want to.

Figure 2: Reasons for not making a complaint

Experience of complaining at the practice level

For the consumers who do decide to complain, the first port of call is speaking to the veterinary practitioner or practice itself. Among those in our survey who had complained, the majority complained to their practice either in person or over the phone, whilst 21% complained in writing to their practice and 8% complained to the corporate group that owns their practice. 

Just over half of the pet owners we surveyed who made a complaint to their practice were satisfied with the way their complaint was handled (56%) and/or the outcomes of their complaint (53%), but a significant minority were not. Three in ten (31%) were dissatisfied with the handling of their complaint, and 35% were dissatisfied with the outcome. In total, 38% were dissatisfied with either the handling or outcome.

Figure 3: A significant minority were dissatisfied with the complaint handling and/or outcome

The qualitative interviews and open ended comments in our survey give some insight into what sets apart a good experience from a bad one. A satisfactory experience of a practice complaints process was often driven by outcomes like receiving compensation or having a mistake rectified by further treatment. Other aspects related to a satisfactory experiences included: 

• Timeliness in responding to and dealing with the complaint
• Acknowledgement of the pet owner’s concerns, and taking accountability if the incident involved a mistake on the vet’s part
• Setting out how the feedback would be used to prevent future issues

“The vet practice was genuinely apologetic for their error, and I received adequate recompense”

“My vet practice is excellent and the error was rectified immediately after I contacted them”

“They were hugely apologetic, corrected the error immediately, and told us the steps they were taking to ensure it didn't happen again”

Those who had a negative experience with their practice’s complaints handling, meanwhile, highlighted the absence of a timely response, accountability and steps for future changes.  

“I didn't hear back from them, even though I emailed them twice”

“There was no accountability of what they did wrong” 

“Although I received an apology, this did not really seem very genuine and I didn’t feel as though there would be any serious repercussions/changes that would be brought about…to improve things for the future”

Choosing whether to escalate a complaint

Our survey findings suggest that a large minority of consumers who complain to their vet practice are dissatisfied with the handling of their complaint, the outcome or both. That amounted to 162 pet owners in our survey. All of these pet owners are potential candidates for taking their complaint further and seeking redress by escalating the complaint. However, very few do. Among pet owners who experienced an issue in our survey, just ten reported having contacted the VCMS, and four reported having contacted the RCVS. None had taken legal action. We therefore need to understand what factors might prevent pet owners from escalating a complaint.

One in seven (14%) said that the complaint was not serious enough to warrant further action, as opposed to identifying some kind of barrier to doing so. However, the majority did indicate that there were barriers that prevented them from taking the complaint further. Three-fifths (59%) said they did not think they would get anywhere if they took their complaint further, whilst over a third (36%) said they did not know how, and a fifth (21%) said they were concerned about falling out with their veterinary practice. A quarter (25%) said the process would be either too time consuming or too complicated. 

Figure 4: Pet owners often did not escalate a complaint because they did not think they would get anywhere or they did not know how

Some of the participants in our qualitative interviews who had complained to the practice emphasised these issues, with some stating that they simply did not know there were other options. Others indicated they were so fatigued by the initial practice complaints procedure that they were discouraged from taking it any further.

“I felt we’d come to the end of the road, I didn’t know there was anything more I could do”

“To be honest, I didn’t know what other options there were [to complain]...I don’t know who they [veterinary practices] are answerable to really” 

“I did consider taking the complaint to the Veterinary Council or whatever they’re called. But at that stage I’d already been dealing with this for over a year…”

We also spoke to a pet owner who had complained to the group that owned the practice, thinking that this was an independent mediator as she felt it had been presented to her in this way.

“I was led to believe they were independent… almost like, not an ombudsman but somebody more independent, I didn’t know it was someone in-house… I’m sure they suggested they were an independent mediator”

Experience of escalating a complaint

In addition to our survey, we interviewed seven pet owners who had escalated their complaint beyond the practice level to understand in depth their experience of doing so. Most of the pet owners we spoke to had a strong negative outlook toward the process, although this will in part be as a result of the nature of the sample - the complaints within our sample tended to be serious in nature, and some of the pet owners we spoke to had spontaneously contacted us to discuss this issue. However, these interviews offered insight into the experience of escalating complaints from a consumer perspective and revealed a number of common issues. 

We spoke to several pet owners who simply felt that they had no effective means of seeking redress, leaving them feeling powerless and unsupported. Some pet owners set the veterinary market apart as one where they have weaker access to redress than others. 

“If something goes wrong with a vet, unless they [the vet practice] decide to be decent… you have not got a prayer” 

“It’s the only aspect of my life where if something goes wrong I don’t have any access to redress”

This ultimately leaves pet owners feeling that they are ‘on their own’, and that the current channels that exist for complaints are not there to support and protect the consumer.

Their feelings of powerlessness are exaggerated by the perception that the practices themselves do have power and access to legal support, meaning there is an imbalance of power between the pet owner and the profession.

"These big corporate vets have lawyers coming out of their ears... There should be someone to help us"

Escalating a complaint within the current system can also mean that pet owners can spend a long time - months, or even years - pursuing a veterinary complaint. This will often involve dedicating a great deal of time to building their case and repeating the details of what might be a traumatic experience for them, particularly when the death of a pet is involved. This can be a very significant emotional burden for pet owners who are already dealing with the grief of losing a beloved pet.  

In this section we will attempt to unpick these insights further by examining pet owners’ experience with and attitude towards the different options currently available to escalate a complaint.

Experience of using mediation through the VCMS

Ten respondents to our survey had contacted the VCMS - some of them were positive about the experience and commented on how quickly they got involved and helped resolve the issue. Others had the opposite experience, with some consumers finding that it took time to get into contact with the VCMS or that the process itself was slow.

Three of the pet owners who took part in our qualitative interviews had been in contact with the VCMS at some point during their complaint journey. One made initial contact but went no further as she said she did not hear back for a month, and by that time was already in the RCVS complaints process. Only one completed the mediation process, but it did not end in a successful resolution. These interview cases tended to be quite serious and complex, though, and so may not reflect a ‘typical’ experience - the VCMS reported a high resolution rate of 84% in its 2022-23 annual report. They do, however, highlight some of the situations where mediation may not be a sufficient avenue for redress, as demonstrated by the below case studies:

We also spoke to a pet owner who had heard of mediation but decided not to use it as he did not think it would be successful - especially given that he was already involved in the RCVS complaints process. Other pet owners interviewed who might have benefited from mediation because they were unhappy with how their practice dealt with their complaint, were not always aware of the mediation scheme’s existence. 

These experiences show that while mediation can be very successful for some, it is not for others, either as a result of the nature of their case, or just because they were not directed towards mediation at an appropriate time. Some pet owners only heard of the VCMS when the complaint had escalated to a point that was unlikely to be resolved by mediation anyway, and others hadn’t heard of the service at all.

Experience of raising a concern with the RCVS

We conducted qualitative interviews with seven pet owners who had contacted the RCVS to escalate their complaint through the RCVS ‘raise a concern’ process. 

In interpreting the experience of those who went through the RCVS process, it is important to consider the nature of many of these complaints. They are not ‘run-of-the-mill’ complaints about minor issues, and instead tend to be complex and serious in nature:

• The complaints may involve an alleged mistake in the delivery of care or treatment, which in the pet owner’s eyes caused significant suffering or the premature death of their pet;
• Pet owners who had a serious complaint like this spoke of the very significant impact the situation had on their mental health;
• These situations can follow complex and expensive treatments like multiple surgeries so the financial losses of complainants can also be very significant;
• Pet owners might appeal initial decisions, and can end up being in the complaints process for months or even years.

As a result of these complexities, complaints that reach this stage are unlikely to be straightforward and easily solved cases. The serious nature of the RCVS process will undoubtedly also have a big impact on the veterinary professionals involved, although this research is focused on the consumer experience. 

The seven pet owners we spoke to who had been through this complaints process all had a negative outlook towards it. Many of them felt that the individuals they dealt with at the RCVS were compassionate and trying to be helpful. Still, their negative outlook was generally driven by a perception that the process as a whole is not there to support pet owners, but to protect vets, and the RCVS is by default “on the vet’s side”.

"It seems like the whole system is there to protect vets"

"The process was totally one sided and I was powerless actually as a customer, as an individual to have my case heard"

This perception is reinforced by the high threshold set for RCVS to take on a complaint initially and then to progress it through the stages of the process. The RCVS only deals with the most serious concerns about very poor professional conduct that involves serious departures from the standards set out in the RCVS Code, or fraud or criminal issues. They do not take on cases of clinical negligence or complaints about fees or service, and might redirect pet owners to the VCMS to pursue these complaints. This can mean that pet owners struggle to get the RCVS to take on their case to begin with - and this in turn reinforces the perception that the RCVS wants to avoid dealing with their complaint, and is not there to support the pet owner. From the point of view of some of the pet owners’ we spoke to though, their case often does involve a “serious departure” from the standards set out in the RCVS Code.

“The RCVS sets the standard for misconduct very high - so basically no case ends up falling under it, and so they get out of it”

The bar for progressing the complaint through the stages is higher still - the complaints process aims to establish whether there is a ‘realistic prospect’ that the incident could amount to serious professional misconduct. Only then might it be progressed to the disciplinary stage. Furthermore, the burden of proof for a disciplinary case is the criminal burden of proof “beyond reasonable doubt” as opposed to the civil “on the balance of probabilities”. The civil standard is more typical among professional regulatory bodies, including health related ones like the General Medical Council and General Dental Council.

These high thresholds leave consumers feeling that it is just about impossible to get their concerns heard and addressed through this route, even if they have gone to great lengths to gather evidence about their experience. Several of the pet owners we interviewed had accessed clinical notes through Subject Access Requests or paid for second opinions from other vets.

“If it’s just your word as a pet owner against the vet - even if you have rock solid proof or a second opinion it gets chucked out and there’s nothing you can do about it"

Some of the pet owners we interviewed who had approached the RCVS about their complaint specifically mentioned the existence and contents of the Code, and how they believed the vet had breached aspects of the Code in the case of their complaint. This led to an increased sense of frustration when they found that the RCVS would not progress their complaint. From the pet owner’s point of view, the RCVS should be enforcing its published Code, but under the current regulatory framework this is not really the case. The RCVS does state that it can pursue complaints that represent “serious departures” from their Code, but interpretation of what constitutes a serious departure can vary, and from the point of view of a consumer with a complaint, the RCVS holds the bar far too high. 

These fundamental aspects of how the RCVS process works ultimately reinforce pet owners’ perception that it exists to protect vets first and foremost. If the threshold for investigation and burden of proof are exceptionally high, the vast majority of complainants will not reach this, even if they have a very serious complaint. This can lead to feelings that a complaint has been ‘dismissed’ and a perception that the RCVS does not want to address it.  

"If you got some kind of justice and felt like you'd been listened to… not made to feel like you're a drama queen then maybe that would help with the healing process. But that's not what you get, you get the door shut in your face and told you're a nuisance"

The pet owners affected wanted to see an independent complaints process that leaves them feeling that their concerns have been fairly considered.

“Maybe there needs to be an independent complaints process where you feel you are more likely to get a fair hearing”

The case study below demonstrates some of the challenges pet owners can face in raising a concern with the RCVS.

Court processes

Pet owners can also seek redress through the courts. However, no pet owners from our quantitative survey had pursued this option. Some participants in our qualitative interviews had considered court proceedings at some point and two were still considering it at the time of their interview, but we interviewed no-one who had actually used the court system.

Pet owners who considered using the courts felt that they had little chance in succeeding via this route, particularly given the element of clinical judgement often involved in these cases and the feeling that it is “their word against the vets”, and that the veterinary practices have access to much more legal support than them. They were further deterred by the fees associated with using the courts. Given the perception that success was unlikely, the fees were considered a major barrier and so pursuing a legal route was not seen as a viable option. 

Discussion and recommendations

This section sets out our recommendations for reforms so that the veterinary services market is better equipped to deal with consumer issues. It includes recommendations for the public enforcement of consumer law in the market and the measures we believe are needed to create adequate provision for private redress when a consumer experiences a problem.  

Public enforcement

The RCVS is the statutory regulator for veterinary professionals. It has Codes of Professional Conduct for veterinary surgeons and nurses and operates a Practice Standards Scheme for veterinary practices, whereby they can become accredited by the RCVS. Regulation of vets is underpinned by the Veterinary Surgeons Act 1966. The Code does make reference to the applicability of consumer law, such as regulation of unfair commercial practices and the non-broadcast code of advertising practice (CAP code), but it is limited in its scope and the RCVS’s ability to enforce consumer protections, as the CMA has identified as part of its market investigation.

We believe that the current set-up for regulation of the veterinary profession, as it relates to protection of consumer interests, is not fit for purpose and that some of the issues that consumers are experiencing when complaining are an inevitable consequence of this. There are two particular issues: the RCVS regulates professionals but not practices, and the RCVS lacks the range of sanctions necessary to be able to hold professionals to account for unfair treatment of customers.

The need for regulation at the practice level

Whilst the regulation of individual professionals is important, it does not reflect the way that many veterinary practices are now run as part of large veterinary groups. This is particularly key in a changing market where practices are less likely to be independent, and veterinary professionals are more likely to be working within a practice team with the practice manager or wider practice group determining policies and procedures rather than the veterinary professionals themselves. The RCVS’s Practice Standards Scheme does set out a framework to promote high standards among practices, but membership of the scheme is voluntary and only 69% of practices are signed up to this approach.

The issue of practice accountability featured in several of our interviews with pet owners who had raised complaints. In most cases, it was the practice manager who dealt with the complaint, including formulating the response, and not the individual veterinarian who had carried out the treatment. In several cases, the pet owner felt let down by the response of the practice as a whole. However, under the current regulatory framework, the RCVS would only be able to hold the individual vet accountable and not the practice. 

Recommendation: The government needs to update the regulatory framework to allow regulation at a practice level rather than solely at the level of an individual professional. This would better reflect the way that the modern veterinary market works, with prices and policies (including complaints) often determined by practice management and not individual professionals. Updated regulation should set out clear duties that ensure vets and veterinary practices act in consumers’ interests.

Appropriate sanctions to enforce consumer rights

Even when the RCVS’s inability to regulate at a practice level does not represent a fundamental barrier to enforcing consumer rights (for example in the case of a small, independent practice), the RCVS would be unlikely to enforce against breaches of consumer rights.

Our survey with pet owners who had experienced an issue showed that many problems fall under the category of consumer rights, like issues around pricing, transparency and quality. The RCVS Code does cover a wide range of issues that include how a veterinary professional should operate in respect of their client (the pet owners). There is guidance on communication about treatment options, obtaining informed consent, prescribing veterinary medicines, keeping clinical records, communicating practice information and fees clearly and supporting pet owners freedom of choice by providing them with the information needed to make an informed decision. 

However, these provisions cannot be effectively enforced by the RCVS because the threshold for a consumer concern to progress through the RCVS complaints process is prohibitively high. The threshold is focused on serious professional misconduct, reflecting that the RCVS’s sanctions are limited to a warning about future conduct, suspension from the veterinary surgeon's register, and removal from the register. The vast majority of concerns regarding consumer rights issues are unlikely to reach the threshold, and removal from the register (either temporarily or permanently) may not be an appropriate sanction. The failure to have appropriate sanctions means that not only will unfair treatment of consumers go unpunished, but there is no effective deterrent to poor behaviour.

Recommendation: The government should ensure that the regulator for veterinary services is sufficiently equipped to independently enforce consumer law as it relates to the provision of veterinary services, including issues such as unfair commercial practices. The regulator needs to have appropriate expertise, powers and sanctions to incentivise compliance and allow for effective, proportionate enforcement that will drive improvements and higher standards in the market.

Private redress

Notwithstanding the need to improve public enforcement of consumer rights in veterinary services, it is also important that pet owners have access to private redress channels to pursue their individual complaints and receive compensation where appropriate. This is especially important given the strong emotional attachment that pet owners have to their animals and the large amounts of money spent on veterinary services. Veterinary care is becoming increasingly expensive, with the average cost of a pet insurance claim having increased significantly in the past decade, and some surgeries costing up to £10,000. 

The first step in seeking private redress is to contact the practice itself, and a public enforcement body could set standards by setting out best practice guidelines for practice complaints processes. This would help to address some of the barriers to complaining identified in our research, in particular that pet owners do not always know how to go about complaining. It could also help to maximise the number of complaints that can be resolved at a practice level by setting out clear expectations for the process. 

Recommendation: As part of reforms to the regulatory framework, veterinary practices should be required to have a written complaint process based on specified criteria to ensure consistency in how complaints are defined, handled and signposted. This will enable consumers to understand how to make a complaint and what to expect.  

However, consumers should also have access to alternative resolution mechanisms for cases when a complaint cannot be resolved at practice level. Alternative Dispute Resolution (ADR) often involves a third party providing mediation, adjudication or arbitration for complaints that cannot be settled directly between a consumer and business. Beyond resolving individual cases, effective ADR schemes drive improvements in a sector by gathering and analysing data on consumer experiences, which can be used to guide businesses and regulators. ADR is also a more affordable alternative for both consumers and businesses than a case going to court. 

Currently, the only ADR available within veterinary services is mediation via the VCMS. Mediation can be a valuable tool for consumers to resolve individual disputes and avoid escalation through courts or referral to an enforcement authority, and we can see particular benefits in the veterinary sector where complaints are especially likely to be emotionally charged. The strong attachment between owners and the pets means any complaint about a situation that has caused suffering to a pet will likely also have caused emotional harm for the owner/s. In situations like these, mediation can be valuable in opening lines of communication between the practice and pet owner, and in taking into consideration the emotional needs of the pet owner when addressing questions of financial redress and the need for an apology or explanation.  

However, mediation is unlikely to be a sufficient or appropriate mechanism to resolve all complaints that have escalated beyond a veterinary practice. We believe there are likely to be significant numbers of consumers for whom their relationship with the practice has broken down to the extent that mediation is not a realistic prospect. There will be others, who may disproportionately be vulnerable consumers, who would simply be unable to effectively navigate a mediation process to reach a fair outcome. This is likely to represent a significant gap in the private redress landscape in veterinary service. It could be filled by the creation of a more comprehensive, mandatory ADR scheme, ideally an ombudsman that offers adjudication in addition to mediation. 

Ombudsmen can provide an enhanced form of ADR by actively investigating disputes and requesting additional information, removing a burden from consumers to present all relevant evidence themselves. Additionally, ombudsman schemes can play a pivotal role in driving improvements, for example by providing advice and training. 

We believe that these fundamental characteristics of an ombudsman offering adjudication would help address some of the key issues we heard about from pet owners in our research, namely:

• The perceived lack of independence of the current avenues available;
• The sense of powerlessness pet owners feel in having their case heard, and the perception that vet practices do hold power;
• The desire among pet owners for complaints to feed through to future changes and improvements in standards.

We believe that mediation should still be offered as a part of this enhanced ADR scheme. There are Ombudsman schemes in other markets that offer mediation as an initial step before adjudication, such as the Rail Ombudsman. Whilst we think that some pet owners would receive better redress through adjudication, it is probable that some would achieve a better outcome through mediation. For example, for some complaints that would be unlikely to be upheld by an adjudicator, mediation (given its collaborative nature) might help secure a positive outcome such as a goodwill gesture for the consumer. In such a case, this could help to maintain a good relationship between the pet owner and the vet or vet practice. This provides a benefit for the business in terms of customer relations and retention, whilst simultaneously alleviating the pet owners’ concerns about ‘falling out’ with their practice, which our research shows is a common barrier to raising or escalating a complaint. 

Our research highlights the varied and complex nature of veterinary complaints, the high sums of money sometimes involved, and the far-reaching impacts on those involved. An ombudsman scheme offering both mediation and adjudication would offer a robust framework for consumers to seek redress, as well as providing a means for complaints data to feed back into driving improvements across the sector and improving outcomes for consumers. A robust system like this could both prevent instances of consumer harm by driving higher standards and reduce the extremely high levels of emotional and financial harm some consumers currently experience when making a complaint. 

Recommendation: Given the complex nature of veterinary care and the significant expenses involved for consumers, there needs to be a more comprehensive and mandatory alternative dispute resolution (ADR) scheme for when issues cannot be resolved at the practice level. This must be clearly signposted to consumers and build on the current mediation service, but it should also ensure that the scheme has the ability to investigate and adjudicate complaints, and to enforce its decisions. We recommend that an ombudsman scheme be introduced to deal with complaints relating to veterinary services for pets.